E-invoicing (IRN) for outdoor media companies in India

This guide describes the rules as we understand them in October 2026. GST notifications and portal validations change, sometimes at short notice — confirm thresholds and dates with your chartered accountant and the e-invoice portal before you rely on them.

Do you have to e-invoice?

E-invoicing is not a separate kind of invoice. You still issue your own tax invoice; you also report it to an Invoice Registration Portal (IRP), which validates it and returns an IRN (Invoice Reference Number) and a digitally signed QR code.

You must do this if your aggregate turnover crossed ₹5 crore in any financial year from 2017-18 onwards. The ₹5 crore threshold has applied since 1 August 2023, under Notification 10/2023-Central Tax, which amended the original Notification 13/2020-Central Tax (TaxGuru, October 2026).

Three points people miss:

• Aggregate turnover is PAN-wide. All your GSTINs across states count together.
• Once in, you stay in. Crossing ₹5 crore in any year since 2017-18 brings you in, even if turnover drops later.
• The invoice is not valid without an IRN. If you are required to e-invoice and you do not, the client may not get input tax credit on that invoice — which is the fastest way to lose an agency client.

A few categories are exempt (banks and NBFCs, insurers, goods transport agencies, passenger transport, specified cinema admissions, SEZ units). An outdoor media company is normally not in any of them.

What gets an IRN

Document	IRN needed?
Tax invoice to a GST-registered client or agency (B2B)	Yes
Credit note or debit note to a registered client	Yes
Export invoice, supply to an SEZ	Yes
Invoice to an unregistered client or consumer (B2C)	No
Proforma invoice or quotation	No — it is not a tax invoice
Receipt voucher for an advance	No

Most outdoor media billing is B2B: brands, agencies and other media owners with a GSTIN. If the client gives you a GSTIN, assume the invoice needs an IRN.

The 30-day limit

A GSTN advisory dated 5 November 2024 says that from 1 April 2025, taxpayers with an annual aggregate turnover (AATO) of ₹10 crore or more cannot report an e-invoice more than 30 days after the document date. The IRP simply rejects it.

• It applies to invoices, credit notes and debit notes.
• The advisory’s example: an invoice dated 1 April 2025 cannot be reported after 30 April 2025.
• It was ₹100 crore and above before; the advisory lowered it to ₹10 crore.
• Below ₹10 crore AATO there is no such restriction “as of now”, in the advisory’s words. You still need the IRN if you are above ₹5 crore — you just are not blocked by the 30-day check.

We found no later advisory changing this as of October 2026, but GSTN has lowered the threshold twice. Check the e-invoice portal news section.

In practice the risk for an outdoor media company is the gap between billing in OMMS or your accounts package and registering on the IRP. If invoices are raised on the last day of the month and someone uploads them in a batch weeks later, the oldest ones fail.

What the IRP needs

The IRP validates your invoice in the standard e-invoice schema. For a typical outdoor media invoice that means:

• Supplier: GSTIN, legal name, address, state.
• Recipient: GSTIN, legal name, address, and the place of supply.
• Document: type (invoice, credit note or debit note), number and date. Invoice numbers are limited to 16 characters and must be unique for the financial year.
• Each line: description, SAC (with “is service” marked), taxable value, GST rate and tax amount. Six-digit SAC is generally required above ₹5 crore turnover — see SAC code for outdoor advertising.
• Totals: taxable value, IGST or CGST and SGST, and invoice value.

The IRP returns the IRN, an acknowledgement number and date, and a signed QR code. The QR code must appear on the invoice you give the client. The invoice details then flow into your GSTR-1 automatically.

IRP, GSP and how you upload

You can report invoices in several ways:

• The government IRP — enter invoices on the portal or use its bulk upload tool. Fine for a few dozen invoices a month.
• A private IRP — several are notified; they offer the same function, often with better bulk tools.
• A GSP or ERP integration — your accounting or billing software calls the IRP through an API and gets the IRN back automatically.

Whichever you use, someone must own the step and do it the day the invoice is raised.

Cancelling and correcting

• Within 24 hours, an IRN can be cancelled on the IRP. The whole invoice is cancelled — there is no partial cancellation — and the same invoice number cannot be reused.
• After 24 hours, you cannot cancel or edit the IRN. Correct it with a credit note (or a debit note if the value went up), which itself needs an IRN and, above ₹10 crore AATO, must be reported within 30 days of its own date.
• A GST credit note for a financial year must generally be issued by 30 November following that year.

Outdoor media cases

FOC sites

Many deals include free-of-cost (FOC) or bonus sites. If the FOC site is part of a paid deal, there is no separate supply to invoice — the consideration for the paid sites covers it. List FOC sites in the site annexure or campaign schedule rather than as invoice lines.

If you want them on the invoice, check with your GSP or IRP whether zero-value service lines are accepted. Ask your accountant before treating a stand-alone free site, with no paid deal around it, as anything other than taxable.

Cancelled bookings

If a client cancels before the campaign starts and no invoice was raised, nothing goes to the IRP.

If you invoiced in advance, cancel the IRN within 24 hours if you can. Otherwise issue a credit note for the cancelled value and report it within the time limit.

If you keep a cancellation charge, that is usually billed as its own taxable supply with its own invoice and IRN. Treatment of forfeitures and penalties depends on the contract — confirm it with your accountant.

Campaign extensions

An extension is new display time. Bill it on a new invoice with a new IRN — do not reopen or edit the original. Date the invoice when the extension is billed, and report it within 30 days of that date.

If a client asks to change sites mid-campaign, issue a credit note for the sites dropped and an invoice for the sites added, rather than trying to amend the registered invoice.

Split and agency billing

Agencies often want one campaign split into several invoices — by brand, by PO, or display separately from production. Each invoice is a separate document with its own IRN. Make sure every split is reported, not just the first one.

A routine that works

1. Raise the tax invoice from the campaign the day the PO is in.
2. Register it on the IRP the same day; keep the IRN and acknowledgement number with your invoice records.
3. Send the client the copy with the QR code.
4. Each week, compare invoices raised with IRNs generated. Anything without an IRN is a problem within days, not a month.
5. Before filing, reconcile your GSTR-1 report with what the IRP auto-filled.