RCMDOM & RCMIMP: New E-Invoicing Supply Types Under RCM

The two new supply types have been introduced by GSTN on 16 October 2026 for e-invoicing of invoices under reverse charge. This new code allows the registered receiver of the service or goods to self-invoice through the IRP system and obtain their IRN. However, until now, the self-invoice, which has been generated through the reverse charge system, was not a part of e-invoicing at all. This new decision is taken after the recommendation of the 57th GST Council Meeting that took place on 8 October 2026. It addresses the longstanding gap that has been existing since long: millions of RCM purchases (GTA freight, advocate fee, director’s remuneration, imported SaaS and consultancy).

A note of caution though – this is a system enablement notification and not a regulation. The two new supply codes are enabled only at the sandbox level at all six IRPs (NIC IRP-1 and IRP-2, Cygnet, Clear, EY and IRIS) and NIC API developer portal. The actual date of production implementation and other details will be notified in due course of time.

RCMDOM and RCMIMP supply types for e-invoicing under reverse charge

GSTN's advisory defines the two codes as follows:

Supply type	Official definition
RCMDOM	Recipient-generated self-invoices for specified domestic supplies received from unregistered persons, where the registered recipient is liable to pay tax under RCM
RCMIMP	Recipient-generated self-invoices for import of services from suppliers located outside    India, where the registered recipient is liable to pay tax under RCM

 

GSTN states the intended applicability is taxpayers with aggregate annual turnover (AATO) of ₹5 crore and above, the current e-invoicing threshold, expressly "subject to the relevant statutory provisions and notifications". The turnover condition, the "specified domestic supplies" list and the effective date are all proposals until notified.

The law that already applies, regardless of rollout

These obligations are unchanged and predate the announcement:

• The RCM levy. Tax is payable by the recipient on notified goods and services under section 9(3) of the CGST Act (for example GTA services, advocates' services, directors' services, security services by a non-body corporate, sponsorship, insurance and recovery agents, renting of motor vehicles, per Notification 13/2017-CT(R) as amended), and in limited cases under section 9(4), today principally real-estate promoters (Notification 7/2019-CT(R)). Section 9(4) is not a blanket tax on all purchases from unregistered vendors; older descriptions of it are superseded.
• The self-invoice duty. Under section 31(3)(f), a registered person liable under 9(3) or 9(4) must issue an invoice for supplies received from an unregistered supplier.
• The 30-day window. Rule 47A (with effect from 1st November 2024, according to notification No. 20/2024-Central Tax) mandates that the self invoice be issued within 30 days of the receipt of the invoice. For supplies by unregistered suppliers, the time of supply as per section 13(3) would be the earliest between the date of payment (account entry or bank debit) and the date of issuance of the self invoice.
• Payment and ITC. RCM tax must be paid in cash through the electronic cash ledger and reported in GSTR-3B Table 3.1(d). ITC is claimable in the same return, subject to sections 16 and 17.
• Import of services. Where the supplier is outside India, the recipient is in India, and the place of supply is in India (IGST Act section 2(11)), IGST applies under section 5(3) read with Notification 10/2017-IGST(R). The default place of supply is the recipient's location, i.e. its state (section 13(2)). Imports of goods are untouched; IGST on goods is paid through the customs bill of entry, with no self-invoice.

What changes is only the reporting channel for these self-invoices, and even that is sandbox only.

How the technical mechanics differ from normal e-invoicing

Per NIC IRP-1's release notes of 16 October 2026:

• Recipient-only reporting. The recipient, not the supplier, registers the invoice on the IRP.
• IRN hash on the recipient's GSTIN. A standard B2B IRN hash uses supplier GSTIN + financial year + document type + document number. For RCMDOM/RCMIMP, the hash is calculated on the recipient's GSTIN, which determines the authenticating credentials (see system changes below).
• Supplier is always "URP". The seller block carries the unregistered-person code, with no supplier GSTIN. For RCMIMP, a foreign supplier with a foreign address.
• RCMIMP restrictions. Only service transactions are allowed; the origin country code is mandatory and outside India; no e-way bill will be generated for these invoices.
• Reverse-charge flag. The transaction carries the reverse-charge flag ("RC"); the place of supply for RCMIMP is reported as the recipient's state (consistent with secondary analysis; confirm against the NIC documentation).

This also supersedes, prospectively, the legacy GSTN FAQ position (versions 1.3/1.4) that e-invoicing "doesn't arise" for RCM supplies from unregistered persons or import of services; the advisory reverses that position, but only once production goes live.

System changes finance and IT should map now

• ERP transaction header: add the new supply-type values (RCMDOM, RCMIMP) and use separate document-type/numbering series for self-invoices.
• Vendor master: support URP suppliers and foreign-address entries; add an origin-country field for service imports.
• IRP connectivity: the IRN keys on the recipient's GSTIN, so review which credential and GSP mapping performs reporting; a supplier-side integration will not work for these codes.
• E-way bill integration: suppress EWB generation for RCMIMP.
• Schema fields: take the exact JSON element names for the supply-type and origin-country fields from the NIC release note and updated schema documents, not secondary articles.

Accounting and reconciliation

The accounting treatment does not change: the self-invoice remains the documentary basis for the RCM liability, tax is paid in cash, ITC is claimed in the same GSTR-3B period subject to the eligibility conditions. What should change is reconciliation discipline. Self-invoices flowing through the IRP are expected to appear in the recipient's GSTR-2B/IMS pipeline, not only your AP sub-ledger. The 57th Council has also recommended a new rule 86D, an electronic statement of tax paid on reverse charge and ITC claimed, alongside broader return reforms. Plan a three-way match of GSTR-3B Table 3.1(d), 2B/IMS and the RCM statement, plus a duplicate-prevention control of one IRN per self-invoice.

Example decision table: when does a recipient self-invoice plus e-invoice apply?

Scenario	Self-invoice needed?	E-invoice via RCMDOM/RCMIMP?
RCM supply (e.g. GTA) from a registered supplier	No. The supplier issues a tax invoice marked "tax payable on reverse charge basis"	No. The supplier's normal e-invoicing applies if it is notified
RCM supply (e.g. advocate, director, scrap) from an unregistered supplier	Yes. Section 31(3)(f), within 30 days per Rule 47A	Intended: yes, as RCMDOM, subject to notification and turnover threshold
Import of services from a foreign supplier	Yes. The foreign supplier is outside the GST net	Intended: yes, as RCMIMP. Services only, foreign origin country, no e-way bill
Import of goods	No. Customs bill of entry route	No. Not covered by these codes
Taxpayer below ₹5 crore AATO (as proposed)	Self-invoice duty still applies where RCM arises	Not intended to apply. The threshold awaits notification

 

Risks and common errors

• Treating the announcement as mandatory from 16 October 2026. It is sandbox only; no production date exists.
• Assuming RCM applies to all purchases from unregistered vendors. Only notified categories under 9(3) and the limited 9(4) cases attract it.
• Conflating RCMDOM with goods imports, or OIDAR supplies with import of services. OIDAR has its own registration route.
• Trying to report with the supplier's GSTIN. The supplier is always URP and the IRN hash uses the recipient's GSTIN.
• Paying RCM from ITC. The cash ledger is the only route.
• Late self-invoices breaching the 30-day Rule 47A window. Interest and ITC-timing exposure follow.

Migration checklist for finance and IT teams

1. Confirm AATO eligibility against the proposed ₹5 crore threshold.

2. Continue issuing self-invoices under section 31(3)(f)/Rule 47A exactly as today. Nothing is deferred.

3. Enable sandbox testing with your GSP/ERP across both codes, including RCMIMP payloads (foreign currency value, origin country, place of supply).

4. Map all RCM categories in your AP data; identify unregistered and foreign vendors.

5. Update self-invoice templates and numbering series.

6. Review IRP credential and GSP mapping for recipient-side reporting.

7. Suppress e-way bill generation for RCMIMP transactions.

8. Train the AP team on the 30-day self-invoice discipline.

9. Align ITC reconciliation to GSTR-2B/IMS and prepare for the rule 86D RCM statement when implemented.

10. Monitor einvoice.gst.gov.in for the production notification before mandating anything internally.

Conclusion

RCMDOM and RCMIMP close a real gap: RCM self-invoices were the one large invoice class with no IRN. From the 8 October recommendation by the 57th Council to become sandbox-ready was only a week's time. The notification through the law will determine who will have to file, since when, and for what supplies; get the data, vendor master, and integration ready, and stick to the current self-bill practice until then.

For a second pair of eyes on RCM readiness, self-invoice controls or GST compliance more broadly, SKMC Global's