The self-invoice has long been the most neglected document in a finance team's file. It is raised late, sometimes not at all, and discovered only when an auditor or an officer asks for it. That casual treatment is about to get much harder to sustain.

What the GST Council has recommended

At its 57th meeting on 8 October 2026, the GST Council recommended extending e-invoicing to two transactions that have so far stayed outside it: reverse-charge purchases from unregistered persons, and the import of services. To support this, GSTN has opened two new supply types in the sandbox environments of all six IRPs.

• RCMDOM — self-invoices for specified domestic supplies received from unregistered persons, where the registered recipient pays tax under RCM.
• RCMIMP — self-invoices for services imported from suppliers outside India.

Who is covered

Every taxpayer already required to issue e-invoices, that is, registered persons with an aggregate annual turnover of Rs 5 crore and above. No new class of taxpayer is being brought in. What changes is that your existing e-invoicing obligation will extend to your reverse charge purchases.

What changes in practice

Until now, generating an e-invoice was the supplier's job. Under the proposed change, the recipient reports the self-invoice to an authorised IRP and selects RCMDOM or RCMIMP. Once the details pass validation, the IRP generates an IRN. The self-invoice will carry a digital footprint from the day it is raised.

Why it matters

Self-invoices already have to be issued within 30 days of receiving the supply, under Rule 47A read with Section 31(3)(f), in force since 1 November 2024. Input tax credit on reverse charge rests on them. Once they are backed by an IRN, a late or missing self-invoice becomes much harder to explain. Expect any gap between the RCM liability declared in GSTR-3B and the IRNs actually generated to become an easy analytics flag.

Where things stand

The functionality is live in the sandbox environments of all six IRPs, with uniform validations across them. The amending notification, the effective date and the production rollout are still awaited. GSTN has said these will be communicated in due course. Nothing is mandatory yet, but the testing window has opened.

What should businesses do now

1. List every RCM purchase from unregistered persons and every imported service, such as overseas consultancy or foreign software subscriptions.
2. Get a firm delivery date from your ERP vendor or GSP for RCMDOM and RCMIMP support, and start testing in the sandbox.
3. Tighten the self-invoice process: who raises it, by when, and who reviews it.
4. Reconcile the RCM tax paid against the self-invoices issued, every period.

The lesson from every earlier phase

Each earlier phase of e-invoicing taught the same thing. Businesses that tested early went live quietly, while those that waited spent their first month fixing rejections. The notification will fix the date. The sandbox is open now, and that head start lasts only until it does.