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GSTN AdvisoryHigh impact for ecommerce sellers

Invoice Management System (IMS): accept, reject, pending and deemed acceptance

Reviewed by CA Apurav GargSummary reviewed

Document
GSTN Advisory on Invoice Management System (IMS) and FAQ on IMS changes from October 2025
Issued
15 Oct 2025
Effective
IMS from 1 October 2024; changes from the October 2025 tax period
Issued by
Goods and Services Tax Network (GSTN)
Official PDF(opens in a new tab)

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On this page

What it means for ecommerce sellers

Every invoice, debit note and credit note your suppliers report in GSTR-1, IFF or GSTR-1A appears in your IMS dashboard. You can accept, reject or keep it pending until you file GSTR-3B. Anything you leave untouched is deemed accepted when GSTR-2B is generated. For a brand that buys from many vendors, logistics partners and marketplaces (commission invoices), IMS decides which input tax credit reaches GSTR-2B. Rejecting a supplier's credit note raises that supplier's liability. From the October 2025 tax period, credit notes can also be kept pending for one tax period, and you can declare the amount of ITC to be reduced.

Who it affects

  • Every GST-registered buyer claiming input tax credit
  • Sellers who receive marketplace commission and logistics invoices
  • Suppliers who issue credit notes to registered customers
  • Quarterly (QRMP) taxpayers

Before and after

  • What reaches GSTR-2B

    Before
    Every invoice the supplier filed
    After
    Accepted and deemed-accepted records only; rejected and pending records stay out

  • Record with no action

    Before
    Not applicable
    After
    Deemed accepted when GSTR-2B is generated

  • Credit notes kept pending

    Before
    Not allowed for an original credit note
    After
    Allowed from the October 2025 tax period, for one tax period (month or quarter)

  • ITC to be reduced on a credit note

    Before
    The system reversed the full ITC on acceptance
    After
    From October 2025 the recipient can declare the amount of ITC to be reduced

What to do

  1. Review the IMS dashboard every month before filing GSTR-3B, starting with high-value and unfamiliar suppliers.
  2. Match marketplace commission and logistics invoices against the settlement reports before accepting them.
  3. Recompute GSTR-2B after any action taken after the 14th of the month.
  4. Track pending credit notes, since the pending option ends after one tax period.

Provisions referred to: Section 16(4) CGST Act; Section 34 CGST Act (credit notes); GSTR-2B; GSTR-3B

Related tools and services

Official text

As issued by Goods and Services Tax Network (GSTN). Where the text starts with “Extract”, only the parts that concern ecommerce sellers are reproduced; the official PDF (opens in a new tab) is the authoritative version.

Type a word, number or section to highlight it below.

Extract: GSTN advisory on IMS (complete text of the advisory) followed by questions 1 to 5 of GSTN's FAQ on new changes in IMS from the October 2025 tax period. The complete documents are on tutorial.gst.gov.in. Invoice Management System To enable taxpayers to efficiently address invoice corrections/amendments with their suppliers through the portal, a new communication process is being brought at portal. This will also facilitate taxpayer in matching of their records/invoices vis a vis issued by their suppliers for availing the correct Input Tax Credit (ITC). GSTN is in the process of developing a new functionality called Invoice Management System (IMS) which will allow the recipient taxpayers to either accept or reject an invoice or to keep it pending in the system, which can be availed later. 2. This facility shall be available to the taxpayer from 1st October onwards on the GST portal. The said functionality would be a major enhancement in the ITC ecosystem of GST. Now, only the accepted invoices by the recipients would become part of their GSTR-2B as their eligible ITC. Therefore IMS will provide the taxpayers an opportunity to review the genuineness and authenticity of the received invoices. Once the suppliers save any invoice in GSTR 1 / IFF / 1A /the same invoice would be reflected in the IMS dashboard of the recipient. A sample screenshot of the same is provided below. 3. The invoices reflect in the IMS dashboard as shown in the picture above. The recipient can accept or reject an invoice or can simply keep it pending in the system. These actions can be taken from the time of saving the records in GSTR 1 / IFF / 1A by the supplier taxpayer till the recipient taxpayer files his/her corresponding GSTR-3B. If recipient doesn’t take any action on an invoice in IMS then it will be deemed accepted and will move to GSTR-2B as an accepted invoice. In case, the supplier amends the details of a saved invoices in the GSTR-1 before filling the GSTR-1, in such cases the amended invoice will replace the original invoice in IMS, irrespective of the action taken by the recipient on the original invoice. 4. In case supplier has amended any invoice filed in GSTR-1 through GSTR-1A then same will also flow to IMS, however, ITC corresponding to the same will flow in GSTR-2B of the recipient, generated for the subsequent month only. The invoices which would be kept pending can be availed by taxpayers at any future point of time but not later than the limits prescribed by Section 16(4) of the CGST Act, 2017. All the invoices/ records reported or saved by the supplier taxpayer in their GSTR-1 or IFF or GSTR 1A will be available in the IMS dashboard of the recipient taxpayer for taking the actions. Supplier will also be able to see, what action his recipient has taken on invoices in IMS. 5. Further, at the time of generation of GSTR-2B only the filed invoices/records by the supplier, will be considered for the computation of ITC. Based on the current cut-off dates and action taken by the recipient, a draft GSTR-2B will be made available to recipient on 14th of the subsequent month as currently being generated. However, the recipient will be free to take actions of accept/reject or keep pending even after generation of GSTR-2B till the filing of GSTR-3B. If recipient taxpayers have taken an action on any invoice after 14th of the month, then he would be required to recompute their GSTR-2B. However, they will not be able to take any action after filing of GSTR-3B for the same month. It may be noted that till GSTR-3B is filed by the taxpayer, GSTR-2B for subsequent month will not be generated. 6. On the basis of action taken by the taxpayer, invoices/records can be categorized as mentioned below : i. No action taken: These are the invoices/records where no action has been taken by the recipient these will be treated as deemed accepted at the time of GSTR-2B generation; ii. Accepted: There are the accepted records and will be part of GSTR-2B generation; iii. Rejected: These records will not be considered for GSTR-2B generation; iv. Pending: These records will not be considered for GSTR-2B generation for the month, same will be carried forward in IMS itself for further action in subsequent months. This functionality is a facilitation for the taxpayers and will not add any compliance burden on the taxpayers as No Action records shall be considered as Deemed Accepted and the taxpayer’s intervention will only be required in case a record need to be Rejected or kept Pending. QRMP Taxpayers: The records/invoices saved or filed through IFF by a QRMP taxpayer will flow to IMS for the recipient, and will become part of GSTR-2B, as per action taken by the recipient in IMS on the same. The GSTR- 2B of the recipient will be generated monthly, unless the recipient is a QRMP taxpayer. It may be noted that GSTR-2B will not be generated for Month M-1 and M-2 for QRMP taxpayer. GSTR-2B for a QRMP taxpayer will be generated on Quarterly basis only. Flow of IMS: All the outward supplies reported in the GSTR 1 / IFF / 1A shall populate in the IMS of recipients for taking the actions. 1. Accept –Accepted records will become part of ‘ITC Available’ section of respective GSTR 2B. GST on accepted records will auto-populate in GSTR 3B as eligible ITC. 2. Reject –Rejected records will become part of ‘ITC Rejected’ section of respective GSTR 2B. ITC of rejected records will not auto-populate in GSTR 3B. 3. Pending –Pending records will not become part of GSTR 2B and GSTR 3B. Such records will remain on IMS dashboard till the time same is accepted or rejected. ‘Pending’ action shall not be allowed in following scenarios: a. Original Credit note b. Upward amendment of the credit note irrespective of the action taken by recipient on the original credit note c. Downward amendment of the credit-note if original credit note was rejected by recipient, d. Downward amendment of Invoice/ Debit note where original Invoice/ Debit note was accepted by recipient and respective GSTR 3B has also been filed. Below is a screenshot of IMS dashboard showing summary of all inwards records and action taken thereon: Key points on IMS: 1. Deemed accepted: At the time of GSTR 2B generation, a record will be considered as ‘Deemed Accepted’ if no action is taken on that record in IMS. 2. It is mandatory to recompute GSTR 2B from IMS dashboard in case of any change in action already taken on concerned records or any action is taken after 14th of the month i.e. date of generation of Draft GSTR-2B. 3. Following supplies will not go to IMS and will be directly populated in the GSTR 3B -a. Inward RCM supplies where supplier has reported in the Table 4B of IFF / GSTR 1 or GSTR 1A and b. supplies where ITC is not eligible due to section 16(4) of CGST Act or on account of POS rule. 4. Records will flow to IMS dashboard at the time of saving of record by supplier in respective form and recipient can take action on such record in IMS. However, such records will be populated in the GSTR 2B after filling of return in GSTR-1/IFF/1A by the supplier. 5. All the accepted/ deemed accepted/ rejected records will move out of IMS dashboard after filing of respective GSTR 3B. 6. Pending records will remain on IMS dashboard and these records can be accepted or rejected in future months. 7. It is mandatory to take action on original record and file the respective GSTR 3B before taking action on amended record (amended through GSTR-1A/GSTR-1) when original and amended record belongs to 2 different GSTR 2B return period. If both the records belong to same period’s 2B, only amended record will be considered for ITC calculation of GSTR 2B. 8. Any change made in a record/invoice before filing GSTR-1/1A/IFF by the supplier will reset the record’s status on recipient’s IMS dashboard. 9. GSTR 2B will be sequential now. i.e. system will generate GSTR 2B of a return period only if GSTR 3B of previous return period is filed. 10. The liability of supplier will be increased in GSTR 3B for the subsequent tax period, for the invoices/records which have been rejected by the recipient in the IMS for the following transactions a. Original Credit note rejected by the recipient b. Upward amendment of the credit note rejected by the recipient irrespective of the action taken by recipient on the original credit note c. Downward amendment of the credit note rejected by the recipient if original credit note was rejected by him, d. Downward amendment of Invoice/ Debit note rejected by the recipient where original Invoice/ Debit note was accepted by him and respective GSTR 3B has also been filed. — FAQ on New Changes in Invoice Management System (IMS) from October 2025 Tax Period — 1 For which documents, pending option has been provided now which was not allowed earlier? Pending option has also been provided for the following documents. a. Credit notes, or upward amendment of Credit note, b. Downward amendment of CN where original CN was rejected, c. Downward amendment of Invoice / DN only where original Invoice already accepted and 3B has been filed, d. ECO-Document downward amendment only where original accepted, and 3B has been filed. 2 What are the new changes being introduced in IMS? The following new changes have been introduced in the IMS functionality: - 1. Allowing pending action for the records mentioned above in Question-1 2. Option to declare the ‘Amount of ITC to be reduced’ in IMS by the recipient taxpayers for the records for which the ITC was already reversed or not availed by the taxpayers such as CNs, upward amendment of CN or downward amendment of Invoice/DN. 3. Option to provide a remark by the recipient taxpayers at the time of taking reject or pending action on the records. 3 Are these changes intended to be applied prospectively or retrospectively? The new changes shall be implemented prospectively and the above mentioned options will be available to the taxpayers from October tax period onwards. Please refer to the examples mentioned below for better understanding. Examples: 1. CN dated 15 Sept 2025, reported in GSTR-1 of Sept 2025 filed on 11 Oct 2025 → Appears in IMS but without Pending Option/new facility. 2. CN dated 15 Oct 2025, reported in GSTR-1 of Oct 2025 on 15th Oct 2025 filed on 11 Nov 2025 → Appears in IMS with Pending Option/new facility at the time of record added in the GSTR 1 3. CN dated 15 Mar 2025, reported in GSTR-1 of Oct 2025 filed on 11 Nov 2025 → Appears in IMS with Pending Option/new facility, since GSTR-2B period is Oct 2025. 4. CN dated 20 Sept 2025, reported in GSTR-1A of Sept 2025 filed on 14 Oct 2025 → Appears in IMS with Pending Option/new facility at the time of adding the record, as its GSTR-2B period is Oct 2025. 4 Till what date can Credit Notes and other specified records be kept pending? 1. For monthly taxpayer(recipient) – 1 tax periods (month) 2. For Quarterly taxpayer(recipient) – 1 tax period (One quarter) These records are allowed to keep pending as per formula below - Due date of GSTR-3B filing of [applicable GSTR-2B period (as per date of filing of source return) + Specified period (i.e. 1 tax period)]. Example – If Recipient is Monthly GSTR-1 is filed by supplier on 10 November 2025 in GSTR 1 or IFF. So CNs reported in this GSTR-1 can be kept as pending on IMS dashboard by recipient taxpayer till 1 month as explained below • Applicable GSTR 2B period – October 2025 • Specified period – 1 Tax period i.e. one Month • Next tax period following the GSTR 2B period is October’25 + 1 Months = November’25 • Therefore, last date to keep the record as pending i.e. due date of GSTR 3B for November’25 = 20th December 2025 If Recipient is Quarterly GSTR-1Q for Oct -December Quarter is filed by supplier on 10th January 2026. So CNs reported in this GSTR-1 can be kept as pending on IMS dashboard by recipient taxpayer who is opted for QRMP till 1 tax period as explained below • Applicable GSTR 2B period – Oct-Dec 2025 • Specified period – one Tax period i.e. one Quarter • Next tax period following the GSTR 2B period is Oct-Dec 2025 + 1 Quarter = Jan-March 2026 Therefore, last date to keep the record as pending i.e. due date of GSTR 3B for Jan-March 2026= 22nd /24th April 2026 5 What will happen after the expiry of allowed period for keeping the record as pending Pending action will be disabled after specified period. Hence, recipient has to accept or reject that record after the expiry of specified time period. If no action is taken then system will consider such record as deemed accepted.

Questions sellers ask

What happens if I take no action on an invoice in IMS?

The GSTN advisory says that a record with no action is treated as deemed accepted at the time of GSTR-2B generation, and its ITC flows into GSTR-2B.

Can I keep a credit note pending in IMS?

Before the October 2025 tax period, an original credit note could not be kept pending. GSTN's FAQ on the October 2025 changes allows credit notes to be kept pending for one tax period, after which they must be accepted or rejected, or are deemed accepted.

What happens to the supplier when I reject a credit note?

The advisory states that the supplier's liability is increased in GSTR-3B for the subsequent tax period when the recipient rejects an original credit note or certain amendments of it.

Until when can I act on records in IMS?

From the time the supplier saves the record until you file the GSTR-3B for that period. After filing GSTR-3B, no action can be taken for that month.

Want help working out what this means for your business?

We handle GST and TDS compliance, returns and notice replies for D2C and marketplace sellers, and can walk you through how a change applies to your books.

Contact usWhatsApp us

General information only, not professional advice. The summary is ecomca’s reading of the document; the official PDF is the authoritative version, and later amendments may change it. Check the official source before you act.