The GST Council's May 2026 clarification has tightened e-invoicing requirements for large-value infrastructure contracts (value >₹50 lakh per invoice). From 1 June 2026, NHAI, port authorities, power distribution companies and real-estate SPVs must file real-time e-invoices via IRP and cannot rely on batch uploads or manual GST portal entry.
Non-compliance risks demand notices and 5% ITC denial on future claims.
Market signals
From June 2026, businesses supplying infrastructure services (civil works, engineering procurement, power transmission) must integrate accounting software directly with the IRP's API. Manual e-invoice generation is no longer acceptable for invoices above ₹50 lakh.
GST Department circulars (May 2026) warn that invoices filed outside real-time API channels will trigger automatic ITC denial and demand notices. Retroactive compliance carries penalties even if payment was made on time.
Project SPVs (especially in roads, power and ports) now face higher audit frequency. GST authorities are cross-checking e-invoice timestamps against project milestones and bank payment records to detect fake invoicing.
Infrastructure firms must ensure their accounting systems (Tally, SAP, or cloud ERP) are certified e-invoice API-ready by end of June 2026. Non-compliance will result in ITC reversal notices under Rule 36(4) and potential penalties under Section 122. Vinayakam Consultants helps map your current GST and e-invoice processes, certify API integration readiness, and guide SPVs and consortia on compliant invoice structuring to protect ITC eligibility and avoid demand notices.
Your action checklist
- Audit your ERP/accounting software: confirm it is IRP API-certified and tested with at least one live e-invoice transaction by 15 June 2026.
- Review all outstanding invoices >₹50 lakh issued since May 2026: verify they were generated via API and filed in real-time; re-file any batch uploads immediately.
- Train GST compliance staff on the new e-invoice timestamp, project-code, and milestone-matching requirements; document API failure logs to counter demand notices.
- For SPVs and consortia: prepare consolidated ITC reconciliation statement showing API-filed invoices, project milestones, and payment timelines; engage a GST audit specialist before 30 June 2026.
Frequently asked questions
From June 1, 2026, NHAI, ports, power companies and real-estate SPVs must file real-time e-invoices via IRP API for contracts over ₹50 lakh. Manual uploads and portal entry are no longer permitted.
Non-compliance triggers automatic ITC denial, demand notices, 5% ITC reversal on future claims, and penalties under GST Section 122 and Rule 36(4).
Your ERP or accounting system (Tally, SAP, cloud ERP) must be IRP API-certified and tested by end of June 2026 to remain compliant.