A client asks for a "bill of supply" instead of an invoice, a friend on the composition scheme says tax invoices are not for them, and you are not registered for GST at all and wonder what to send. India's GST rules name several kinds of billing document, and freelancers often use the wrong name for the right document, or add GST lines they have no right to charge.
A GST-registered freelancer on the regular scheme issues a tax invoice. A registered freelancer on the composition scheme, or one supplying exempt services, issues a bill of supply instead, which shows no tax. An unregistered freelancer is outside these rules and sends a plain invoice with no GST. This post explains each document, what a bill of supply must contain, the mixed case, and what changes when you cross the registration threshold.
Registered freelancers on the regular scheme issue a tax invoice
Under Section 31 of the CGST Act, a registered person supplying taxable services issues a tax invoice with the particulars in Rule 46: GSTIN, a serial number of up to 16 characters, the date, the recipient's details, the accounting code of the service, the taxable value, the rate and amount of tax, and the place of supply for an inter-state sale. The guide to GST invoices for freelancers covers the fields, and the guide to SAC codes for freelancers covers the code.
Composition and exempt suppliers issue a bill of supply
Section 31(3)(c) says a registered person who supplies exempted goods or services, or who pays tax under the composition scheme, issues a bill of supply instead of a tax invoice. Rule 49 lists its contents: the supplier's name, address and GSTIN, a serial number of up to 16 characters unique for the financial year, the date, the recipient's details, a description, the value and a signature, which is not needed on an electronic bill. It shows no tax rate or amount. A bill of supply is not needed below ₹200, subject to the prescribed conditions.
Under Rule 5 of the CGST (Composition Levy) Rules, a composition taxpayer must also put the words "composition taxable person, not eligible to collect tax on supplies" at the top of the bill, and "composition taxable person" on every notice or signboard at the place of business. The rate, the turnover limit and the filings are in the guide to the GST composition scheme for freelancers.
Mixed supplies to an unregistered client can share one document
Rule 46A lets a registered person who supplies both taxable and exempt goods or services to an unregistered recipient issue one "invoice-cum-bill of supply" for all of them. It must carry the particulars of Rule 46 and of Rule 49. It matters only if you mix taxable and exempt work for the same unregistered client, and most freelancers never do.
An unregistered freelancer is outside Section 31
Section 31 is written for registered persons, so it does not require an unregistered freelancer to issue a tax invoice or a bill of supply. A plain invoice is still sensible, because your client and your income-tax records need it. Call it an invoice, show your name, address, PAN, the client, the service, the amount and the date, and show no GST. Do not call it a tax invoice or a bill of supply. The guide to invoice numbering covers the serial number, and the free invoice template gives a layout.
Do not add GST to an invoice until you hold a GSTIN. Collecting GST without a GSTIN means you cannot deposit it as tax or pass on credit, as the guide on when a freelancer must register explains.
When you cross the registration threshold, switch from the effective date
Once you register, issue tax invoices from the effective date of registration, not from the day you decide to. A newly registered person can issue revised invoices for the period between the effective date and the registration certificate, within one month of the certificate, as Section 31 provides. The threshold is ₹20 lakh of aggregate turnover for services (₹10 lakh in special-category states), as the guide on when a freelancer must register for GST explains. Keep a record of which invoices fall before and after.
E-invoicing does not apply to most freelancers
E-invoicing is mandatory for businesses with aggregate turnover of ₹5 crore or more, from 1 August 2023 under Notification 10/2023-Central Tax, as the e-invoice portal states. The threshold is ₹5 crore as of October 2026, so it is irrelevant to nearly all freelancers.
Rinto handles GST invoices for registered freelancers
Rinto creates GST-ready invoices with automatic IGST, CGST and SGST calculation for registered freelancers. It does not file GST returns or choose your scheme. If you are unregistered, you do not add GST, and your CA can confirm the right document for your case. This post is general information, not tax advice.
Frequently Asked Questions
What is the difference between a bill of supply and a tax invoice?
A tax invoice is issued by a registered person supplying taxable services and shows GST, the GSTIN and the accounting code. A bill of supply is issued by a registered person who supplies exempt services or pays tax under the composition scheme, and it shows no tax rate or amount. Section 31(3)(c) of the CGST Act sets this out, and Rule 49 lists the bill's contents. A freelancer who is not registered issues neither and sends a plain invoice. A freelancer on the regular scheme who also sells an exempt service would issue both documents.
Does an unregistered freelancer need to issue a bill of supply?
No. Section 31 of the CGST Act is written for registered persons, so it does not require an unregistered freelancer to issue a bill of supply or a tax invoice. A plain invoice is still sensible for your client's records and your own. Call it an invoice, show your name, PAN, the service and the amount, and add no GST. Do not call it a tax invoice, and do not charge GST until you hold a GSTIN. Issuing the wrong document does not change the tax you owe, but it can confuse a client's accounts team.
What must a bill of supply contain?
Under Rule 49, the supplier's name, address and GSTIN, a serial number of up to 16 characters unique for the financial year, the date, the recipient's details, a description of the service, the value and a signature, which an electronic bill does not need. It shows no tax. A composition taxpayer must also show the words "composition taxable person, not eligible to collect tax on supplies" at the top. A bill of supply is not needed below ₹200 subject to conditions.
What is an invoice-cum-bill of supply?
Rule 46A lets a registered person who supplies both taxable and exempt goods or services to an unregistered recipient issue one combined document for all of them. It must carry the particulars required by Rule 46 for a tax invoice and by Rule 49 for a bill of supply. It matters only if you mix taxable and exempt supplies to the same unregistered client, which is rare for a freelancer. Most freelancers issue one document type consistently. The choice of document depends on your own status, not on the client's.
Do freelancers need to issue e-invoices?
Almost never. E-invoicing is mandatory for businesses with aggregate turnover of ₹5 crore or more, from 1 August 2023 under Notification 10/2023-Central Tax, as the e-invoice portal states. Turnover is counted across all GSTINs under one PAN. The threshold is ₹5 crore as of October 2026, so it does not apply to a typical freelancer. Businesses below it can still use the portal's invoice tools voluntarily, but nothing requires an e-invoice from them, and the ordinary invoice rules continue to apply.