GST E-way Bill — Rule 138 Mechanics for FY 2025-26

Why the E-way Bill exists

The E-way Bill (EWB) is an electronic permit generated on the EWB common portal before the movement of goods exceeds the prescribed consignment-value threshold. Mandated under Rule 138 of the CGST Rules 2017, it replaced the pre-GST physical state-border check-posts and paper-based waybills.

The mechanism creates a continuous digital chain from invoice → e-invoice IRN → EWB → physical movement → GSTR-1 reporting. It enables real-time enforcement against undeclared movement and makes detention proceedings under Section 129 / 130 procedurally simple.

For where the EWB intersects with invoicing and return-filing, see the e-invoicing applicability + IRP mechanics spoke and the GSTR-1 monthly + quarterly filing spoke.

When EWB is required + the ₹50,000 threshold

Inter-state movement

For movement of goods between States or Union Territories, EWB is mandatory if consignment value > ₹50,000.

Two carve-outs override the threshold (EWB mandatory regardless of value):

1. Inter-state movement of goods sent by a principal (one State) to a job worker (another State)
2. Inter-state movement of handicraft goods by a person exempt from registration

Intra-state movement

The CGST default is also ₹50,000, but Rule 138(1) empowers individual States to notify their own thresholds. Most States have notified ₹1,00,000 for intra-state movement; some retain ₹50,000. Always verify the State Commercial Tax Department’s current threshold before relying on the ₹1L assumption.

Consignment value computation

“Consignment value” determines whether the threshold is breached:

• Includes the value of goods per the invoice / bill of supply / delivery challan
• Includes CGST + SGST + IGST + Cess charged in the document
• Excludes the value of exempt goods (if the invoice covers a mix of taxable + exempt supplies, only the taxable portion counts toward the threshold)

Who must generate

Registered consignor (default)

A registered supplier shipping goods is the default generator. Alternatively, the registered recipient (if the supply is from an unregistered to a registered person) is the generator.

Transporter (when consignor doesn’t generate)

If the consignor doesn’t generate the EWB and the goods are handed over for transportation, the transporter must generate the EWB using the invoice / delivery challan furnished by the consignor.

If multiple consignments are carried in a single conveyance and the aggregate value exceeds ₹50,000 — even if no individual consignment crosses the threshold — the transporter must generate a consolidated E-way Bill in Form GST EWB-02.

E-commerce operator scenarios

For goods supplied through an e-commerce operator or a courier agency, the operator / courier can generate the EWB on behalf of the consignor if authorised. This is common for marketplace-fulfilled shipments.

Part A + Part B mechanics

Form GST EWB-01 has two sections.

Part A — consignment details

• GSTIN of supplier + recipient (or “URP” if recipient is unregistered)
• Place of delivery (PIN code)
• Document number + date (invoice / bill of supply / delivery challan)
• Value of goods + GST breakup
• HSN code (2-digit if AATO ≤ ₹5 cr; 4-digit or higher if AATO > ₹5 cr per current notification)
• Reason for transportation (supply, export, job work, line sales, etc.)

Part B — vehicle / transport details

• Vehicle number (road) or transporter ID + transport document number (rail / air / vessel)
• Mode of transport

The EWB is not valid for movement until Part B is updated — except in the 50 km Part-B-exemption scenario (covered below).

Vehicle change mid-transit

If goods are transferred to another vehicle (breakdown, trans-shipment, multi-leg movement), the person responsible for the new leg must update Part B with the new vehicle number on the EWB portal before movement resumes. Continuing with the old Part B is treated as movement without a valid EWB.

Validity period + extension

The validity is distance-based and starts when Part B is first updated.

Normal cargo

1 day per 200 km (or part thereof). A consignment travelling 350 km is valid for 2 days (200 km = 1 day; additional 150 km, being part of the next 200 km block, = 1 day).

Over-dimensional cargo + multimodal vessel shipments

1 day per 20 km (or part thereof). The shorter slab reflects the slower movement and handling overhead.

Extension rules

If the consignment cannot reach the destination within the validity period due to exceptional circumstances — vehicle breakdown, natural calamity, law-and-order issues, trans-shipment delays — the transporter can extend the validity. The extension window:

• 8 hours before expiry to 8 hours after expiry
• Requires reason + current location of the goods
• Extension creates a new validity duration counted from the original expiry

Outside the 16-hour window, extension is not permitted — a fresh EWB must be generated, which exposes the consignment to scrutiny on the gap period.

EWB cancellation + rejection

Cancellation by generator within 24 hours

If the EWB is generated with incorrect details, or the consignment is not actually moved, the generator can cancel on the EWB portal within 24 hours of generation. After 24 hours, cancellation is not permitted.

Cancellation is also blocked if the EWB has been verified in transit by a proper officer — at that point the EWB is treated as activated and any subsequent cancellation is investigated.

Rejection by recipient within 72 hours

When an EWB is generated against a recipient’s GSTIN, the recipient sees it on the portal. The recipient can communicate acceptance or rejection within 72 hours of details being made available, or by the time of delivery, whichever is earlier. If neither is communicated within 72 hours, the EWB is deemed accepted (and the consignment-value goes into the recipient’s GSTR-2A / 2B trail).

Rule 138E — block of EWB generation

Rule 138E is the compliance-enforcement mechanism. It blocks EWB generation for non-compliant filers:

Continuous 2-period non-filing

• Regular taxpayer: non-filing of GSTR-3B for 2 consecutive months (or 2 consecutive quarters under QRMP)
• Composition taxpayer: non-filing of CMP-08 / GSTR-4 for 2 consecutive quarters

The block applies to the GSTIN as both consignor (cannot generate own EWBs) and consignee (cannot have EWBs generated against the GSTIN).

Unblocking

• Automatic: filing the pending returns triggers auto-unblock typically within 24 hours
• Manual: Form GST EWB-05 to the jurisdictional officer with reasons; officer can pass an order in Form EWB-06 to unblock for a specific period

Connection to e-invoicing

For taxpayers under the e-invoicing mandate (AATO > ₹5 cr per current threshold), EWB and e-invoice workflows are integrated to avoid duplicate data entry.

IRP auto-population of Part A

When an IRN is generated on the Invoice Registration Portal (IRP), the consignment details flow to the EWB portal automatically. Part A is pre-populated from the e-invoice payload.

Auto-generation of complete EWB

If vehicle details are included in the e-invoice payload at IRN generation, the IRP triggers full EWB generation (Part A + Part B) — no second portal trip needed. If vehicle details are not yet known at invoicing, the EWB Part A is pre-populated; the supplier or transporter logs into the EWB portal later, retrieves the EWB by IRN, and updates Part B.

This integration is why an e-invoice supplier rarely needs to manually re-enter Part A; the gap is only in updating Part B if vehicle details emerge after IRN generation.

Penalties for movement without a valid EWB

Movement of goods exceeding the threshold without a valid EWB attracts immediate action under Sections 129 + 130:

Section 129 — detention + seizure

• Goods + conveyance detained by the intercepting officer
• For taxable goods: penalty = 200% of the tax payable on the goods (where the owner comes forward to pay)
• For exempt goods: penalty = 2% of the value of goods or ₹25,000, whichever is less
• Where the owner does not come forward, penalty = 50% of the value of goods (or applicable tax + 100% of value, depending on category)

Section 130 — confiscation

Where intent to evade tax is established, goods + conveyance can be confiscated. Fine in lieu of confiscation = market value of goods (less the tax chargeable), capped at not less than the penalty under Section 129. The taxpayer must also pay the underlying tax + penalty.

EWB exemptions

Rule 138(14) exempts specific scenarios from EWB requirements:

Commodity-based exemptions

• Goods specified in Annexure to Rule 138 (e.g., jewellery, currency, used personal + household effects, LPG for domestic use, kerosene for PDS)
• Goods exempt from GST under specific notifications (fresh milk, raw meat, exempt agricultural produce)
• Alcoholic liquor for human consumption, petroleum crude, HSD, motor spirit, natural gas, and ATF (outside GST framework anyway)

Mode-based exemptions

• Goods transported by a non-motorised conveyance (handcart, animal-drawn cart, manual)
• Goods transported under customs bond between ICD / CFS and a customs port / airport / land customs station (or vice versa)
• Goods transported to / from the Ministry of Defence

Short-distance Part-B exemption

For movement within the same State / UT for a distance ≤ 50 km — from the consignor’s place of business to the transporter’s place of business, or from the transporter to the consignee — Part B is not required. Part A is still required.

2025 portal changes — 2-factor authentication

The NIC has been progressively mandating 2-factor authentication (2FA) for login to the EWB + e-Invoice portals through 2025, rolled out by AATO tier:

• Phase 1: AATO > ₹100 cr
• Phase 2: AATO > ₹20 cr
• Phase 3: AATO > ₹5 cr
• Phase 4: all taxpayers

The exact effective dates per tier shift periodically; verify the current NIC advisory before each phase. 2FA is typically via OTP to the registered mobile / email of the authorised signatory.

Common SME mistakes

1. Treating ₹50,000 as inclusive of basic value only — consignment value under Rule 138 includes GST. A ₹46,000 base value + ₹8,280 GST (18%) = ₹54,280 consignment value → EWB required. The taxable-value-only mental model misses the threshold.
2. Failing to update Part B on vehicle change — trans-shipment without portal update invalidates the EWB and exposes the consignment to Section 129 detention. The old vehicle number on the EWB is the first cross-check the field officer performs.
3. Assuming ₹1 lakh intra-state threshold without checking State notification — most States are at ₹1L, but the consignor’s State (origin) governs, not the destination State. Cross-border issues arise where the origin State has a lower threshold than the destination.
4. Missing the 16-hour extension window — attempting to extend an expired EWB 10 hours after expiry fails (the window is 8 before + 8 after). Must generate a new EWB, with risk of detention on the in-between gap.
5. Mismatch between e-invoice and manually-generated EWB — generating an e-invoice via IRP, then separately creating an EWB on the portal with slightly different values or dates instead of pulling Part A from the IRN. The resulting mismatch surfaces in GSTR-1 reconciliation as a flagged discrepancy.
6. Ignoring the 72-hour rejection window as a recipient — accepting all GSTIN-based EWBs by default means accepting any false-supplier-generated EWB into your audit trail. Establishing a recipient-side review process within the 72-hour window blocks erroneous or fraudulent attributions.

For the broader GST framework + return-filing cadence that the EWB feeds into, see the GSTR-3B summary return spoke and the GSTR-1 monthly + quarterly filing spoke. For end-to-end EWB + e-invoice + return-filing through partner CA firms, see the GST Return Filing service.