GSTN Opens Sandbox for E-Invoicing of RCM Self-Invoices: RCMDOM and RCMIMP Supply Types

The Goods and Services Tax Network has opened the e-invoicing system to self-invoices raised by recipients under reverse charge. In its advisory of 16 October 2026, titled Introduction of e-Invoicing Facility for Recipient Generated Self Invoices under Reverse Charge Mechanism for Domestic Supplies from Unregistered Persons (RCMDOM) and Import of Services (RCMIMP), GSTN says two new supply types have been built into the Invoice Registration Portals so that a registered recipient can report its own self-invoice and obtain an Invoice Reference Number. The facility is live only in the sandbox environments of all six IRPs for now; the production date and the date from which reporting becomes mandatory have not been fixed.

The advisory gives effect to item 18.4 of the recommendations of the 57th GST Council meeting of 8 October 2026, which proposed extending e-invoicing to domestic supplies received from unregistered persons where tax is payable under reverse charge, and to the import of services, for taxpayers with aggregate annual turnover of ₹5 crore and above. That is the same turnover test that has governed supplier-side e-invoicing since 1 August 2023, when Notification No. 10/2023-Central Tax dated 10 May 2023 replaced the words ten crore rupees with five crore rupees in Notification No. 13/2020-Central Tax. The earlier report on the 57th GST Council recommendations covers the rest of that package.

RCMDOM and RCMIMP: the two new supply types

Until now the IRP has accepted documents from the supplier side only. A registered supplier reports its B2B invoice, credit note or debit note, and the IRN travels with that document. The advisory extends reporting to the recipient for two specific transactions. RCMDOM is the supply type for a self-invoice covering specified domestic supplies received from an unregistered person, where the registered recipient pays tax under reverse charge. RCMIMP is the supply type for a self-invoice covering import of services from a supplier located outside India, again with the registered recipient paying the tax. In both cases the recipient selects the supply type while reporting through an authorised IRP, and the IRN is generated once the document passes validation.

The legal document being digitised is the invoice that section 31(3)(f) of the CGST Act already requires. A registered person liable to pay tax under section 9(3) or 9(4) must issue an invoice for goods or services received from an unregistered supplier, and an overseas service provider is by definition unregistered in India. Since 1 November 2024, rule 47A, inserted by Notification No. 20/2024-Central Tax dated 8 October 2024, has required that self-invoice to be issued within thirty days from the date of receipt of the supply. The advisory does not change that time limit. What changes, once the facility goes live in production, is that the self-invoice of a covered taxpayer will need an IRN in the same way its outward B2B invoices do.

Side by side on the IRP, the three reporting streams differ in ways that matter for ERP mapping.

What is live in the sandbox and what is still pending

The two supply types are available for testing on NIC IRP-1 (einvoice1), NIC IRP-2 (einvoice2), Cygnet IRP-3 (einvoice3), Clear IRP-4 (einvoice4), EY IRP-5 (einvoice5) and IRIS IRP-6 (einvoice6), and on the NIC e-Invoice API Developer Portal. GSTN says the business validations and validation codes will be uniform across all six portals and will follow the technical specifications and release note to be published by NIC IRP-1. GSPs, ASPs, ERP vendors and in-house integration teams are asked to complete development, integration and testing in the sandbox now, and to brief their own ecosystem partners.

Four things remain open. The production rollout date and the date from which reporting becomes mandatory are to be communicated separately. The scope, applicability and effective date depend on statutory notifications that have not yet been issued, so the ₹5 crore figure in the advisory is the intended coverage rather than a legal threshold today. The NIC IRP-1 release note, which will carry the schema fields, validation rules and error codes for the new supply types, has not been published. A webinar by GSTN and the IRPs is planned, with details to follow. Until those arrive, nothing in the advisory requires a taxpayer to generate an IRN on a self-invoice, and no IRP will do so outside the sandbox.

How the self-invoice e-invoice interacts with ITC timing

The compliance stakes on self-invoices are already higher than most finance teams treat them. Under rule 36(1)(b), input tax credit on a reverse charge supply from an unregistered person is availed on the section 31(3)(f) invoice, subject to payment of the tax. Circular No. 211/5/2024-GST dated 26 June 2024 clarified that the section 16(4) time limit for that credit runs from the financial year in which the recipient issues the self-invoice, not the year in which the supply was received, provided the tax is paid and the other conditions of sections 16 and 17 are met. The same circular warned that a recipient who issues the invoice late and pays the tax after the time of supply is liable to interest on the delayed payment and may face penal action under section 122. An IRN on each self-invoice gives the department a timestamped record of exactly when the document was raised, which makes the thirty-day rule in rule 47A far easier to test in audit.

An illustration shows why the dates need watching. A company with AATO of ₹40 crore receives legal services from an overseas law firm on 20 November 2026 and the fee is ₹10,00,000. Tax is payable under reverse charge at 18 per cent, so IGST of ₹1,80,000 is due. Under rule 47A the self-invoice must be issued by 20 December 2026, thirty days from receipt. Once RCMIMP reporting is in production, that self-invoice would also need an IRN. If the company instead raises the self-invoice only on 15 April 2027 after an audit query, the credit of ₹1,80,000 falls into Financial Year 2027-28 for the section 16(4) deadline under Circular 211, but the ₹1,80,000 of tax carries interest from the original due date and the delayed invoice is open to a section 122 penalty. The e-invoice record would show the April date on its face.

Reporting of these transactions in the return does not change with the advisory. The recipient continues to declare the reverse charge liability in GSTR-3B and take the credit in Table 4(A)(3), the table discussed in the earlier note on ICAI FAQs on import-service RCM credit in GSTR-3B. The Council has separately recommended a new rule 86D for an electronic statement of tax paid on reverse charge and credit claimed, to take effect from the return for April 2027; the self-invoice IRNs generated under RCMDOM and RCMIMP are the natural feed for that statement, although the advisory does not say so.

What a ₹5 crore-plus business should set up before the production date

Three items are worth doing now rather than after the notification. The first is a clean population of reverse charge inward supplies in the ERP, split between unregistered domestic suppliers and overseas service providers, because the two will map to different supply types and the self-invoice series for each should be distinct. The second is a test connection to the sandbox of whichever IRP the business already uses for outward invoices, so that the recipient-side JSON can be validated as soon as the NIC release note lands. The third is a check of the self-invoice calendar against rule 47A, since any business that is late today will be late in a more visible way once the IRN exists. For teams new to the IRP mechanics, the guide to e-invoicing applicability, IRN generation and the 30-day reporting rule explains the supplier-side process that recipients will now mirror, and the note on time of supply for services under reverse charge sets out the payment-date and 60-day tests that fix when a reverse charge liability, and with it the interest in the example above, arises.

Two questions the advisory leaves unanswered will decide how much work this creates. One is whether the thirty-day reporting window that already applies to outward documents of taxpayers with AATO of ₹10 crore and above will also apply to self-invoices, which would compress the rule 47A window and the IRP window into the same month. The other is which domestic supplies count as specified for RCMDOM, since the advisory uses that word without listing categories and the reverse charge entries covering unregistered suppliers sit in more than one notification under sections 9(3) and 9(4). Both should be settled by the statutory notifications and the NIC release note. Updates will appear on the e-invoice portal.

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