GSTN Advisory: Important New Changes in Invoice Management System

The Goods and Services Tax Network (GSTN) recently released Advisory No. 624 on September 23, 2025, introducing significant updates to the Invoice Management System (IMS). These reforms aim to reduce compliance burdens, improve flexibility, and allow more granular control by taxpayers. Below, we break down the changes, implications, and best practices you should know. 

What’s New Under Advisory 624

The latest advisory brings several important enhancements to the Invoice Management System (IMS), aimed at simplifying compliance and improving transparency:

1. Pending Action for Specified Records
   Taxpayers will now have the option to mark certain documents as pending (rather than outright accept or reject) for a limited period.
   
   
   • For monthly filers: one tax period (i.e. one month)
     
     
   • For quarterly filers: one tax period (i.e. one quarter)
     
     
   • The types of documents eligible to be kept “pending” include:
     • Credit Notes or upward amendments of Credit Notes
     • Downward amendment of Credit Note (when original was rejected)
     • Downward amendment of Invoice / Debit Note (if original invoice already accepted and GSTR-3B filed)
     • Downward amendment of ECO-Document (if original already accepted and GSTR-3B filed)
     
     
2. Declaring the ITC Reduction Amount
   In cases where the recipient either hasn’t availed Input Tax Credit (ITC) or availed only partly, the advisory clarifies that full reversal of ITC may not be required. Taxpayers can now explicitly declare the amount of ITC actually availed, and reverse only that portion if needed.
   
   
   • If the ITC was never availed, no reversal is needed
     
     
   • If partially availed, reversal is limited to that portion
     
     
   • The IMS portal will provide a facility for entering the availed/reversed amount, even for earlier periods
     
     
3. Option to Save Remarks on Actions
   A new (optional) feature will allow taxpayers to record remarks when rejecting or putting documents in pending status. These remarks would appear in GSTR-2B and in the Outward Supplies dashboard for suppliers, aiding transparency and future reconciliation.
   
   
4. Effective Dates & Applicability
   
   • The “pending” credit note / ITC-declaration changes will be activated from the October 2025 tax period onward.
   • The due date to mark a record as pending is based on when the supplier communicated the document.
   • These changes will operate prospectively. Only records filed after the rollout will be eligible.

What This Means for Taxpayers

These changes are designed to provide more flexibility and fairness, but also come with new responsibilities. Below are key takeaways and things to watch out for.

One subtle but important point: this is not a “restart”. The advisory does not allow retrospective advantage on old, already accepted or rejected records. The changes apply only from the date of the rollout onwards.

Practical Tips to Navigate the Transition

1. Update Internal Workflows Immediately
   Ensure your accounting, billing and reconciliation teams are aware of the “pending” option and ITC-declaration ability. Document SOPs to use these features on the IMS portal.
   
   
2. Train Staff & Stakeholders
   Suppliers, purchasers and finance teams should be aligned. For example, the remarks you leave may show up in the supplier’s dashboard, so clarity matters.
   
   
3. Reconcile ITC Usage Carefully
   Now that you’ll be declaring how much ITC you availed, your internal ledger and reports must match your IGST/CGST/SGST utilization. Errors or mismatches may lead to unwanted reversals.
   
   
4. Monitor Portal Updates & Rollout Communications
   The optional remarks feature is expected to be rolled out “shortly” as per the advisory. Keep an eye on GSTN notifications for further instructions or refinements.
   
   
5. Plan for Transition
   Since the changes are prospective, your current accepted/rejected records remain unaffected. But for new invoices, credit/debit notes, maintain rigorous documentation and review timelines.

Conclusion

GSTN Advisory No. 624 introduces practical changes in the Invoice Management System that give taxpayers more flexibility in handling documents, ITC reversals, and reconciliations. Features like marking records as pending, declaring actual ITC reversal amounts, and adding remarks aim to make compliance smoother and more transparent.

As an application service provider (ASP), our role is to keep you updated on such regulatory changes and provide tools that help you manage GST compliance efficiently. Staying informed and adapting your processes in line with these updates will ensure seamless compliance and avoid last-minute challenges.