E-Invoicing Reaches RCM Self-Invoices: What RCMDOM and RCMIMP Mean for Your Business
Chandrasekhar Kutty Partner, Sashthi Taxlegal Advisory Services LLP GST Litigation • Advisory • Appellate Representation | Hosur • Bengaluru
Oct 18, 2026
What has been announced
Self-invoices raised under reverse charge are coming into the e-invoicing net. On 16 October 2026, GSTN issued an advisory introducing two new supply types on the Invoice Registration Portals (IRPs): RCMDOM for domestic purchases from unregistered persons, and RCMIMP for import of services.
The change follows the recommendation of the GST Council at its 57th meeting to extend e-invoicing to these transactions for taxpayers with aggregate annual turnover of Rs. 5 crore and above. The functionality is live only in the IRP sandbox for now. The production date, and the notification making it mandatory, are yet to come.
The gap this closes
Until now, e-invoicing has run on the supplier’s side. Under Rule 48(4) of the CGST Rules, the registered supplier generates the IRN, and the recipient sees the document flow into GSTR-2B. That design breaks down when the supplier has no GSTIN.
Where the recipient pays tax under reverse charge on supplies from an unregistered person, or on services imported from abroad, the recipient itself must raise the invoice under Section 31(3)(f) of the CGST Act. Rule 47A now requires this self-invoice within 30 days of receiving the supply. These self-invoices have so far stayed outside the IRP, so the department had no real-time, document-level record of them.
The new supply types bring these self-invoices onto the same e-invoice rails as ordinary B2B invoices, with the recipient as the reporting party.
RCMDOM and RCMIMP at a glance
The recipient selects one of two new supply type codes while reporting the self-invoice through any authorised IRP. On successful validation, the IRP generates an IRN, as it does for a normal e-invoice.
| Supply type | Covers | Supplier | Statutory basis for RCM |
| RCMDOM | Specified domestic supplies received from unregistered persons | Unregistered, in India | Section 9(3) or 9(4) CGST Act, and IGST equivalents |
| RCMIMP | Import of services | Located outside India | Section 5(3) IGST Act |
Where the supplier under RCM is registered, the supplier continues to issue the tax invoice, and this change does not apply. The trigger for RCMDOM is the combination of reverse charge and an unregistered supplier. The precise list of “specified” supplies will depend on the notification yet to be issued.
Who is covered, and from when
The facility is meant for registered persons whose aggregate annual turnover (AATO) is Rs. 5 crore or more, the same threshold that applies to e-invoicing today. Entities already exempt from e-invoicing under the threshold notification (such as SEZ units, insurers, banking companies and GTAs) should await the final notification to see whether the exemption is carried over.
Three points on timing:
- Today: sandbox only, across all six IRPs (NIC IRP-1 and IRP-2, Cygnet, Clear, EY and IRIS). Validations will be uniform and follow the NIC IRP-1 release note.
- Next: NIC will issue a detailed release note with technical specifications and validation codes, and GSTN plans a webinar.
- Mandatory date: to be notified. Until a notification amends the e-invoicing provisions, generating an IRN on a self-invoice is not a legal requirement.
Why this matters beyond compliance
Seen closely, this is a data change as much as a procedural one. RCM on unregistered purchases and imported services has been a steady source of notices, mostly built on mismatches between books, GSTR-3B and the financial statements.
Once self-invoices carry an IRN, the department will hold a dated, invoice-level record of every RCM liability the taxpayer has declared. Expect four consequences:
- Sharper mismatch detection. IRN data can be matched against Table 3.1(d) of GSTR-3B, against ITC claimed in Table 4(A)(2) and 4(A)(3), and against foreign remittance data for imported services.
- Time of supply becomes visible. The IRN date will show whether the self-invoice was raised within the Rule 47A window, and whether tax was paid in the right period. Interest disputes under Section 50 will rest on this date.
- ITC timing is tied to the self-invoice. Since the self-invoice is the document for availing RCM credit, its date also governs the Section 16(4) time limit. A delayed self-invoice can cost the credit.
- Weaker defence by explanation. Today, gaps are often explained through reconciliations at the reply stage. With IRN data on record, the burden will shift to the taxpayer earlier, often at the scrutiny (ASMT-10) or DRC-01A stage.
The practical message is simple. The self-invoice is no longer an internal voucher. It will be a reported document that the department can read.
What taxpayers should do now
The production date is not yet out, but the preparation is mostly internal and can start today.
- ☐ Map RCM transactions. List every recurring purchase from unregistered persons and every imported service (software subscriptions, cloud services, foreign consultants, advertising platforms).
- ☐ Review the self-invoice process. Check who raises the self-invoice, in which system, and whether it is raised within 30 days of receipt as required by Rule 47A.
- ☐ Speak to your ERP or GSP vendor. Ask when RCMDOM and RCMIMP will be supported, and test on the sandbox once the NIC release note is out.
- ☐ Clean up past periods. Reconcile RCM paid in GSTR-3B with books and RCM ITC claimed. Correct gaps before the new data stream makes them visible.
- ☐ Watch for the notification. Track the notification on applicability, exemptions and the effective date before treating IRN generation as mandatory.
Closing note
E-invoicing began as a supplier-side discipline. With RCMDOM and RCMIMP, it now reaches the recipient’s own documents. Businesses that treat the self-invoice as a proper tax document today will find the transition easy, and will be on firmer ground if a notice arrives later.
For help reviewing your RCM processes or responding to notices, contact Sashthi Taxlegal Advisory Services LLP at +91 99521 84110 or contact@sashthitaxlegal.com.
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Source: GSTN advisory dated 16 October 2026 on introduction of e-invoicing facility for recipient generated self-invoices (RCMDOM and RCMIMP). This article is for general information and does not constitute professional advice.