GST Returns

Invoice Management System (IMS): How to Accept or Reject Invoices Before GSTR-2B Locks (2026)

GST Consultancy Team24 June 20269 min read
IMSInvoice Management SystemGSTR-2BITCGSTR-3Bdeemed acceptanceSection 38reconciliation
Since 1 October 2025, your ITC is legally tied to the invoices you accept in the Invoice Management System. Here's what each IMS action does to your GSTR-2B, the deemed-acceptance trap that can cost you interest, and how to act before the return locks.

Last updated: 23 June 2026. For its first year the Invoice Management System (IMS) was an optional convenience — a dashboard where you could accept or reject the invoices your suppliers filed against your GSTIN. That changed on 1 October 2025. With Section 38 of the CGST Act now rewritten to match how the portal actually works, the input tax credit in your GSTR-2B is tied to the records you accept in IMS. This guide explains what each IMS action does, the one default that quietly costs people money, and how to finish your review before the return locks.

Applicability Note: This guide reflects GST provisions, GSTN advisories, and CBIC notifications applicable as of 23 June 2026. IMS behaviour has changed through successive GSTN advisories and may change again — the GST portal is the authoritative source. Always verify the current position on gst.gov.in or with a GST professional before acting on your returns.

What IMS Is — and Why It Now Matters

The Invoice Management System went live on the GST portal on 1 October 2024, with the first IMS-based GSTR-2B generated for the October 2024 tax period. It is a single dashboard showing every invoice, debit note, and credit note your suppliers have filed in their GSTR-1, IFF, or GSTR-1A against your GSTIN — before any of it becomes your GSTR-2B.

For the first twelve months IMS ran without direct statutory backing. That gap closed on 1 October 2025, when the substituted Section 38 was brought into force by Notification No. 16/2025-Central Tax dated 17 September 2025. The legal effect: your GSTR-2B is now built from the records you have accepted (or are treated as having accepted), and your eligible ITC flows from there. IMS stopped being a nice-to-have and became the gate your credit passes through.

The Four Actions — and What Each Does

For every record on the dashboard you can take exactly one of four positions. Here is what each one does to your GSTR-2B and, downstream, your GSTR-3B:

Action What It Means Effect on GSTR-2B / ITC
Accept The record is correct and belongs to you. Moves to "ITC Available" in GSTR-2B; auto-populates as eligible ITC in GSTR-3B.
Reject The record is wrong — not yours, wrong GSTIN, or a duplicate. Goes to "ITC Rejected"; the credit does not flow to GSTR-3B.
Pending You can't decide yet (goods not received, dispute open). Held back from this month's GSTR-2B; carried to a later period. Allowed only for specified records and only for one tax period.
No action You never touched the record. Deemed accepted — flows into GSTR-2B exactly as if you had clicked Accept.

The Trap: "No Action" Is Not "Safe"

The single most expensive misconception about IMS is that ignoring the dashboard is the cautious choice. It is the opposite. A record you never look at is deemed accepted and lands in your GSTR-2B as available ITC.

So if a supplier files an invoice against your GSTIN by mistake — or a fraudulent one — and you take no action, that credit auto-populates into your GSTR-3B. If you then claim it, you have availed ITC you weren't entitled to, and you'll have to reverse it with interest at 18% per annum under Section 50 of the CGST Act. The portal's default works against the inattentive taxpayer, not for them.

The takeaway: review the IMS dashboard the way you'd review a bank statement — every line, every month. Reject what isn't yours before it becomes deemed-accepted ITC.

One more guardrail worth stating plainly: accepting a record in IMS — or having it deemed accepted — does not on its own entitle you to the credit. The conditions of Section 16(2) still apply independently: you must have received the goods or services, hold a valid tax invoice, and the supplier must have actually paid the tax to the government. IMS controls what appears in your GSTR-2B; Section 16 still controls what you may lawfully claim.

"Before GSTR-2B Locks": The Timing That Matters

IMS is a live dashboard you can act on at any time, but two dates govern when your actions count:

  • The 14th of the next month — your draft GSTR-2B is generated, reflecting whatever Accept/Reject/Pending/No-action positions stand at that moment.
  • The moment you file GSTR-3B — this is the real lock. Once GSTR-3B is filed for the period, the GSTR-2B for that period is frozen, and you can no longer change its ITC.

You can still change an action after the 14th — up until you file GSTR-3B — but if you do, you must recompute GSTR-2B using the "Compute GSTR-2B" button so the statement reflects your latest decisions. Skip the recompute and your GSTR-3B auto-population won't match your corrected IMS actions. The cleanest workflow is to finish your review before the 14th so the first draft is already right.

The "Pending" Action Has Limits

Pending is useful when you genuinely can't decide — but it isn't a parking spot for everything. From the October 2025 tax period, GSTN extended Pending to a defined set of records and put a clock on it. You can keep the following pending, but only for one tax period (one month for monthly filers, one quarter for quarterly filers):

  • Credit notes, and upward amendments of credit notes;
  • A downward amendment of a credit note where the original credit note was rejected;
  • A downward amendment of an invoice or debit note where the original was accepted and its GSTR-3B already filed;
  • A downward amendment of an ECO document (the supply an e-commerce operator reports under Section 9(5)) where the original was accepted and its GSTR-3B already filed.

After that single period, the record must be Accepted or Rejected — it can't sit in Pending indefinitely. For credit notes specifically, accepting one reduces your ITC, so the portal also asks you to declare the ITC reversal where part of the credit was already availed. The practical rule: use Pending sparingly, and clear it the following period.

A Simple Monthly IMS Routine

  1. Log in at gst.gov.in → Services → Returns → Invoice Management System (IMS).
  2. Sort by supplier and match each record against your purchase register and goods-receipt records.
  3. Accept genuine purchases you've received and hold a tax invoice for.
  4. Reject anything that isn't yours — wrong GSTIN, duplicate, or an invoice you don't recognise — so it never becomes deemed-accepted ITC.
  5. Keep Pending only the limited, eligible records you genuinely can't decide on, and remember to clear them next period.
  6. Finish before the 14th. If you act after the draft generates, click Compute GSTR-2B to recompute before filing.
  7. Reconcile GSTR-2B against your books, then file GSTR-3B. Once filed, the period is locked.

For the reconciliation step that comes right after IMS, see our guide on GSTR-2B Reconciliation Before GSTR-3B, and the filing walkthrough in How to File GSTR-3B.

Key Takeaways

  • IMS went live on 1 October 2024; since 1 October 2025 it has statutory backing — Section 38 was substituted via Notification No. 16/2025-Central Tax dated 17 September 2025, so ITC now follows the records you accept in IMS.
  • Four actions: Accept, Reject, Pending, No action. No action means deemed accepted — the record enters your GSTR-2B as available ITC.
  • Reject wrong or fraudulent records before they're deemed accepted. Claiming ITC you weren't entitled to means reversal with 18% interest under Section 50.
  • IMS acceptance is not a substitute for Section 16(2) conditions — receipt, valid invoice, and tax actually paid still apply.
  • Draft GSTR-2B generates on the 14th. You can act until you file GSTR-3B, but actions after the 14th require recomputing GSTR-2B. Filing GSTR-3B locks the period.
  • Pending is limited to specified records (mainly credit notes and certain amendments) and only for one tax period.

Frequently Asked Questions

What happens if I take no action on an invoice in IMS?

It is treated as deemed accepted and flows into your GSTR-2B as available ITC, exactly as if you had accepted it. "No action" is not a safe default — review and reject anything that isn't genuinely yours, or you may end up reversing the credit with interest.

Can I change my IMS action after GSTR-2B is generated on the 14th?

Yes — you can Accept, Reject, or keep Pending right up until you file GSTR-3B for the period. But any action taken after the 14th means you must recompute GSTR-2B using the "Compute GSTR-2B" button so the figures auto-populating into GSTR-3B reflect your latest decisions. Once GSTR-3B is filed, the period is locked.

Does accepting an invoice in IMS guarantee my ITC?

No. Accepting a record puts it in GSTR-2B, but the credit is still subject to Section 16(2) — you must have received the goods or services, hold a valid tax invoice, and the supplier must have paid the tax to the government. IMS controls what appears in 2B; Section 16 controls what you can lawfully claim.

Which records can I keep Pending, and for how long?

From the October 2025 tax period, Pending is allowed for specified records — credit notes and their upward amendments, a downward amendment of a credit note where the original was rejected, a downward amendment of an invoice/debit note where the original was accepted and its GSTR-3B filed, and a downward amendment of an ECO document (Section 9(5)) on the same accepted-and-filed condition. These can be kept pending for only one tax period (one month for monthly filers, one quarter for quarterly filers), after which you must accept or reject them.

I rejected an invoice by mistake — can I fix it?

Yes. As long as you haven't filed the GSTR-3B for that period, go back into IMS, change the action to Accept, and recompute GSTR-2B before filing. If the period has already been filed, the record can be acted on in a subsequent period — GSTN has issued advisories on handling inadvertently rejected records; verify the current procedure on the portal.

Disclaimer: This article is for informational purposes only and does not constitute professional tax advice. GST rules are subject to frequent changes through notifications, circulars, and GSTN advisories. Please consult a qualified tax professional or verify the current provisions on the official GST portal (gst.gov.in) before making any compliance decisions.

Want your IMS dashboard reviewed and reconciled every month so no wrong invoice slips into your ITC? Our GST experts can manage it → gstconsultancy.com

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