Do I need an IRN for an RCM purchase from a registered supplier?

Not under this change. Notification 04/2026-Central Tax covers purchases from a seller who is not registered, and imports of services. If the seller is registered, the seller makes the tax invoice. Example: you get a ₹1,00,000 freight bill from a registered goods transport agency, and you pay the GST under RCM. This bill is not a self-invoice made by you, so you do not need an IRN for it.

Does a business with ₹3 crore turnover have to do this?

No. This change adds two new kinds of document for businesses that already have to make e-invoices. That means businesses with turnover above ₹5 crore in any year since 2017-18. The notification does not change this limit. Example: a trader with ₹3 crore turnover makes RCM self-invoices as before. A trader whose turnover went above ₹5 crore in 2023-24 must e-invoice them from 1 January 2027.

Is import of goods covered?

No. The notification says import of services only. It does not mention import of goods. Example: a machine worth ₹5,00,000 imported from Germany is not covered. Software consulting worth ₹5,00,000 from a US company is covered.

Do I need to do anything before 1 January 2027?

Nothing is due before that date. But changes to billing software can take time. The e-invoice format (Form GST INV-01) also changes to schema version 1.2 on the same date, with two new codes. Example: your accounts team makes RCM self-invoices in a spreadsheet. Now is a good time to check if your software can send them to the invoice registration portal (IRP).

E-Invoicing for RCM and Import of Services From 1 Jan 2027

From 1 January 2027, businesses that already make e-invoices must make them for two more kinds of documents. The first is the self-invoice for a reverse charge purchase from a seller who is not registered. The second is the document for an import of services.

Nothing changes before that date. We are writing this because our 57th GST Council post said only that e-invoicing "is extended", with no date. A reader could think it is already in force. It is not.

The short version

Date: 1 January 2027. Notification 04/2026-Central Tax is dated 26 October 2026.
New documents covered: (1) goods or services you buy from a seller who is not registered, when you pay the tax under reverse charge, and (2) import of services.
Not covered: import of goods, and purchases from registered sellers.
Who must do it: only businesses that already make e-invoices. That means turnover above ₹5 crore in any year since 2017-18. This limit has not changed.
New format: the e-invoice schema moves to version 1.2. It has two new codes, RCMDOM and RCMIMP.

What the notification says

Notification 04/2026-Central Tax changes Notification 13/2020-Central Tax. The older notification says which supplies need an e-invoice. The new one adds two items to the list. After the change, e-invoicing covers supplies of goods or services:

to a registered person;
for exports;
received from a person who is not registered, when the buyer pays the tax under reverse charge; or
import of services.

Items 1 and 2 are the old rules. Items 3 and 4 are new. They start on 1 January 2027.

Another notification, 05/2026-Central Tax, changes the CGST Rules. It also changes the e-invoice form (Form GST INV-01) from the same date. The schema becomes version 1.2. The field for the type of supply gets two new codes:

Code	Meaning
RCMDOM	Domestic supply from a person who is not registered, under RCM
RCMIMP	Import of services

Why this is new for RCM purchases

Usually the seller makes the invoice. But when you buy from a seller who is not registered, under reverse charge, the seller cannot give a tax invoice. So you make a self-invoice. See our reverse charge (RCM) explainer for how this works.

From 1 January 2027, if you already make e-invoices, you must report this self-invoice to the invoice registration portal (IRP). You will get an invoice reference number (IRN), as you do for your sales invoices.

An import of services is similar. The foreign company does not give an Indian tax invoice. You pay the IGST yourself under reverse charge. The new code RCMIMP marks this kind of document.

Example: a company with ₹12 crore turnover pays ₹50,000 a month to a landlord who is not registered. The RCM tax at 18% is ₹9,000 a month. The tax does not change. What changes in January is the paperwork. The company reports the monthly rent self-invoice to the IRP, with supply type RCMDOM.

Example: the same company pays ₹2,00,000 to a US company for software consulting. The IGST at 18% is ₹36,000 under reverse charge. From January, the document is reported as RCMIMP.

You can work out the tax in both examples with our RCM calculator. The calculator does not make e-invoices.

What we do not know yet

The notification tells us what is covered and when. It does not tell us how the portal will handle each case. For example, we do not know how a seller with no GSTIN will be entered. We have not seen the IRP's technical instructions. Please wait for them before you build anything detailed. Also ask your software provider.

What to do before January

Check if you must make e-invoices. Is your turnover above ₹5 crore in any year since 2017-18? If you already make e-invoices on your sales, then you do.
List your RCM purchases from sellers who are not registered, and your imports of services. Rent, legal fees from individuals and sponsorship are common examples. See the list in the RCM explainer.
Ask your billing or ERP software provider if they will support schema version 1.2 and the two new codes, and by when.
Keep paying RCM as you do now. The cash payment and GSTR-3B Table 3.1(d) do not change.

Summary

From 1 January 2027, e-invoicing covers RCM self-invoices for purchases from sellers who are not registered, and imports of services.
Import of goods and purchases from registered sellers are not covered.
Only businesses that already make e-invoices are affected. The ₹5 crore limit is the same.
The invoice format moves to schema 1.2, with the codes RCMDOM and RCMIMP.
Nothing changes before 1 January 2027.

Sources

CBIC Tax Information Portal: GST notifications
Notification 04/2026-Central Tax, 26 October 2026 (changes 13/2020-Central Tax)
Notification 05/2026-Central Tax, 26 October 2026 (Central Goods and Services Tax (Amendment) Rules, 2026: Form GST INV-01)

We read both notifications on 6 November 2026 on third-party tax sites. We did not compare them with the Gazette copies. The ₹5 crore limit comes from the older Notification 13/2020-Central Tax, which Notification 04/2026 does not change. Please check the latest text before you file. This is not legal advice.