GST guide

Billing without a GSTIN

Plenty of small businesses invoice customers without being registered, and that is perfectly legal. The trap is a narrow one, and it costs more than a missing field.

By Mohit Sehgal, founder of BahiSathi · Updated 15 Aug 2026

Two questions get run together here and they have different answers. "Can I send an invoice without a GSTIN?" — yes. "Can I charge GST on it?" — no, and doing so anyway is the one mistake on this page worth being careful about.

The rule, in one line

If you are not registered, you may bill freely — but you must not collect tax and must not show any tax amount on the document. No GSTIN, no GST.

What you issue instead

A plain commercial invoice. Your name and address, the customer, the lines, quantities, rates and a total. No CGST, SGST or IGST column, no tax rate, no tax amount, and no GSTIN — because you do not have one.

The total is simply the price. That is not a lesser document: it is a perfectly valid bill your customer can pay and book as an expense. What it is not is a tax invoice, which is a specific thing with its own required fields that only a registered person can issue.

The thing not to do

Do not add "GST 18%" to an invoice while unregistered, and do not put someone else's GSTIN on your document. An unregistered person is not permitted to collect tax, and the money collected has to be paid over regardless, typically with penalty and interest on top. Your customer also cannot claim the credit, so they have paid 18% more for nothing and will eventually notice.

When registration stops being optional

Registration is compulsory once your aggregate turnover crosses the threshold for your state and what you supply. Broadly:

What you supplyMost statesSpecial category states
Goods₹40 lakh₹20 lakh
Services₹20 lakh₹10 lakh

Turnover here means aggregate turnover across everything you supply on the same PAN, all India, including exempt supplies — not the turnover of one shop or one line of business. These figures have moved before and a few states have opted differently, so confirm your own position rather than reading the table as settled.

Cases where the threshold does not save you

Some supplies require registration from the first rupee, whatever your turnover:

  • Inter-state supply of goods — selling across a state border.
  • Selling through an e-commerce operator that is required to collect tax at source.
  • Liability under reverse charge, where you are the one who has to pay the tax on a supply received.
  • Casual or non-resident taxable persons — occasional supply in a state where you have no fixed place of business.

Inter-state services are treated differently from goods here, and the e-commerce position has changed more than once. If either applies to you, check it properly rather than assuming the threshold covers you.

What your customer loses

A registered business buying from you cannot claim input tax credit, because there is no tax on the document to claim. In practice that makes you roughly 18% more expensive than a registered competitor quoting the same headline price, which is the real reason many small suppliers register voluntarily well before they have to.

Selling to consumers, it makes no difference at all — they were never claiming credit. Whether registration is worth it therefore depends almost entirely on who your customers are, not on your turnover.

Registering voluntarily

You can register before crossing any threshold. It makes you attractive to business customers and lets you claim credit on your own purchases. It also commits you to filing returns on time whether or not you sold anything that period, and late filing carries a fee per return. It is a real obligation, not a badge — worth taking on deliberately.

How BahiSathi handles it

Leave the GSTIN blank when you set up your business and the tax columns disappear from the editor and from the PDF. You get a clean invoice with lines, quantities, rates and a total, and no tax anywhere on it. Nothing has to be switched off and there is no way to accidentally show a tax amount you are not entitled to charge.

When you do register, add the GSTIN in Settings. The tax columns appear from that point on, and documents you already issued are untouched — they were correct when you sent them and they stay exactly as your customer received them.

Thresholds, state-level variations and the e-commerce rules all change. This is a plain-language summary, not advice on your own registration position — check that with your accountant.

Registered or not, send a proper bill.

Leave the GSTIN blank and BahiSathi gives you a clean invoice with no tax on it.