Categories: GST E-Invoice

Introduced for Unregistered Dealers on E-Way Bill Portal

Form ENR-03: Introduced for Unregistered Dealers on E-Way Bill Portal

The E-Way Bill (EWB) system now allows unregistered dealers to generate e-Way Bills using Form ENR-03, eliminating the requirement for a GSTIN. This simplifies goods transportation compliance and enhances logistics efficiency. GSTN Issue Notification issued on ENR-03 filing process for Unregistered Persons (URPs) to generate e-Way Bills under the GST system, based on the latest GSTN advisory

  • Unregistered Persons (URPs) can now generate e-Way Bills without registering for GST. They must enroll on the E-Way Bill (EWB) portal by filing Form ENR-03.
  • The Enrolment ID generated will act as a substitute for Supplier GSTIN/Recipient GSTIN.
  • Previously, if neither buyer nor seller was registered, the transporter had to generate the e-Way Bill. Now, any one party (buyer/seller) can enroll using ENR-03 and generate an e-waybill. Helps small businesses below the GST threshold to comply with GST rules without registering.

Key Highlights on Form ENR-03 Introduced for Unregistered Dealers on E-Way Bill Portal

  • Unregistered dealers can now generate e-Way Bills without GST registration.
  • Enrolment ID (15 characters) will serve as an alternative to GSTIN.
  • PAN & mobile number verification (via OTP) required.
  • Username & password setup needed for login.
  • Easy e-Way Bill Generation – Use the “Generate New” option after login.
  • Effective Date: February 11, 2025, which is Issued By: GST Network (GSTN)

Key Advantages of ENR-03 Enrolment

  • No GST registration needed for e-Way Bills.
  • No third-party dependency (generate bills independently).
  • Speeds up logistics & compliance processes.
  • Better tracking & regulation of transported goods.

Step-by-Step Guide to Filing ENR-03 on the E-Way Bill Portal

Step 1: Access the E-Way Bill Portal

  • Go to the GST E-Way Bill portal.
  • Click on ‘Registration’ in the main menu.
  • Select the ‘ENR-03 Enrollment’ option.
  • Enter State, PAN, Mobile Number, and Address Details → Verify via OTP

Step 2: Enter Business Details

  • Select State and enter your PAN details (for verification).
  • Choose the type of enrollment (individual, business, etc.).
  • Provide address details and mobile number (OTP verification required).
  • Set up login credentials → Submit & receive enrolment ID.

Step 3: Create Login Credentials

  • Choose a username & password and check availability.
  • Submit the details.
  • A 15-character enrollment ID will be generated and displayed.
  • Log in → Use enrolment ID as supplier/recipient → Generate e-Way Bill.

Step 4: Generate an e-Way Bill

  • Log in to the E-Way Bill Portal using your credentials.
  • Click on ‘Generate New.’
  • Your enrollment ID will auto-fill as the supplier/recipient GSTIN.

Enter the transport details and generate the e-Way Bill. For the official user manual & guide: GST Portal

Impact of This Change For Unregistered Businesses:

  • No need for GST registration just to generate an e-Way Bill. Easier movement of goods while staying GST-compliant. Reduces dependency on transporters for e-Way Bill generation.
  • Help small traders, job workers, and transporters comply with GST without full registration.
  • Removes dependency on registered buyers/sellers or transporters for e-Way Bills.
  • Strengthens tracking of goods movement and reduces tax evasion.

The ENR-03 feature is a major relief for small businesses, traders, job workers, and transporters who don’t meet the GST registration threshold but still need to move goods. This update ensures better compliance, efficiency, and formalization of the economy.

GST E-Way Bill System Gets Stricter After CAG Points Out Gaps

E-way bill system under the Goods and Services Tax mechanism.

Generation of Multiple E-Way Bills for the Same Invoice is a Systemic Deficiency Noted: E-Way Bills by Non-Filers. E-Way Bill Generation by Cancelled GSTINs. India’s GST E-Way Bill system has been tightened following a Comptroller and Auditor General audit that exposed key vulnerabilities. The Comptroller and Auditor General Report, tabled in Parliament on December 9, 2025, highlighted issues like multiple bills per invoice, non-filers generating bills, and the use of cancelled Goods and Services Tax Identification Numbers.​

The Comptroller and Auditor General – Identified Gaps: The audit revealed manipulation via case variations in invoice details, allowing duplicates, alongside failures in blocking bills for non-compliant taxpayers. Weak integration between portals also enabled invalid Goods and Services Tax identification numbers, incorrect HSN codes, and illogical routes.​

Measures Taken by Government to Rectify These Deficiencies:

  • Multiple E-Way Bills for Same Invoice: The issue occurred due to variations in upper-case and lower-case entries. Validation has been developed. The system does not permit the same document number on the same date for more than one E-Way Bill. Bills older than 180 days are not allowed for generation.
  • E-Way Bills by Non-Filers: Generation remains blocked for taxpayers who have not filed the previous three returns. Filing status is checked before permitting E-Way Bill generation.
  • E-Way Bill Generation by Cancelled GSTINs: Validations verify whether the Goods and Services Tax Identification Number is cancelled. If cancelled, the system does not allow any E-Way Bill generation against such a Goods and Services Tax Identification Number.
  • Government Fixes: Strict document-number validation now prevents duplicates and limits bills to invoices under 180 days old. Generation is auto-blocked for those missing the last three returns, and real-time Goods and Services Tax Identification Number checks bar cancelled registrations.​
  • Additional rules include phased invoice registration requirements and a 180-day invoice limit for bill creation, enhancing overall compliance. These changes aim to curb evasion and streamline logistics

GST Update: Mandatory Capture of “Ship-to” Field & Voluntary Closure of E-Way Bill from 1 August 2026

As per the GSTN update dated 2 July 2026, GSTN has released FAQs clarifying the implementation of mandatory capture of the “Ship-to” field in E-Way Bills and voluntary closure of E-Way Bills. These changes are scheduled to be implemented on the E-Way Bill portal from 1 August 2026.

Key Highlights on Mandatory Capture of “Ship-to” Field & Voluntary Closure of E-Way Bill

1. Mandatory Capture of Ship-to Details

  • Taxpayers generating E-Way Bills will be required to furnish the actual Ship-to address/details wherever applicable.
  • The objective is to improve the accuracy of movement tracking and ensure consistency between invoices and E-Way Bills.
  • System validations may be introduced to ensure correct reporting of delivery locations.

2. Voluntary Closure of E-Way Bills

  • A new facility will allow stakeholders to voluntarily close an E-Way Bill when the intended movement of goods does not take place or is cancelled.
  • This aims to maintain the integrity of E-Way Bill data and reduce compliance issues arising from unused E-Way Bills.

Compliance Action for Taxpayers

  • Taxpayers must review ERP/E-Way Bill generation systems for capturing accurate Ship-to information.
  • Train logistics and dispatch teams regarding the new mandatory fields.
  • Taxpayers have to establish internal controls for timely voluntary closure of E-Way Bills where movement is cancelled.
  • Taxpayers have to monitor GSTN notifications and FAQs for detailed procedural requirements.

Significance for Businesses

  • These changes will enhance traceability of goods movement and reduce mismatches between invoices and E-Way Bills. Improve GST compliance and data quality. Help taxpayers manage cancelled consignments through proper closure mechanisms.
  • Businesses having bill-to/ship-to transactions, third-party logistics arrangements, branch transfers, or direct delivery to customer locations should carefully review their E-Way Bill processes before 1 August 2026 to avoid validation errors during EWB generation.
  • The GSTN FAQs referenced in the advisory provide detailed clarifications on the applicable validations, procedures, and compliance requirements for both functionalities.
Rajput Jain & Associates

Rajput Jain & Associates is a Chartered Accountants firm, with it's headquarter situated at New Delhi (the capital of India). The firm has been set up by a group of young, enthusiastic, highly skilled and motivated professionals who have taken experience from top consulting firms and are extensively experienced in their chosen fields has providing a wide array of Accounting, Auditing, Taxation, Assurance and Business advisory services to various clients and their stakeholders. Rajput jain & Associates, a professional firm, offers its clients a full range of services, To serve better and to bring bucket of services under one roof, the firm has merged with it various Chartered Accountancy firms pioneer in diversified fields. We have associates all over India in big cities. All our offices are well equipped with latest technological support with updated reference materials. We have a large team of professionals other than our Core Team members to meet the requirements of our prospective clients including the existing ones. However, considering our commitment towards high quality services to our clients, our team keeps on growing with more and more associates having strong professional background with good exposure in the related areas of responsibility.

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