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E-invoicing · 5 crore rule

E-invoice and the 5 crore rule for mutual fund distributors

Some MFDs must report every AMC invoice to the government portal and print an IRN and QR code on it. Here is who the rule covers, since when, and what to do about it.

E-invoicing sits on top of your normal invoice. For the base layer, see the invoice format and SAC code guide.

The rule in one line

If your aggregate turnover crossed 5 crore rupees in any financial year since 2017-18, then from 1 August 2023 e-invoicing is mandatory on your B2B invoices. Your invoices to fund houses (AMCs) are B2B, so they are covered.

Two words in that rule deserve a second look:

What e-invoicing actually means

E-invoicing does not mean a PDF sent by email. It means each B2B invoice is reported to the government e-invoice portal, which returns two things that must appear on the invoice:

ItemWhat it is
IRNThe Invoice Reference Number, a unique code the portal assigns to that invoice.
QR codeA machine-readable code carrying the invoice's key details, printed on the invoice.

The rest of the invoice stays the same: your details and the AMC's, the 18% GST split as CGST plus SGST or IGST, the SAC code 997152, and your signature. The registrar side does not change either; you still upload signed invoices to KFIN and CAMS in the usual 7th to 15th window, as covered in the KFIN guide and the CAMS guide.

Does this cover you?

Most individual MFDs earn well under 5 crore a year and are outside the rule. But do not assume:

If you are near the line, check your turnover for every year since 2017-18 with your accountant before deciding you are exempt.

Why skipping the IRN is serious

If the rule covers you and an invoice goes out without an IRN, that invoice is not a valid invoice. The AMC's claim to credit for the GST it paid you rests on a valid invoice, so an invalid one puts that GST at risk, in the same way a missing entry in the AMC's GSTR-2B does. That reconciliation story is explained in the GSTR-2B and clawback guide.

So if e-invoicing applies to you, the order each month is: prepare the invoice, get the IRN and QR code from the government portal, then upload the signed invoice to the registrar.

Where MFD Office fits in, honestly. MFD Office handles the registrar invoice step: upload your KFIN or CAMS file and it makes a signed GST invoice for every fund house, keeps every amount and GST figure exactly as the registrar computed it, never retyped, and fills the registrar's Excel sheet to match. It does not generate IRNs; if the 5 crore rule covers you, that step happens on the government portal and stays with you and your accountant. See one of your own invoices free, no signup.

Get the registrar invoices done in minutes

Upload your KFIN or CAMS file and see a real, signed invoice made from your own figures. No signup, no card.

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Common questions

Does e-invoicing apply to mutual fund distributors?

Yes, if aggregate turnover crossed 5 crore in any financial year since 2017-18. From 1 August 2023 it is mandatory on B2B invoices, and invoices to AMCs are B2B. Most individual MFDs are below the limit; larger firms and corporate ARNs may not be.

What is an IRN and QR code?

The government e-invoice portal assigns each reported invoice an Invoice Reference Number and a QR code, and both must appear on the invoice. Without them, when required, the invoice is not valid.

Does the 5 crore limit reset every year?

No. Crossing it once, in any financial year from 2017-18 onwards, is enough to bring you under the rule permanently.

What if I skip the IRN when it is required?

The invoice is invalid, which puts the GST the AMC paid you at risk. Generate the IRN first, then upload the signed invoice to the registrar as usual.

Does MFD Office generate e-invoices?

No. It prepares your signed registrar invoices with the registrar's exact figures and fills the Excel sheet to match. The IRN, where required, comes from the government portal.

Please note: this page is general information, not tax advice. Whether e-invoicing applies to you depends on your exact turnover history, so confirm with your tax advisor before acting on it.