E-Invoicing for RCM Self-Invoices: RCMDOM and RCMIMP Explained

E-Invoicing for RCM Self-Invoices: RCMDOM and RCMIMP Explained

E-invoicing for RCM self-invoices is coming. In Advisory No. 678 dated 16 October 2026, GSTN enabled e-invoicing for invoices that a registered recipient issues to itself under the reverse charge mechanism (RCM). Two cases are covered: specified purchases from unregistered persons in India, and import of services. For businesses with aggregate annual turnover (AATO) of ₹5 crore and above, these self-invoices will need an Invoice Reference Number (IRN), just like sales invoices.

The key point for finance heads and CA firms is timing. The facility is live only in sandbox on all six Invoice Registration Portals (IRPs). GSTN has not announced a production date. Until a notification says otherwise, IRN generation for self-invoices is not mandatory. That leaves a window to fix data, controls and ERP logic before it is.

What GSTN announced

The change follows a recommendation of the 57th GST Council meeting to extend e-invoicing to domestic supplies from unregistered persons taxed under RCM, and to import of services. GSTN has added two new supply type codes to the e-invoice schema:

The flow is simple. The recipient selects RCMDOM or RCMIMP as the supply type when it reports the self-invoice to an authorised IRP. If the invoice passes validation, the IRP returns an IRN. GSTN says business validations and error codes will be the same across all six IRPs. NIC IRP-1 will publish a release note with field-level specifications, and GSTN and the IRPs plan a webinar.

Who it applies to and where things stand

Watch the threshold wording. The current e-invoicing mandate (Notification 10/2023-Central Tax, from 1 August 2023) applies where AATO exceeds ₹5 crore. The advisory says "₹5 crore and above". A business at exactly ₹5 crore should wait for the final notification.

Entities exempt from e-invoicing today, such as banks, insurance companies, NBFCs and goods transport agencies, should also check whether the notification keeps their exemption for self-invoices. The advisory does not address this.

The law has not changed: self-invoicing is already mandatory

E-invoicing changes how a self-invoice is reported, not whether it must be issued. These rules already apply.

1. 1

   Issue the self-invoice within 30 days

   • Section 31(3)(f) of the CGST Act: a registered recipient paying tax under RCM on supplies from an unregistered supplier must issue an invoice for that supply. For import of services, the recipient issues the self-invoice because the overseas supplier is outside the GST system.
   • Rule 47A of the CGST Rules: this self-invoice must be issued within 30 days of receipt of the goods or services. Rule 47A has applied since 1 November 2024.
2. 2

   Get the time of supply right

   • Services (Section 13(3)): where the recipient must issue the invoice, the time of supply is the earlier of the date of payment and the date the recipient issues the invoice. This has applied since 1 November 2024.
   • Goods (Section 12(3)): follow the RCM time-of-supply rules in Section 12(3) for each transaction.
   • Services from an overseas associated enterprise: the time of supply is the date of entry in the books of the recipient or the date of payment, whichever is earlier.
   • Do not apply a blanket "60 days from invoice" rule. That test depends on a supplier invoice, which an unregistered or overseas supplier may not issue.
3. 3

   Pay tax in cash, then claim ITC

   • RCM tax is paid in cash, under Section 9(3) or 9(4) of the CGST Act (Section 5(3) of the IGST Act for imported services). It cannot be paid from the ITC ledger.
   • ITC is claimed on the self-invoice under Rule 36(1)(b), after the tax is paid.
   • CBIC Circular 211/5/2024-GST (26 June 2024) clarifies that for supplies from unregistered persons, the Section 16(4) time limit runs from the financial year in which the recipient issues the self-invoice.
   • Late payment of tax attracts interest. Late or no issuance of the self-invoice can attract penalty under Section 122.

E-invoicing will make these dates visible. Once an IRN carries the self-invoice date, gaps between receipt, invoice, payment and ITC claims are easier for the department to spot.

Readiness checklist for finance teams

How Figment's products fit in

GSTCPC is Figment's GST compliance software. E-invoices and e-way bills are generated from the same records used to file returns, so the invoice registered on the IRP and the one in the return stay consistent. GSTCPC also tracks eligible ITC and reports mismatches before GSTR-3B is filed, which helps when matching RCM tax paid with ITC claimed.

For companies that want to generate IRNs from their own ERP, Figment's e-Invoice API provides IRN generation, bulk IRN generation, cancellation within 24 hours and e-invoice lookup. It works with SAP ECC and S/4HANA, Oracle, Microsoft Dynamics 365, Tally Prime and in-house ERPs, and sandbox access is available on request. Figment is a GSP-authorised provider (GSP APIs).

Support for the new RCMDOM and RCMIMP supply types will depend on the final NIC specifications and notification. Speak to the Figment team about sandbox testing.

Key takeaways

• GSTN Advisory No. 678 (16 October 2026) adds RCMDOM and RCMIMP supply types for self-invoices.
• It is intended for taxpayers with AATO of ₹5 crore and above, subject to notification.
• It is in sandbox only. No production date has been announced.
• The underlying rules already apply: a self-invoice within 30 days, tax paid in cash, and ITC on the self-invoice.
• Use the sandbox window to clean data, fix controls and test ERP integration.