INDIA: E-Invoicing Reform Postponed Until 1 October 2020

With roughly two weeks to go until the first mandatory phase of India’s e-invoicing reform was set to go live, the GST Council has now decided to slam the breaks and halt the go-live. Or at least, bring it to a significant temporary standstill of 6 months, until 1 October 2020.

Following a long list of complaints — both from the private sector toward the GST Council, as well as from the GST Council vis-á-vis the IT infrastructure provider that powers the GST Network, Infosys — the council decided to revisit the 1 April go-live in a recent meeting held today, Saturday 14 March.

The GST council made a number of important decisions, including most notably:

• Delaying the first mandatory go-live of India’s e-invoicing reform with six months, from 1 April 2020 until 1 October 2020
• Delaying the obligation for B2C invoices (issued by the largest taxpayers in India, with a threshold above Rs.500 Crore) to include a QR code, from 1 April 2020 until 1 October 2020
• Excluding certain types of taxable persons from the scope of the e-invoicing reform and the obligation to generate QR codes (a few examples include insurance companies, banks and other financial institutions, non-banking financial institutions, passenger transportation services)
• Postponing the entry into force of the new GST returns until 1 October 2020
• Calling the chairman of Infosys to attend the next three GST Council meetings for the purpose of reporting status updates of technical and infrastructure improvements to the underlying IT platforms that are the foundation of the on-going GST control reforms

The decisions made in the 39^th meeting of the GST Council will require either that the legislative framework (Notifications) published in early December be amended or entirely replaced with new ones to reflect the new reality. However, given the recent economic volatility triggered by the ongoing pandemic, it wouldn’t be unreasonable to expect even further delays to the roll out of this reform. Only once both global markets as well as the underlying technical platforms of the GST control reform seem to stabilize will the post-October timeline of the roll out be fully certain.