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Checklist3 min readPublished

E-invoicing compliance audit: thresholds and common gaps

An audit checklist for e-invoicing compliance under GST, covering applicability thresholds, IRN generation testing, and the common gaps auditors find between invoices raised and invoices actually reported.

An e-invoicing compliance audit tests whether the company's aggregate turnover crosses the applicable threshold and, if so, whether every document required to carry an Invoice Reference Number, including invoices, credit notes and debit notes for business-to-business and export supplies, was actually reported to the Invoice Registration Portal and carries a valid IRN and QR code, by reconciling the sales register against the e-invoice reporting log rather than assuming compliance because the billing software has an e-invoicing module switched on; the exact threshold and document scope should be confirmed against the current GST notification.

Applicability threshold testing

  1. 01Recompute aggregate turnover across the relevant preceding financial yearsAggregate turnover for e-invoicing applicability is computed on a PAN basis across all GST registrations of the entity, not registration by registration; confirm the company's own computation covers every registration under the PAN.
  2. 02Confirm the threshold used reflects the current notified limitThe turnover threshold triggering mandatory e-invoicing has been progressively lowered over successive notifications; confirm applicability against the threshold in force for the period under audit, not a threshold from an earlier year.

Document scope and IRN generation testing

Documents in scope and common gaps
Document typeIn scope?Common gap found
B2B tax invoiceYesInvoices raised from a branch billing system not integrated with the e-invoicing module
Export invoiceYesExport invoices treated as out-of-scope because no GST is charged, when IRN is still required
Credit note / debit note against a B2B invoiceYesCredit notes issued through a manual journal entry, bypassing the e-invoicing flow entirely
B2C invoiceGenerally no, subject to the current notificationConfirm current scope rather than assuming exclusion applies
Delivery challan (no supply)NoSometimes incorrectly pushed through the e-invoicing flow, inflating the reconciliation population
Documents in scope and common gaps

Reconciliation testing

  1. 01Reconcile the sales register against the e-invoice reporting logEvery in-scope invoice on the sales register should have a corresponding IRN; list every invoice without one and investigate whether it was missed entirely or reported with a delay.
  2. 02Check the time lag between invoice date and IRN generation dateA pattern of IRNs generated days after the invoice date suggests invoices are raised outside the integrated billing flow and reported later as a batch correction, which also risks breaching any time limit for IRN generation in force.
  3. 03Reconcile credit and debit notes separately from original invoicesCredit and debit notes are frequently handled through a different process than the original sale, and are the most common document type found missing an IRN in practice.
  4. 04Cross-check e-invoice data against GSTR-1 auto-populationConfirm that e-invoice data flowing into GSTR-1 was not manually overridden in a way that creates a mismatch between the IRN-carrying invoice and what is ultimately filed.

An e-invoice generated but subsequently cancelled on the portal must be cancelled within the permitted window; a cancellation attempted after that window leaves a live IRN against a transaction the company no longer intends to report, which complicates the sales register reconciliation if not tracked separately.

Regulatory requirement

The exact turnover threshold, the scope of documents required to carry an IRN, and the time limits for generation and cancellation are set out in the GST Act, rules and notifications as currently in force. Confirm all of these against current source material before concluding on compliance.

This is practical guidance written for audit teams, not an authoritative statement of any standard or statute. Standards, forms and timelines change. Check the current text issued by the ICAI and the relevant authority before relying on anything here in an audit file.

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