GST

Do export of services invoices need e-invoicing under GST?

Author:: Editorial team, serviceexportguide.com
Verified by:: Editorial team
Published: 28 October 2026
Last modified: 30 October 2026
Reading time: 6 min read

Short answer

Export of services invoices need e-invoicing if aggregate turnover in any preceding financial year from 2017-18 exceeded ₹5 crore.²⁵ Notification No. 13/2020-Central Tax, as amended, covers invoices for exports.² An export invoice issued by such a taxpayer without an IRN is not treated as an invoice under rule 48(5).¹ Most individual freelancers are below the threshold.⁵

Applies to	Governed by	Deadline	Penalty	Last verified
Registered persons with aggregate turnover above ₹5 crore in any preceding financial year from 2017-18²⁵	CGST Rules, 2017, rule 48(4) to (6); Notification No. 13/2020-Central Tax, as amended¹²	Scope widens to import of services and reverse charge supplies from 1 January 2027⁶	Invoice without an IRN is not treated as an invoice; continued non-compliance may lead to penal action¹¹⁰	28 October 2026

E-invoicing in GST does not mean the government writes your invoice. You still create it in your own accounting or billing software, then report it to the Invoice Registration Portal (IRP). The IRP returns a unique Invoice Reference Number (IRN), a digital signature and a QR code.⁷ For larger service exporters, that applies to export invoices as well as domestic B2B ones.²

This guide explains who must e-invoice export invoices, which documents are covered, who is exempt, what happens if you do not comply, and the change that takes effect on 1 January 2027. It reflects notifications up to 26 October 2026.⁶

What is e-invoicing for export of services under GST?

E-invoicing for export of services under GST is the requirement in rule 48(4) of the CGST Rules for a notified class of registered persons to prepare invoices with the particulars in FORM GST INV-01, after obtaining an IRN by uploading the invoice information to the common e-invoice portal.¹

Invalid without IRN: rule 48(5) says any invoice issued by such a person in another manner "shall not be treated as an invoice".¹
No duplicate copies: rule 48(6) removes the need for duplicate or triplicate copies for e-invoices.¹
Notified class: set by Notification No. 13/2020-Central Tax, dated 21 March 2020, as amended.²³⁴⁵

The IRP returns the IRN, a digital signature and a QR code for each reported document.⁷

Who must e-invoice export of services invoices?

A registered person must e-invoice export of services invoices once its aggregate turnover in any preceding financial year from 2017-18 onwards exceeds ₹5 crore, unless it falls in an excluded class.²³⁴⁵

Entity type	Must e-invoice?	Why	Best for
Registered exporter with aggregate turnover above ₹5 crore in any year from 2017-18	Yes	Notification 13/2020 as amended covers exports and uses "any preceding financial year"²⁵	Agencies and IT services firms
Registered exporter below ₹5 crore in every year	No	Below the threshold under Notification 10/2023⁵	Most individual freelancers
Special Economic Zone unit	No	Excluded by Notification No. 61/2020-Central Tax³	SEZ units
Government department or local authority	No	Excluded by Notification No. 23/2021-Central Tax⁴	Public bodies
Persons in rule 54(2), (3), (4) and (4A)	No	Excluded in the principal notification since 2020; the e-invoice overview lists insurers, banking companies and financial institutions including NBFCs, goods transport agencies, suppliers of passenger transportation, and suppliers of admission to cinema exhibition in multiplex screens²⁷	Banks, insurers and transport operators

Aggregate turnover under section 2(6) of the CGST Act is computed on an all-India basis for the same PAN and includes exports.⁹ For example, a digital marketing agency or IT services firm with ₹4 crore of export billing and ₹1.5 crore of domestic billing in 2025-26 has crossed the threshold.⁵⁹ An exporter of consulting, design, software or marketing services is not in any of the excluded groups.

How do you e-invoice an export of services invoice?

You e-invoice an export of services invoice by creating it in your own software with the export particulars, reporting it to the IRP to get the IRN, and reconciling GSTR-1.¹⁷⁸¹¹

Check your turnover history for every year from 2017-18 onwards against the ₹5 crore threshold.²⁵
Create the export invoice in your billing or invoicing software, with the rule 46 export endorsement and the recipient's name and address, address of delivery and country of destination.¹¹ See the export invoice format.
Report it to the IRP, which returns the IRN, a digital signature and a QR code.⁷
Report credit and debit notes on export invoices to the IRP as well.⁷
Reconcile GSTR-1 each period, since e-invoice data flows into it.⁸
Prepare for 1 January 2027: add import of services documents to your process if you pay foreign vendors.⁶

Make sure your software can generate e-invoice data for export invoices and credit notes, and receive the IRN and QR code. See invoicing software for exporters.

Which documents and GSTR-1 tables apply to e-invoiced exports?

E-invoicing applies to three document types issued by notified taxpayers to registered persons or for exports: invoices, credit notes and debit notes.⁷ Details reported to the IRP flow into GSTR-1 automatically.⁸

Document	Reported to the IRP?	GSTR-1 table	Best for
Export invoice	Yes⁷	Table 6A⁸	Every export bill
Credit note on an export invoice	Yes⁷	Table 9B (Unregistered)⁸	Reducing an export invoice
Debit note on an export invoice	Yes⁷	Table 9B (Unregistered)⁸	Increasing an export invoice

You can edit auto-populated details in GSTR-1 before filing.⁸ See credit note on an export invoice.

What happens if an exporter does not e-invoice?

If an exporter who must e-invoice issues an export invoice without an IRN, the document is not treated as an invoice under rule 48(5).¹ That can affect your ability to show a valid export invoice for an LUT export or a refund claim.

Officer checks: CBIC Instruction F. No. CBIC-20006/15/2023-GST (18 October 2023) asked tax officers to find out why notified taxpayers were not issuing e-invoices for B2B and export invoices.¹⁰
Declaring exemption: the instruction said taxpayers below the threshold or exempt should declare that on the portal.¹⁰
Penal action: the instruction said continued non-compliance may lead to penal action under the CGST Act.¹⁰

If you are below the threshold or exempt, the declaration on the portal records that position.¹⁰

What is the timeline for e-invoicing of export invoices?

The timeline for e-invoicing of export invoices runs from Notification No. 13/2020-Central Tax in March 2020 to the ₹5 crore threshold from 1 August 2023 and the wider scope from 1 January 2027.²⁵⁶

Date	Change	Best for
21 March 2020	Notification No. 13/2020-Central Tax sets the notified class²	Background
30 July 2020	Notification No. 61/2020-Central Tax excludes SEZ units³	SEZ units
30 September 2020	Notification No. 70/2020-Central Tax adds exports and the "any preceding financial year from 2017-18" test²	All exporters
1 June 2021	Notification No. 23/2021-Central Tax excludes government departments and local authorities⁴	Public bodies
1 August 2023	Threshold of ₹5 crore under Notification No. 10/2023-Central Tax⁵	Exporters between ₹5 crore and higher earlier thresholds
18 October 2023	CBIC Instruction on non-issuance of e-invoices¹⁰	Taxpayers under review
1 January 2027	Scope rewritten by Notification No. 04/2026-Central Tax⁶	Exporters importing services

What changes for e-invoicing on 1 January 2027?

Notification No. 04/2026-Central Tax, dated 26 October 2026, rewrites the scope of Notification 13/2020-Central Tax from 1 January 2027. Notified taxpayers will prepare e-invoices in respect of:⁶

supply of goods or services or both to a registered person;
supply of goods or services or both for exports;
supply received from an unregistered person where tax is payable by the recipient under reverse charge; and
import of services.

Exports stay in scope. The new items (3) and (4) matter to exporters who buy services from abroad, such as a SaaS company paying a foreign cloud provider or an agency paying an overseas freelancer. Documents for those imports will also need to go through the IRP from 1 January 2027.⁶ See RCM on imported services and SaaS tools.

What are the common mistakes with e-invoicing for export of services?

The common mistakes with e-invoicing for export of services are checking only the latest year's turnover, leaving out credit notes, and dropping the rule 46 export particulars.²⁷¹¹

Checking one year only: the test is any preceding financial year from 2017-18 onwards.²
Leaving out exports: export turnover counts in aggregate turnover.⁹
Skipping credit notes: credit and debit notes on export invoices are reported too.⁷
Dropping the endorsement: e-invoicing does not replace the rule 46 export particulars.¹¹
Missing import documents from 2027: import of services comes into scope from 1 January 2027.⁶

Whether e-invoicing applies, and how to handle groups with several GSTINs, depends on your turnover history and structure. If you are near the threshold, confirm the position with a chartered accountant (CA).

How did we verify this?

We checked this page against the sources below on 30 October 2026. Read our methodology or report an error.

Frequently asked questions

Is e-invoicing mandatory for export invoices?+

E-invoicing is mandatory for export invoices issued by notified taxpayers. Notification 70/2020-Central Tax added the words "or for exports" to Notification 13/2020-Central Tax, so export invoices are covered along with B2B invoices.² Taxpayers below the turnover threshold, and exempt classes such as SEZ units, are outside the requirement.³⁵

What is the turnover threshold for e-invoicing?+

The turnover threshold for e-invoicing is aggregate turnover above ₹5 crore in any preceding financial year from 2017-18 onwards, applicable from 1 August 2023 under Notification 10/2023-Central Tax.²⁵ Aggregate turnover is computed on an all-India basis for the same PAN and includes exports.⁹

I crossed ₹5 crore once, years ago. Does e-invoicing still apply?+

E-invoicing still applies if you crossed ₹5 crore once, years ago. The test in Notification 13/2020-Central Tax, as amended, is aggregate turnover in any preceding financial year from 2017-18 onwards, so a single year above the threshold brings you in.²⁵ Check every year's turnover from 2017-18 when deciding.

Are credit notes on export invoices e-invoiced too?+

Credit notes on export invoices are e-invoiced too. The e-invoice system covers invoices, credit notes and debit notes issued by notified taxpayers to registered persons or for exports.⁷ After reporting, credit and debit notes on export invoices populate Table 9B (Unregistered) of GSTR-1 automatically, according to the GST portal FAQs.⁸

Does an SEZ unit need to e-invoice its exports?+

An SEZ unit does not need to e-invoice its exports. Notification 61/2020-Central Tax excluded Special Economic Zone units from the notified class.³ Government departments and local authorities are also excluded, under Notification 23/2021-Central Tax.⁴ A consulting, design, software or marketing exporter outside an SEZ is not in these groups.

Does e-invoicing replace the rule 46 export endorsement?+

E-invoicing does not replace the rule 46 export endorsement. The export invoice still needs the export endorsement and the recipient's name and address, address of delivery and country of destination under rule 46 of the CGST Rules.¹¹ The IRN, signature and QR code are added on top of those particulars.

This page is general information for Indian service exporters, not tax or legal advice. Rules change and outcomes depend on your facts, so confirm with a chartered accountant before acting.

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