“Do we need e-invoicing?” is one of the most common questions we hear from D2C founders — usually right after a CA mentions it, or a wholesale buyer asks for an IRN. The honest answer is: it depends on who you’re selling to, not just how much you sell.
Here’s the plain-English version, written for brands that sell mostly to consumers but have a few business orders mixed in.
The short answer
- GST e-invoicing applies to B2B invoices, exports, and supplies to SEZs — once your aggregate annual turnover (AATO) has crossed ₹5 crore in any financial year from 2017–18 onward.
- B2C invoices are outside the mandate. An order from a consumer without a GSTIN gets a regular GST invoice, whatever your turnover.
- If your AATO is ₹10 crore or more, each e-invoice (and credit or debit note) must be reported to the Invoice Registration Portal within 30 days of the document date. This took effect on 1 April 2025.
So a brand that only ever sells to consumers usually doesn’t generate e-invoices for its orders. But very few D2C brands are purely B2C once they grow.
What e-invoicing actually is
E-invoicing doesn’t mean “an invoice sent by email”. It means the invoice details are reported to a government Invoice Registration Portal (IRP), which validates them and returns an Invoice Reference Number (IRN) and a signed QR code. For a business that’s covered, a B2B invoice without an IRN isn’t a valid tax invoice — which matters to your buyer, because it affects their input tax credit.
TAX INVOICE
INV-1183 · 2 Oct
Lumina Home
GSTIN 29ABCDE1234F1Z5
Above: a sample B2B order. The GSTIN switches it to B2B treatment, inter-state supply applies IGST, and the invoice is registered for an IRN before it goes out.
Who needs what, at a glance
| Your aggregate turnover | Orders from consumers (B2C) | Orders from businesses, exports, SEZ |
|---|---|---|
| Never crossed ₹5 crore | Regular GST invoice | Regular GST invoice |
| ₹5 crore – under ₹10 crore | Regular GST invoice | E-invoice (IRN + QR code) |
| ₹10 crore and above | Regular GST invoice | E-invoice, reported within 30 days |
One separate rule worth knowing: very large businesses (aggregate turnover above ₹500 crore) must print a dynamic QR code on B2C invoices. That’s not e-invoicing, and it won’t affect most growing D2C brands.
Where D2C brands get caught out
Most brands that cross ₹5 crore have B2B orders hiding in places nobody thinks of as “wholesale”:
- A customer enters a GSTIN at checkout so they can claim input tax credit. That order is now B2B.
- Corporate gifting orders — Diwali hampers, employee kits — almost always come with a GSTIN.
- Resellers, distributors, and retail partners placing orders over WhatsApp or email, invoiced by hand.
- Export orders, including small international shipments, are covered by e-invoicing too.
The risk isn’t usually the rule itself — it’s that these orders flow through a different, manual path, and nobody notices they need an IRN until a buyer’s accountant asks for one.
A practical checklist
- Confirm your AATO history with your CA. Applicability looks at every financial year since 2017–18, so one strong year is enough to bring you in.
- List every way a B2B order can reach you — checkout with GSTIN, wholesale portal, WhatsApp, email, marketplace business accounts.
- Route all of them through one invoicing system that decides B2B or B2C per order and generates the IRN automatically when it’s needed.
- If you’re at ₹10 crore or more, stop batching invoices. Anything older than 30 days can’t be reported, so a month-end “catch-up” habit becomes a real problem.
- Handle returns properly. Credit notes against e-invoiced sales need to be reported as well, on the same timeline.
How we handle it
Our billing & invoicing module treats this as a per-order decision rather than a separate process. If a GSTIN is captured, the order is invoiced as B2B and an e-invoice is generated when your turnover requires it; consumer orders get a standard GST invoice. Credit notes are raised automatically on returns, and everything exports cleanly for your CA at filing time.
This guide is general information for e-commerce sellers, not tax advice. Rules change — confirm your specific situation with your chartered accountant.