The Goods and Services Tax Network (GSTN) has announced an enhancement to the e-invoicing system to facilitate the reporting of recipient-generated self-invoices relating to specified transactions covered under the Reverse Charge Mechanism (RCM).
As announced on 16 October 2026, two new supply types — RCMDOM and RCMIMP — are being introduced for reporting specified self-invoices relating to domestic supplies received from unregistered persons and the import of services, respectively.
The announced functionality is intended for registered taxpayers having an Aggregate Annual Turnover (AATO) of ₹5 crore and above, subject to the applicable statutory provisions and government notifications.
According to the announcement, the functionality is available in the sandbox environments of the six authorised Invoice Registration Portals (IRPs) for testing and integration. The production rollout date and commencement of the associated reporting requirements are yet to be announced.
1. What Are RCMDOM and RCMIMP?
The two new supply types are intended to facilitate the reporting of specified recipient-generated self-invoices through the e-invoicing framework.
| Supply Type | Description |
|---|---|
| RCMDOM | Recipient-generated self-invoices for specified domestic supplies received from unregistered persons where the registered recipient is liable to pay GST under RCM. |
| RCMIMP | Recipient-generated self-invoices for import of services from suppliers located outside India where the registered recipient is liable to pay GST under RCM. |
RCMDOM: Domestic Supplies under RCM
RCMDOM relates to specified domestic supplies received from unregistered persons where the recipient is liable to pay tax under the applicable Reverse Charge Mechanism provisions.
For example, a registered business receiving a legal service from an unregistered domestic supplier must examine whether the transaction falls within a category notified for RCM and whether the recipient is liable to pay GST.
Where the applicable law requires the recipient to issue a self-invoice, the new functionality is intended to facilitate reporting of that invoice through an authorised IRP, subject to the applicable requirements.
RCMIMP: Import of Services under RCM
RCMIMP relates to recipient-generated self-invoices for import of services from suppliers located outside India where the registered recipient is liable to pay GST under RCM.
For example, a registered business receiving consultancy or another service from a foreign service provider must examine the applicable import-of-services provisions, place-of-supply rules, taxability and reverse charge requirements.
The new supply type is intended to facilitate reporting of the relevant self-invoices through the e-invoicing system, in accordance with the applicable legal and technical requirements.
Important: The introduction of these codes does not, by itself, make every purchase from an unregistered domestic supplier or every overseas service transaction liable to RCM. The underlying transaction must independently satisfy the applicable statutory conditions.
2. Applicability and the ₹5 Crore Turnover Threshold
According to the GSTN announcement dated 16 October 2026, the new functionality is intended for registered taxpayers having an Aggregate Annual Turnover (AATO) of ₹5 crore and above.
However, the turnover threshold alone should not be treated as confirmation that every RCM transaction must be reported through e-invoicing.
The applicable statutory provisions, government notifications, prescribed conditions and relevant exclusions must be examined before determining whether a particular taxpayer or transaction falls within the reporting requirement.
Taxpayers should distinguish between the following questions:
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Whether GST is payable under the Reverse Charge Mechanism;
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Whether the recipient is legally required to issue a self-invoice;
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Whether the taxpayer and transaction fall within the applicable e-invoicing requirements; and
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From which date reporting through an authorised IRP becomes mandatory.
These are separate compliance questions and should not be treated as interchangeable.
3. Existing Legal Requirement for Self-Invoicing
Section 31(3)(f) of the Central Goods and Services Tax Act, 2017, provides for the issue of an invoice by a registered person liable to pay tax under Section 9(3) or Section 9(4) in respect of qualifying supplies received from a supplier who is unregistered on the date of receipt.
The requirement must be read with the applicable provisions of the CGST Act and the relevant rules.
Under Rule 47A of the CGST Rules, 2017, where an invoice is required to be issued under Section 31(3)(f), the recipient must issue the invoice within 30 days from the date of receipt of the relevant supply of goods or services, or both.
The statutory provisions governing import of services and IGST under reverse charge must be examined separately, as applicable to the particular transaction.
The introduction of RCMDOM and RCMIMP concerns the proposed reporting of specified recipient-generated self-invoices through the e-invoicing system. It should not be confused with the existing legal requirement to issue a self-invoice.
4. Difference Between a Self-Invoice and an E-Invoice
A self-invoice and an e-invoice are related to different aspects of GST compliance.
Self-invoice: An invoice issued by the recipient where the applicable GST provisions require the recipient to issue an invoice for a qualifying transaction.
E-invoice: An invoice whose prescribed particulars are reported to an authorised Invoice Registration Portal (IRP) under the applicable e-invoicing framework, resulting in the generation of an Invoice Reference Number (IRN) when the submission is successfully validated.
The new RCMDOM and RCMIMP supply types are intended to facilitate reporting of specified recipient-generated self-invoices through this framework.
The introduction of a new supply type does not, by itself, replace the underlying statutory requirements relating to RCM liability, self-invoicing, tax payment or input tax credit eligibility.
5. Current Implementation Status
The GSTN announcement states that the necessary system enhancements for RCMDOM and RCMIMP have been implemented in the sandbox environments of all six authorised IRPs.
The sandbox facility is intended to enable taxpayers, GST Suvidha Providers (GSPs), Application Service Providers (ASPs), ERP providers and other integration partners to test the functionality and prepare their systems.
The announcement does not specify a production rollout date or confirm the commencement of mandatory reporting under the new functionality.
Accordingly, the availability of the facility for sandbox testing should not be interpreted as confirmation that mandatory IRN reporting for these self-invoices has already commenced.
Taxpayers should monitor official announcements, the detailed technical release note and the relevant statutory notifications before determining their compliance obligations.
6. Sandbox Testing and Technical Preparation
According to the announcement, the new supply types have been incorporated into the sandbox environments of the six authorised IRPs.
The NIC e-Invoice API Developer Portal is available at:
https://einv-apisandbox.nic.in/
The announcement states that the implementation, business validations and validation codes for RCMDOM and RCMIMP are intended to be uniform across the six authorised IRPs, in accordance with the technical specifications and release note to be issued by NIC IRP-1.
Taxpayers and integration partners should refer to the official release note for detailed data fields, validation requirements and operational procedures.
Official e-Invoice portal:
7. Practical Impact on Businesses and GST Practitioners
The proposed enhancement may require eligible taxpayers and their technology partners to review existing invoice-generation, accounting and reporting processes.
The following preparatory steps may be considered:
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Review RCM transactions: Identify transactions involving domestic unregistered suppliers and import of services that may fall within the applicable RCM provisions.
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Verify self-invoicing requirements: Determine whether a self-invoice is required under the applicable GST provisions for each relevant transaction.
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Check e-invoicing applicability: Examine the turnover threshold, applicable notifications, statutory conditions and relevant exclusions.
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Coordinate with ERP and accounting providers: Assess whether the accounting or ERP system can support the new supply types and prescribed validations.
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Maintain proper documentation: Keep appropriate records of supplier details, transaction values, invoices, RCM tax payments and input tax credit, where applicable.
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Monitor official developments: Review the technical release note, government notifications and production rollout announcement when issued.
These are preparatory measures. The precise reporting obligations and timelines will depend on the applicable legal framework and official implementation details.
8. What Should Taxpayers Do Next?
Taxpayers should not assume that mandatory reporting has commenced merely because the new functionality is available in the sandbox.
Eligible businesses may review their RCM processes, consult their accounting or ERP providers where necessary, and monitor official communications for the production rollout date and applicable legal requirements.
Once the relevant statutory notifications and technical specifications are available, taxpayers should assess the changes required in their invoicing, accounting and GST compliance systems.
Conclusion
The introduction of RCMDOM and RCMIMP represents an enhancement to the GST e-invoicing framework for reporting specified recipient-generated self-invoices under RCM.
The functionality is available for sandbox testing and integration, according to the GSTN announcement dated 16 October 2026. However, the production rollout date and commencement of the associated reporting requirements are yet to be announced in that notice.
Taxpayers should distinguish between existing legal obligations relating to RCM and self-invoicing and the proposed e-invoice reporting requirements. Compliance decisions should be based on the applicable statutory provisions, government notifications and official technical guidance.
Official References
GSTN announcement 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).
Reported advisory link: https://www.gst.gov.in/newsandupdates/read/678
Official e-Invoice portal: https://einvoice.gst.gov.in
NIC e-Invoice API Developer Portal: https://einv-apisandbox.nic.in/
Relevant legal provisions:
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Section 31(3)(f) of the CGST Act, 2017 — recipient-issued invoices for qualifying supplies received from unregistered suppliers.
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Rule 47A of the CGST Rules, 2017 — time limit for issuing invoices where the recipient is required to issue them.
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Applicable provisions of the IGST Act and the relevant RCM notifications for import of services, where applicable.
Disclaimer: This article is intended for general informational purposes and should be read with the applicable provisions of GST law, government notifications and official technical specifications. The announcement's reported implementation status should not be treated as a substitute for verification of the applicable statutory requirements.