RCMDOM and RCMIMP: What GSTN's RCM Self-Invoice Sandbox Means

A new IRP option, but not a live reporting requirement

On 16 October 2026, GSTN announced two e-invoice supply types for recipient-generated self-invoices under reverse charge: RCMDOM and RCMIMP. The advisory says the enhancements are available in the sandbox environments of all six authorised Invoice Registration Portals (IRPs). It also says the production rollout date and start of the associated reporting requirements will be communicated later.

That status matters. A GST Council recommendation and a sandbox test option do not, by themselves, make the new reporting step live. As of 19 October 2026, teams should treat RCMDOM and RCMIMP as a system change to prepare for, not as a production filing instruction. Read the GSTN advisory and the recommendations from the 57th GST Council meeting together, and watch for the implementing notifications and technical release note.

What RCMDOM and RCMIMP refer to

The advisory describes two use cases:

RCMDOM is for recipient-generated self-invoices for specified domestic supplies received from unregistered persons, where the registered recipient is liable to pay GST under reverse charge.
RCMIMP is for recipient-generated self-invoices for imports of services from suppliers outside India, where the registered recipient is liable to pay GST under reverse charge.

The GST Council recommended extending e-invoicing to these specified transactions for taxpayers with aggregate annual turnover of ₹5 crore and above. The recommendation describes the intended scope. The final legal applicability, exclusions, and effective date depend on the relevant notifications and provisions, not merely the sandbox codes.

Keep the existing self-invoice question separate

The self-invoice obligation and the new e-invoice reporting route are related, but they are not the same question. Section 31(3)(f) of the CGST Act addresses an invoice issued by a registered recipient liable to pay tax under Section 9(3) or 9(4) for supplies received from a supplier who is unregistered on the date of receipt. The current text of Section 31 is one reference for that existing obligation.

The new announcement concerns reporting specified recipient-generated self-invoices to an IRP and obtaining an IRN through the new supply types after the production rollout and applicable legal changes. It does not mean every purchase attracting RCM needs an e-invoice today. First determine whether RCM applies to the transaction under the current law and whether a self-invoice is required. Then follow the new IRP requirement once its legal scope and effective date are formally set.

What CA and finance teams can prepare now

Use the transition period to make the underlying records easy to review, without treating sandbox behaviour as a final production rule:

Map potential transactions. Separately list domestic supplies from unregistered suppliers and imports of services that may fall under the announced categories.
Confirm the existing RCM treatment. Review the supply category, supplier status, recipient, place of supply, and applicable reverse-charge provision. The fact that a supplier is unregistered does not automatically make every purchase subject to RCM.
Keep self-invoices traceable. Link each self-invoice to its source agreement or transaction record, the RCM assessment, tax payment, and the relevant return working papers.
Ask your ERP or integration provider about readiness. GSTN says all six IRP sandboxes have the enhancements. Detailed specifications, validation codes, and operational instructions are to be issued separately by NIC IRP-1. Confirm those materials before building final mappings.
Separate test from production. If your integration partner is testing in a sandbox, label test records clearly and do not treat a sandbox response as a live IRN or proof of production compliance.
Wait for the operative notification. Recheck the exact covered persons, turnover test, supply scope, exclusions, and start date before changing live invoice or return processes.

Questions teams are likely to ask

Is RCMDOM or RCMIMP mandatory today?

The 16 October advisory says the new functionality is available for sandbox testing and that the production rollout and reporting start date will be communicated later. Do not treat the new reporting step as live based on the advisory alone.

Does the ₹5 crore figure settle which taxpayers must use it?

No. It is the turnover scope stated in the Council’s recommendation. The applicable notification and implementation instructions will establish the final requirement and its effective date.

Should existing RCM self-invoices stop until the IRP rollout?

No. Do not confuse the proposed IRP reporting route with any existing invoice obligations. Apply current law to each transaction and continue the documentation required for it. The new supply types concern a further e-invoice reporting step when brought into production.

Does this cover every RCM transaction?

The announced types are limited to the described recipient-generated self-invoice scenarios: specified domestic supplies from unregistered persons and imports of services. Do not assume the change applies to every reverse-charge supply or to import of goods.

The practical takeaway

For now, the useful action is preparation, not a premature process switch. Keep current RCM decisions and self-invoice records in order, ask system providers about sandbox testing, and wait for the notification and technical release note before treating RCMDOM or RCMIMP as a production requirement.

This article summarizes a GSTN system update and is not an announcement of an Invozen feature. No support for generating or reporting RCMDOM or RCMIMP self-invoices is implied. Confirm the current legal requirements and the official rollout instructions with a qualified GST professional before making changes to live compliance processes.