India Delays B2C Requirements from 1 October Go-Live

The weeks leading up to the 1 October go-live of the Indian CTC reform have been marked by  growing voices echoing concern about whether this is the right time for such fundamental change, and asking if the underlying government infrastructure indeed is robust enough. Several industry associations such as the Confederation of GST Professionals and Industries (CGPI) and the India Cellular and Electronics Association (ICEA) have, for these reasons, submitted formal requests for deferral of the go-live date. However, from government sources the response as late as yesterday was that the plan remained in play: an all-engines-go into implementation of the first phase of the planned continuous transaction controls (CTC) e-invoicing regime.

However, despite this ambition, it’s clear that many changes have taken place behind the scenes in the final days and hours leading up to the go-live. Information that had been provided informally through publicly organized webinars by the GSTN Council and FAQs on the GSTN portal, were today codified into law through Notification No. 70/2020 of 30 September. In the last few days, companies in scope have been receiving emails with clarification on several technical questions and concerns.   Further information and context have been made available through public sources.

The most surprising news was announced just moments ago on Twitter by CBIC. In a last minute move to accommodate the concerns, deferral of the B2C-specific requirements of the CTC reform have been announced, namely the obligation to include a QR code on B2C invoices as of 1 October. This requirement will instead apply two months later, on 1 December, as outlined in yet another legal instrument: Notification 71/2020 of 30 September 2020. This eleventh hour update is surprising in that the vast wave of complaints raised by industry have been related to the B2B obligations, which instead appear to be going live as scheduled at the time of writing.