New GST e-Invoicing Supply Types for Reverse Charge: What RCMDOM and RCMIMP Mean for You
On October 16, 2026, GSTN quietly released an advisory that changes how reverse charge transactions will eventually be reported on the e-invoice system. Advisory No. 678 introduces two new supply type codes — RCMDOM and RCMIMP — built specifically for self-invoices that a buyer generates when they, not the seller, are liable to pay GST.
If you handle GST compliance for a business with turnover above ₹5 crore, this is worth understanding now, even though nothing changes in your day-to-day filing just yet.
Background: Where This Change Comes From
This isn't a standalone announcement. It traces back to the 57th GST Council meeting, held on October 8, 2026, in New Delhi under Finance Minister Nirmala Sitharaman. The Council recommended extending e-invoicing coverage to two specific reverse charge situations: domestic purchases from unregistered suppliers, and import of services. GSTN's Advisory 678 is the technical follow-through on that recommendation — it adds the system capability, though the legal mandate requiring its use is still pending a formal notification.
What Is RCM Self-Invoicing, and Why Does It Need Its Own Supply Type?
Under the Reverse Charge Mechanism, it's the buyer — not the seller — who pays GST directly to the government. Because there's no registered supplier issuing a tax invoice in these cases, the law requires the recipient to raise a self-invoice to record the transaction and support their input tax credit claim under Rule 36(1)(b).
Until now, these self-invoices existed entirely outside the e-invoicing system; they were never assigned an Invoice Reference Number (IRN). Advisory 678 changes that by giving recipients a way to report self-invoices through an authorised Invoice Registration Portal (IRP) and receive an IRN for them, just like a regular e-invoice.
RCMDOM: Reverse Charge on Domestic Purchases
RCMDOM applies when a registered business receives specified goods or services from an unregistered domestic supplier, and GST on that transaction is payable by the recipient under reverse charge.
Typical situations where RCMDOM would apply:
• Freight paid to an unregistered Goods Transport Agency (GTA)
• Legal fees paid to an unregistered advocate or firm of advocates
• Rent paid to an unregistered individual for commercial property
• Other notified categories of supply from unregistered persons under RCM
When reporting such a transaction (once the facility is mandated), the recipient creates the self-invoice and tags it with the RCMDOM supply type code on the IRP before submission.
RCMIMP: Reverse Charge on Import of Services
RCMIMP covers self-invoices for services imported from a supplier located outside India, where the Indian recipient is liable to pay GST under reverse charge — since a foreign supplier isn't registered under Indian GST and can't issue a compliant tax invoice.
Common examples include:
• Cloud infrastructure or hosting services billed by an overseas provider (AWS, Google Cloud, etc.)
• Subscriptions to foreign-hosted SaaS or software platforms
• Consultancy or marketing services procured from an overseas agency
Here too, the recipient raises the self-invoice and reports it under the RCMIMP code once this becomes a live requirement.
Who Does This Apply To?
According to the advisory, this facility is intended for taxpayers with Aggregate Annual Turnover (AATO) of ₹5 crore or more — the same threshold that currently governs e-invoicing eligibility. Businesses below this threshold are not in scope.
Importantly, the advisory is explicit that applicability remains "subject to the relevant statutory provisions and government notifications" — meaning the ₹5 crore figure and the overall scope could still be fine-tuned or formally notified separately before go-live.
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Aspect
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Detail
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Turnover threshold
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AATO of ₹5 crore or above
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Covered transactions
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Domestic RCM purchases from unregistered persons; import of services
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Not covered
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Import of physical goods (already tracked via Bill of Entry at Customs)
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Current status
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Live in sandbox/testing environment only, since October 16, 2026
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Mandatory go-live
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Not yet notified
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Is This Mandatory From October 16, 2026?
No — and this is the detail that seems to cause the most confusion. Advisory 678 switches on the RCMDOM and RCMIMP supply types in the sandbox (testing) environments of all six authorised IRPs: NIC-IRP1, NIC-IRP2, Cygnet, Clear, EY, and IRIS. It is a technical enablement for businesses and software vendors to test against, not a live compliance requirement.
The actual legal obligation to route RCM self-invoices through the e-invoice system will only kick in once GSTN issues a separate notification confirming the production go-live date. Until then, your existing self-invoicing and payment voucher process under RCM continues exactly as before.
What Should Businesses Do Right Now?
Since there's no live deadline yet, this is a preparation window rather than a compliance deadline. A few practical steps worth taking:
1. Flag it with your ERP or accounting software vendor — Tally, SAP, Zoho, and similar platforms will need to support RCMDOM and RCMIMP as selectable supply types before go-live.
2. Identify your RCM transaction volume — review how many unregistered-supplier purchases and imported services your business currently handles under reverse charge, since these will eventually need IRN generation.
3. Watch for the NIC release note — NIC IRP-1 is expected to publish detailed technical specifications, validation rules, and error codes for RCMDOM and RCMIMP, which your tech team will need for integration testing.
4. Don't change your live filing process yet — production systems are unaffected; only the sandbox environment has these new codes active.
RCMDOM and RCMIMP vs the Existing RCM Process
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Particular
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Current Process
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Under RCMDOM/RCMIMP (once mandatory)
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Self-invoice format
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Internal document, no IRN
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Reported to IRP, IRN generated
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ITC support document
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Self-invoice/payment voucher under Rule 36(1)(b)
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Same, but now backed by an IRN
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Reporting timeline
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Within 30 days of receiving supply
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Unchanged
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System visibility
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Not visible to GSTN at invoice level
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Captured within the e-invoice ecosystem
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Frequently Asked Questions
Q1. Does RCMDOM or RCMIMP apply to importing physical goods?
No. Import of goods is already tracked through the Bill of Entry at Customs and falls outside the scope of this advisory, which deals only with services and specified domestic RCM supplies from unregistered persons.
Q2. Has the 30-day self-invoicing timeline changed?
No. The statutory requirement to raise a self-invoice within 30 days of receiving the supply remains exactly as it was. What's changing is the reporting channel — eventually through an IRP, for an IRN.
Q3. Is this live for production filing from October 16, 2026?
No. As of the advisory date, RCMDOM and RCMIMP are available only in the sandbox/testing environments of the six authorised IRPs. There is no mandatory production requirement yet.
Q4. Does this apply to businesses under ₹5 crore turnover?
No. The facility is intended for taxpayers at or above the existing e-invoicing turnover threshold of ₹5 crore, consistent with current e-invoicing applicability.
Q5. Where can I read the original advisory?
Advisory No. 678, dated October 16, 2026, is available on the official GST portal at gst.gov.in under News and Updates.
Conclusion
Advisory 678 doesn't change anything in your live GST filings today — but it's a clear signal of where reverse charge compliance is headed. By bringing RCM self-invoices into the e-invoice/IRN framework, GSTN is closing one of the few remaining gaps in invoice-level visibility. Businesses crossing the ₹5 crore threshold and dealing regularly with unregistered domestic suppliers or imported services would do well to start the ERP conversation now, well before a mandatory go-live date is notified.