e-Invoicing on your RCM self-invoices: when RCMDOM or RCMIMP applies, and how to report it

If your business has an annual turnover of ₹5 crore or more, you already generate e-invoices on your outward B2B sales. Following the 57th GST Council recommendation, the Goods and Services Tax Network (GSTN) issued an advisory on 16 October 2026 extending e-invoicing to the inward side whenever you raise a self-invoice under reverse charge (A2Z Taxcorp). Instead of keeping that self-invoice inside your accounting software alone, you will report it to an authorised Invoice Registration Portal (IRP) and obtain an IRN. Which of the two new codes you pick comes down to one simple test: look at where your supplier is located.

Key sections and rules

The one question that picks the code: is your supplier in India or outside India?

A recycling plant, trader, or manufacturing unit with turnover above ₹5 crore often handles two very different kinds of reverse-charge bills in the same month. On Monday, you may buy metal scrap from an unregistered local collector in India where Notification 06/2024-Central Tax (Rate) puts the purchase under reverse charge. On Wednesday, you may pay a software firm or testing laboratory located outside India for a service, which is an import of service taxable under reverse charge.

In both cases, your supplier is outside the GST network and does not issue a GST e-invoice. You, the registered recipient, raise a self-invoice. Under the 16 October 2026 GSTN enhancement, both self-invoices go into the e-Invoice system, but under separate supply type codes (TaxReply):

Buying specified domestic goods or services from an unregistered person in India: use RCMDOM. When you receive domestic supplies from an unregistered seller where GST law makes you liable to pay tax under reverse charge (such as metal scrap under Chapters 72 to 81 from an unregistered seller, or notified domestic RCM services from an unregistered provider), you report the self-invoice to the IRP using supply type code RCMDOM.

Importing services from a supplier located outside India: use RCMIMP. When you receive services from a foreign supplier outside India and you are liable to pay IGST under reverse charge as the recipient, you report the self-invoice to the IRP using supply type code RCMIMP.

If your domestic supplier is already registered under GST (for example, a registered Goods Transport Agency under RCM or a registered scrap dealer under forward charge), the supplier has their own GSTIN. RCMDOM is strictly for specified domestic RCM supplies received from unregistered persons.

What e-invoicing on a self-invoice actually changes for you

Up to now, e-invoicing on the GST e-Invoice portal worked in one direction: a registered seller uploaded a B2B sales invoice and got back an IRN and QR code (GSTN Brochure). Self-invoices for unregistered RCM purchases stayed in your internal purchase register and only showed up in summary numbers when you filed your return.

Extending e-invoicing to recipient-generated self-invoices changes the workflow in three practical ways:

1. Your purchase team must generate an IRN, not just a voucher. Raising an internal self-invoice voucher in Tally, SAP, or your ERP is no longer the final step once mandatory reporting begins. That self-invoice has to be pushed to an authorised IRP under RCMDOM or RCMIMP to get a valid IRN.

2. Input tax credit is tied to a valid self-invoice and tax payment. Under Section 36(1)(b) and Section 31(3)(f) of the CGST Act, your right to claim input tax credit on an unregistered RCM purchase rests on paying the tax in cash and holding a valid self-invoice. Once the mandate takes effect via government notification, a self-invoice issued by a taxpayer with AATO of ₹5 crore and above without a valid IRN risks being treated as an invalid document under Rule 48(5) of the CGST Rules.

3. Every unregistered RCM bill leaves a real-time digital trail. Just as outward B2B e-invoices flow straight into the GST system, reporting RCMDOM and RCMIMP self-invoices gives the tax department invoice-level visibility into unregistered domestic purchases and cross-border service imports as they happen.

Who has to do this, and where the rollout stands on 26 October 2026

Two points in the 16 October 2026 GSTN advisory govern who is covered and when mandatory reporting starts (A2Z Taxcorp):

• The turnover threshold is ₹5 crore and above. The facility applies to active registered taxpayers whose Aggregate Annual Turnover (AATO) is ₹5 crore or more in any preceding financial year, matching the current B2B e-invoicing threshold.

• Sandbox testing is live now; the production start date will be notified separately. As of 16 October 2026, GSTN has enabled RCMDOM and RCMIMP in the sandbox (testing) environments of all six authorised IRPs. The binding legal effective date and production rollout date will be announced through government notifications and further GSTN advisories in due time (Taxo Online).

All six authorised Invoice Registration Portals apply the exact same business validations and validation codes for RCMDOM and RCMIMP, following the release note issued by NIC IRP-1:

Developers and ERP teams can also access the NIC e-Invoice API Developer Portal to test encrypted payloads and validation responses (GSTN e-Invoicing Overview).

A worked example (illustrative figures)

The numbers below are made up to show the mechanics. Use your own figures and GST rate.

Suppose a registered metal and e-waste recycler in Pune, Recycler B, has an Aggregate Annual Turnover of ₹12 crore. Because its turnover is above ₹5 crore, Recycler B is covered by e-invoicing. In one week, Recycler B makes three purchases:

• Purchase 1 (Unregistered domestic scrap seller): ₹2,00,000 of copper scrap bought from an unregistered local aggregator in Maharashtra. Because metal scrap from an unregistered seller falls under reverse charge, Recycler B raises a self-invoice under Section 31(3)(f), selects supply type code RCMDOM, uploads the self-invoice to its IRP to generate an IRN, pays the GST in cash under RCM, and claims input tax credit if eligible.

• Purchase 2 (Foreign service provider): ₹1,50,000 paid to a firm in Germany for remote calibration software support on a shredding machine. Because this is an import of services from a supplier outside India, Recycler B raises a self-invoice, selects supply type code RCMIMP, reports it to the IRP for an IRN, and discharges IGST under reverse charge in cash.

• Purchase 3 (Registered domestic scrap seller): ₹4,00,000 of ferrous scrap bought from a registered dealer in Gujarat. Here the seller has a GSTIN and issues a regular B2B e-invoice under forward charge (and Recycler B deducts 2% GST TDS if the contract exceeds ₹2,50,000). Recycler B does not raise a self-invoice and does not use RCMDOM or RCMIMP.

Three inward bills in the same week, three different compliance tracks: RCMDOM for the unregistered domestic RCM purchase, RCMIMP for the imported service, and no self-invoice at all when the domestic supplier is registered.

What this means for your business

Most companies built their e-invoicing setup around their sales and billing module, because only outward invoices needed an IRN. Self-invoices under reverse charge sit in your purchases and accounts payable module. Use the current sandbox window to get your systems ready before the production date is notified:

• Flag unregistered RCM vendors in your master data: Make sure your purchase software clearly separates unregistered domestic RCM suppliers (RCMDOM) from overseas service vendors (RCMIMP) and registered domestic vendors.

• Connect your Accounts Payable module to your IRP: Ask your ERP vendor, GST Suvidha Provider (GSP), or Application Service Provider (ASP) to map inward self-invoice vouchers to the IRP API using the specifications on the NIC e-Invoice API Developer Portal.

• Run sandbox tests now: Push sample RCMDOM and RCMIMP payloads through your chosen portal among the six IRPs (einvoice1.gst.gov.in to einvoice6.gst.gov.in) and verify that IRNs generate without validation errors.

• Watch for the NIC IRP-1 release note and GSTN webinar: Track einvoice.gst.gov.in for the detailed NIC IRP-1 release note, the joint GSTN-IRP webinar schedule, and the government notification setting the mandatory start date.

Law referred

• CGST Act, 2017: Section 9, Section 31(3)(f), Section 36(1)(b)

• CGST Rules, 2017: Rule 48(4) and Rule 48(5)

• GSTN Advisory dated 16 October 2026: 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)

• Official Portals: GST e-Invoice Portal and NIC e-Invoice API Developer Portal

General information based on the CGST Act, the CGST Rules and the GSTN advisory above, as checked on 26 October 2026. Not legal or tax advice; for any notice, contract or filing, consult a chartered accountant or GST lawyer.