IS IMS Mandatory from 1st October

[Abhijeet Mane]

Hi All,

Pursuant to Sections 127 and 128 of the Finance Act, 2025, has IMS become mandatory from 1st October 2025? If yes, for which months return should it be followed?

The base for this doubt is Since Rule 60 is not amended yet 

[Sadanand Bulbule]

Your observation is perfectly right.

However the authorities may argue that Finance Act, 2025 + notifications+ portal readyness is sufficient to place IMS mandatory from 01/10/2025.

An element of risk is involved, if it is not followed, despite Rule 60 is yet to be amended.

[KASTURI SETHI]

Treat it as mandatory w.e.f. 1.10.2025. No dispute or doubt. Still if you have any doubt, read the legal meaning of the word, "Notification".  Things will be as clear as sunshine. 

[Shilpi Jain]

As on date the portal is not ready. For GSTNs with more than 500 entries it is not possible to comply with IMS.

Additionally rules are yet to be amended.

The Act is ready with the amendment in section 38. 

Once portal is ready along with amendment in rule 60, you can consider it mandatory.

[Rajan Kumar and associates]

My View: 

IMS is not mandatory w.e.f. 01-10-2025, as Rule 60 has not been amended yet... The reason for omitting the words "Auto-drafted" in Sec. 38(1) of the CGST Act, 2017 is GSTR 2B is no longer auto drafted statement, the tax payer could influence the value by using the Accept or Reject or Pending option in the IMS...

[KASTURI SETHI]

Govt.s intention is to make it mandatory w.e.f. 1.10.25. Only legal formality of issuing notification to this effect is pending.

Meaning of "Notification"  

It means and implies a formal announcement of a legally relevant fact. Formal declaration and publication of an order and shall have to be in accordance with the declared policies  or in the event the requirement of the statue then in that event in accordance therewith.   

Source :  Legal dictionary based on the judgement of Supreme Court

[Rajan Kumar and associates]

Attention : Important Advisory on IMS

Oct 8th, 2025

It has come to notice that some posts are circulating incorrect information regarding changes in GST return filing from October 1, 2025. We would like to clarify the following:

I. No Change in Auto-Population of ITC : Input Tax Credit (ITC) will continue to auto-populate from GSTR-2B to GSTR-3B without any manual intervention. The mechanism of auto-population remains unchanged due to the implementation of the Invoice Management System (IMS).

II. GSTR-2B Generation

GSTR-2B will continue to be generated automatically on the 14th of every month, without any manual intervention by taxpayers or based on the actions taken by the taxpayers.
Taxpayers can take actions in IMS even after generation of GSTR-2B till filing of GSTR-3B and can regenerate GSTR-2B accordingly, if required.

III. Credit Note Handling (Effective October 2025 period onward)

Recipient taxpayers will have the option to keep a Credit Note or related document pending for a specified period.

On acceptance of Credit Note or related document, the recipient will also have the flexibility to reduce ITC only to the extent of its availment by adjusting the reversal amount manually.

Thanking You,

Team GSTN

AI Summary

Invoice Management System deemed mandatory from 1 October 2025 amid guidance on GSTR 2B auto population and credit note handling.
The core dispute is whether the Invoice Management System is mandatory from 1 October 2025: some view the Finance Act, 2025 plus notifications and portal readiness as sufficient to make IMS compulsory despite Rule 60 not yet being amended; others contend formal amendment of Rule 60 and issuance of a notification are required and flag portal unpreparedness and compliance difficulty for large taxpayers. GSTN guidance states ITC auto population is unchanged, GSTR 2B will be auto generated monthly on the 14th with regeneration possible until GSTR 3B filing, and recipients may keep credit notes pending with limited ITC adjustment on acceptance.