You Don't Have a GSTIN Yet. Here's What Goes on Your Invoice.
Most freelancers in India start invoicing before they have a GST number. That's normal, it's allowed, and it isn't a hole in your paperwork. You do not need a GSTIN to send an invoice, to get paid, or to work with a large company.
What you do need is an invoice that doesn't create a problem later. There are about eight things on it, and one line that must not be on it.
General information for an independent freelancer supplying services in India, not advice on your specific facts. Thresholds, TDS rates and state rules have exceptions — one short conversation with a Chartered Accountant settles where you stand.
The short version
- You can invoice without a GST number.
- Do not write "GST" anywhere on it. Not as a line, not as a percentage, not as "GST @ 18% — not applicable".
- Don't call it a Tax Invoice. Call it an Invoice.
- Put your PAN on it. Your client needs it.
- Number your invoices in one clean sequence from day one.
- Keep a running total of what you've billed this financial year. That number decides when this article stops applying to you.
What goes on the invoice
1. The word "Invoice" — at the top. Not "Tax Invoice". That term belongs to a registered supplier charging tax under Rule 46, and it isn't yours yet.
2. Your details. Full name or trade name, address, email, phone. If you work as "Studio Nine" but your bank account is in your own name, put both. Mismatched names between the invoice and the bank account slow down payments at large companies more reliably than anything else on this list.
3. Your PAN. This is the one people forget, and it's the one that costs money — see below.
4. Client details. Company name exactly as registered, and their billing address. Ask for it rather than copying the website footer. The entity that pays you is often not the brand name you've been talking to, and an invoice made out to the wrong entity gets returned rather than paid.
5. Invoice number and date. One format, one sequence. More on this below.
6. What you did. One to four lines. "Website redesign — homepage, pricing page, blog template" beats "Design services". A vague description is the most common reason an invoice sits in an approval queue for two weeks while somebody works out what it's for.
7. The amount. One figure, clearly the total. No tax lines. No breakdown you can't explain.
8. How to pay you, and by when. Bank name, account number, IFSC, account holder name. A UPI ID if you take small payments. And a due date — an actual date, not "Net 30". People pay dates; they don't calculate terms.
That's the whole invoice. What's missing from it is as deliberate as what's on it:
| Field | Registered supplier | You, unregistered |
|---|---|---|
| Document title | Tax Invoice | Invoice |
| Supplier GSTIN | Mandatory | You don't have one — leave it off |
| Your PAN | Optional | Put it on |
| HSN / SAC code | Mandatory above the notified turnover | Leave it off |
| CGST / SGST / IGST lines | Mandatory | None. No tax line of any kind |
| Place of supply | Mandatory | Not applicable |
| LUT / export declaration | Needed for zero-rated exports | You can't file an LUT unregistered |
| Serial number, unique for the year | Mandatory under Rule 46(b) | Not required — do it anyway |
The line that causes trouble
If you are not registered, you cannot charge GST. Not at 18%, not at any rate, not "to be adjusted once my registration comes through".
This is a specific prohibition, not a formality. Section 32 of the CGST Act says a person who is not registered shall not collect any amount by way of tax. Section 76 then says that anyone who has collected an amount as tax has to pay it to the Government — whether or not the underlying supply was taxable at all — with interest, and that the department can raise a demand for it. So the money doesn't stay with you, and the exposure sits with you rather than with the client who asked for it.
There is no version of this that ends well, including the common one where a freelancer adds 18% because "the client's finance team asked for a GST invoice".
If a client asks for a GST invoice and you don't have a GSTIN, the plain answer works: "I'm not GST-registered, so this invoice carries no GST. My PAN is on it for your TDS." Most finance teams process that without a second message. They deal with unregistered vendors constantly.
Two related things to avoid:
- Don't write "GSTIN: Applied For" unless you have actually applied and can produce the ARN.
- Don't borrow a GSTIN from a friend's firm, a co-founder, or a company you used to work at. The invoice then belongs to that entity, in that entity's return, and the liability is theirs. It is not a favour anyone understands the size of when they agree to it.
Your PAN, and why the client keeps asking
Your client will usually deduct tax at source before paying you. For professional or technical services that's Section 194J, and it has nothing to do with GST — it's income tax, and it applies to unregistered freelancers exactly as it applies to registered ones.
Two practical consequences:
- No PAN on file means a higher deduction. Section 206AA sets the floor at 20% when the payee's PAN isn't available, against the 10% that professional fees normally attract. That difference is your working capital, sitting with the Government until you file.
- The deduction shows up in your Form 26AS / AIS against your PAN, which is how you claim it back. Money deducted against a wrong or missing PAN is genuinely painful to trace.
Put the PAN on the invoice itself rather than emailing it separately. It ends up in their vendor master that way, and you stop being asked.
Numbering, before anyone requires it of you
Pick one format and don't change it mid-year. 2026-001, INV-001, or plain 001 — all fine. What matters:
- Sequential, no gaps
- Same padding throughout —
001,002,010, not001then0002 - Restart at 1 on 1 April, when the financial year turns
Nothing compels this while you're unregistered. The reason to be disciplined now is that on the day you register, Rule 46(b) makes it mandatory: consecutive, unique within the financial year, sixteen characters maximum, letters and numerals with only hyphen and slash as punctuation. Freelancers who arrive at registration with three years of invoice_final_v2.pdf spend their first month reconstructing a series instead of working.
If you start clean, starting a new series mid-year at the point you register is a twenty-minute job. And when the tax invoice fields do become mandatory, the full Rule 46 checklist is the list you'll be working from.
Foreign clients
You can invoice a client in the US, UK or EU in their currency without a GST number. Show the amount in USD, EUR or GBP, add your SWIFT/BIC and your bank's address, and keep it otherwise identical to a domestic one.
You don't file an LUT, because the LUT only exists for registered businesses. You also don't charge GST — for a different reason than the domestic case, but the invoice looks the same either way. Section 194J TDS generally doesn't apply either, since a foreign client isn't deducting Indian tax. When you do register, invoicing foreign clients in USD picks up an export declaration, a place of supply and a currency-conversion rule for your books.
One thing to start now regardless: save every FIRC, bank advice or remittance confirmation for money arriving from abroad. That trail is much easier to collect as it happens than to reconstruct two years later, and it's the evidence your export treatment rests on once you are registered.
When this article stops applying
The threshold is ₹20 lakh of aggregate turnover in a financial year for a service provider — ₹10 lakh in the special category states. Below it, registration is generally optional, including when your clients are in other states. Inter-State suppliers of services are exempt from the compulsory-registration requirement in Section 24 up to the same threshold, under Notification 10/2017-Integrated Tax. That's the point most articles get wrong, because the rule genuinely is different for goods.
Two things make people register earlier than they have to:
- Foreign clients and refunds. No LUT and no input tax credit without registration. If a meaningful share of your income is export revenue, the arithmetic often favours registering before you're forced to.
- Enterprise clients. Some large companies simply won't onboard an unregistered vendor. That's procurement policy rather than law, but it's not a policy you'll win an argument with.
Whether you should register is worth ten minutes of thought before you hit the threshold rather than after. Registration is not free — it commits you to monthly or quarterly filings for as long as it's live.
Practical version: keep a running total of billed amounts for the financial year somewhere you'll actually look. Most freelancers discover they crossed ₹20 lakh in November while filing something the following August.
Where Mavoin fits
Mavoin was built for the complicated end of this — GST invoices, export invoices, foreign currency — but it handles the simple version too. Clean numbering, one client list, your PAN on the document, a PDF out, and a record of what's been paid and what hasn't.
The point of starting here is that nothing gets rebuilt on the day you register. Your numbering carries on from where it was, your clients and history stay put, and the GST fields switch on when you have a GSTIN to put in them. GST and multi-currency invoicing from ₹199/month.
Start a 30-day trial — no card required.
Sources: Section 32, CGST Act 2017 (CBIC) · Section 76, CGST Act 2017 (CBIC) · Notification 10/2017-Integrated Tax (CBIC)
Mavoin is not a Chartered Accountant service. General information, current as of August 2026.
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Start 30-day trialFrequently asked questions
Can I send an invoice without a GST number in India?
Yes. There is no requirement to be GST-registered in order to invoice a client. You simply cannot charge GST on that invoice.
What do I call the invoice if it isn't a tax invoice?
Just Invoice. The term Tax Invoice describes the document a registered supplier issues while charging GST under Rule 46, so it doesn't apply to you until you have a GSTIN.
My client insists on a GST invoice. What do I do?
Tell them you are not registered and that the invoice carries no GST. Include your PAN so they can handle tax deducted at source. If their procurement policy genuinely blocks unregistered vendors, that is a reason to consider registering — not a reason to add a tax line you are not entitled to collect.
Will my client still deduct TDS if I am not GST-registered?
Likely yes. Tax deducted at source is an income tax matter and is unrelated to GST registration. Professional fees usually fall under Section 194J. Put your PAN on the invoice so the deduction happens at the normal rate rather than the 20% floor Section 206AA applies when no PAN is available.
Do I need an HSN or SAC code on a non-GST invoice?
No. Those are fields of a GST tax invoice issued by a registered supplier. Leave them off until you register.
What happens if I charged GST without being registered?
Stop immediately and speak to a Chartered Accountant. Section 32 of the CGST Act prohibits an unregistered person from collecting tax, and Section 76 requires any amount collected as tax to be paid to the Government with interest whether or not the supply was taxable. It is far better addressed early than found later.
Should I register voluntarily?
It depends on whether you bill foreign clients, whether input tax credit is worth anything to you, and what your clients require to onboard a vendor. It also commits you to monthly or quarterly filings from the date it is granted. It is a real decision, not a default.
Do I have to register because my client is in another state?
Not for services, up to the threshold. Notification 10/2017-Integrated Tax exempts inter-State suppliers of services from the compulsory registration requirement in Section 24 while aggregate turnover stays under the limit. The answer is different for goods, which is why so much general advice says otherwise.