GST E-Invoicing for RCM Self-Invoices: What ERPs Must Test

In short: On 16 October 2026, GSTN announced that self-invoices issued under reverse charge can now be tested for e-invoicing in the sandbox of all six Invoice Registration Portals, using two new supply types, RCMDOM and RCMIMP. The production date is not yet announced. Businesses with turnover of ₹5 crore or more should start ERP testing now.

What Happened

According to a GSTN advisory dated 16 October 2026, as reported by TaxGuru and CAclubindia, e-invoicing is being extended to self-invoices that a registered recipient raises when it pays GST under the reverse charge mechanism (RCM). The advisory says the GST Council recommended this extension at its 57th meeting.

Two new supply type codes have been added to the e-invoice framework:

• RCMDOM: self-invoices for specified domestic supplies received from unregistered persons, where the registered recipient pays tax under reverse charge.
• RCMIMP: self-invoices for import of services from suppliers outside India, where the registered recipient pays tax under reverse charge.

When such a self-invoice is reported to an authorised Invoice Registration Portal (IRP) and passes validation, an Invoice Reference Number (IRN) is generated, just like a normal e-invoice.

For now, the facility is live only in the sandbox (test) environments of all six IRPs and on the NIC e-Invoice API sandbox. Both reports say the date for production rollout and for the start of reporting will be announced later, and that scope and applicability will depend on government notifications. Updates are published on the official GST e-invoice portal.

Who Is Affected

The reports state that the change applies to registered taxpayers with aggregate annual turnover (AATO) of ₹5 crore or more, which is the current e-invoicing threshold, subject to notifications. In practice, this touches:

• Companies that buy services from overseas suppliers, such as software subscriptions, cloud services, consulting or advertising, and pay IGST under reverse charge.
• Companies that receive notified supplies from unregistered persons where tax is payable under reverse charge.
• Finance teams, GST Suvidha Providers (GSPs), application service providers and ERP vendors who build and maintain e-invoicing integrations.

What It Means for Your Business

Many companies today create RCM self-invoices manually or in a separate register, outside their e-invoicing flow. Once this facility moves to production, those documents will likely need to be generated through the same IRN process as outward invoices. That has three practical effects:

• ERP changes. Your ERP or billing system must be able to raise a self-invoice with the correct supply type code and send it to the IRP.
• Master data quality. Vendor masters must clearly mark overseas and unregistered suppliers, or the system will not know when to raise RCMDOM or RCMIMP documents.
• Process timing. Teams that prepare RCM documents only at month-end may need a more regular routine once reporting begins.

Exact field rules and validation codes are expected in a release note from NIC IRP-1, and the reports mention a webinar by GSTN and the IRPs. Until then, avoid making final design decisions on details that are not yet published. This is not legal or tax advice; confirm how the change applies to you with your GST adviser.

What to Do Now

1. List your RCM transactions. Pull the last few months of reverse charge entries and separate imports of services from domestic supplies received from unregistered persons.
2. Check your turnover position. Confirm with your finance team whether your aggregate annual turnover crosses the ₹5 crore e-invoicing threshold.
3. Clean vendor masters. Tag overseas suppliers and unregistered suppliers correctly so your ERP can pick the right supply type.
4. Talk to your ERP or GSP partner. Ask when they will support RCMDOM and RCMIMP and request access to their sandbox build.
5. Test in the sandbox. Generate sample self-invoices for both supply types, check IRN generation and note any validation errors.
6. Watch for the release note and notification. Track the e-invoice portal for the NIC IRP-1 release note and the production date, and update your process once they are out.

If you are still setting up basic e-invoicing, our guide on GST e-invoicing integration with ERP explains the core flow. For the wider decisions from the same Council meeting, see what the 57th GST Council means for your ERP and billing.

Frequently Asked Questions

Is e-invoicing for RCM self-invoices mandatory now?

Not yet, according to the reports. The facility is in sandbox testing, and GSTN has said the production date will be communicated later through due process.

What do RCMDOM and RCMIMP mean?

RCMDOM is for self-invoices on specified domestic supplies from unregistered persons under reverse charge. RCMIMP is for self-invoices on import of services under reverse charge.

Which businesses should prepare?

Registered businesses with aggregate annual turnover of ₹5 crore or more that pay GST under reverse charge, along with their ERP, GSP and accounting partners.

How Affix Center Can Help

Affix Center helps businesses in Mumbai and Maharashtra set up and maintain ERP software and its GST integrations, including e-invoicing flows and master data clean-up. We can review your current RCM process, map the changes your ERP needs and help you test in the sandbox before the rollout date.

To plan your ERP changes for this update, contact our team.