Unregistered persons can now generate e-Way Bill for GST compliance; Step-by-step guide on how to file ENR-03 on E-Way Bill portal

The Goods and Services Tax Network (GSTN) has introduced a new feature in the E-Way Bill (EWB) portal wherein unregistered persons (URPs) can generate an e-Way Bill without taking out a GST registration. This feature has been enabled from February 11, 2025 and requires filing of ENR-03 form. Under GST rules no goods over Rs 50,000 value can be transported if the corresponding e-Way Bill is generated. GST officials can seize both the transport vehicle and the goods if a valid e-Way is not generated for transporting the goods. “Earlier if there were no registered buyers or sellers in the transaction where the taxable value of goods are above Rs 50,000, the transporter would had to create the E-way Bill or one of the parties had to register for GST to generate it. Now this requirement is done away with effect from February 11, 2025if either one of them files ENR-03 and generated an e-Way Bill,” says Chartered Accountant Bimal Jain, founder, A2Z Taxcorp LLP.

What did GSTN say?

GSTN in an advisory dated February 15, 2025 said:

• A new feature has been introduced in the E-Way Bill (EWB) system to facilitate the enrolment of unregistered dealers supplying goods, with effect from 11.02.2025. In accordance with Notification No. 12/2024 dated 10th July 2024, Form ENR-03 has been introduced for the enrolment of unregistered dealers.
• Unregistered dealers engaged in the movement or transportation of goods can now generate e-Way Bills by enrolling themselves on the EWB portal and obtaining a unique Enrolment ID. This ID will serve as an alternative to the Supplier GSTIN or Recipient GSTIN for generating e-Way Bills.

How to use the ENR-03 form to generate e-Way bill without GST registration

GSTN said in the advisory how to fill up the ENR-03 form to generate e-Way Bill without GST registration:
1.Accessing ENR-03:
a)As per the notification, an Unregistered Person (URP) can enrol using Form ENR-03.
b)The option is available under the “Registration” tab in the main menu of the EWB portal.2. Filling Out the ENR-03 Form:
a)Upon selecting the option, the enrolment screen will be displayed.
b)The applicant must select their State and enter their PAN details, which will be verified.
c)The type of enrolment must be selected, and address details must be provided.
d)A mobile number must be entered, which will be verified via OTP.

3.Creating Login Credentials:
a)The user must create a username, check its availability, and set a password before submitting the details.
b)Upon successful submission, a 15-character Enrolment ID will be generated, and an acknowledgment will be displayed.
c)This Enrolment ID can be used for generating e-Way Bills in place of a GSTIN.

4.Generating an e-Way Bill:
a)The enrolled URP can log in to the EWB portal using the registered credentials.
b)By selecting the ‘Generate New’ option, the Enrolment ID will be auto-populated as the Supplier/Recipient.
c)Other relevant details must be entered before proceeding with e-Way Bill generation.

Step-by step guide on how to file ENR-03 form for generating e-Way Bill

As per the notification, Unregistered Persons (URPs) can enrol in the E-Way Bill system using Form ENR-03. Here’s a step by step guide on how to file ENR-03:

Step 1: Go to the GST E-Way Bill portal and click on the ‘Registration’ button available in the main menu interface. Upon selecting the option, the ENR-03 enrolment screen will be displayed.

Source: GSTN portal

Step 2: The user must select their State and enter their PAN details, which will undergo verification. The type of enrolment must be chosen, followed by entering the address details and mobile number, which will be verified through an OTP-based authentication. The user is required to create a username, check its availability, and set a password before confirming the submission of details.

Source: GSTN Advisory

Step 3: Upon submission, a 15-character Enrolment ID will be generated, and an acknowledgment will be displayed. This Enrolment ID can be used in place of a Supplier GSTIN or Recipient GSTIN for e-Way Bill generation. Additionally, the enrolled unregistered person (URP) can log in to the E-Way Bill Portal to generate eWay Bills.

Source: GSTN Advisory

Step 4: To generate an e-Way Bill, the user must log in to the E-Way Bill Portal using their username and password. The user should select the ‘Generate New’ option, where the Enrolment ID will be automatically populated as the Supplier/Recipient. After entering the required details, the eWay Bill can be successfully generated.

Source: GSTN Advisory

Jain says this will help unregistered buyers or sellers by getting a temporary registration for the sole purpose of generating an e-Way Bill. “In practical scenarios most transporters were reluctant to generate an E-Way Bill if both the buyers and sellers were unregistered. Now this won’t be a problem. The impact of this new functionality will be useful for those un-registered persons who run any business but their turnover is yet to cross the threshold required for GST registration. This will also help the government better track the movement of goods thereby making India more a much more formalised economy.”

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