GST Rule 16A — Notification No. 07/2025-Central Tax, dated 23 January 2025: The Central Goods and Services Tax Rules, 2017 ('CGST Rules') are amended to insert Rule 16A, which creates a Temporary Identification Number (TIN) for persons not liable to GST registration but required to make a GST payment. A proper officer issues the TIN and records it in Part B of the substituted FORM GST REG-12. The rule, along with related amendments to Rules 19 and 87(4), comes into force on a date to be separately notified by CBIC.
TL;DR for founders
If your business has a non-resident counterparty, a one-time importer, or any entity that is not required to register for GST in India but still owes a GST payment — Notification No. 07/2025-Central Tax gives that entity a formal mechanism to discharge the liability. CBIC issues the entity a Temporary Identification Number (TIN) via FORM GST REG-12 Part B. The TIN is a payment-only credential: no tax collection, no Input Tax Credit. The rule is not yet operative — watch the CBIC notifications listing for the activation date.
What Notification No. 07/2025-Central Tax says
Notification No. 07/2025-Central Tax, issued by CBIC on 23 January 2025 under No. CBIC-20001/15/2024-GST, amends the Central Goods and Services Tax Rules, 2017 ('CGST Rules'), with principal rules published under G.S.R. 610(E) dated 19 June 2017 and last amended by G.S.R. 626(E) dated 8 October 2024. The notification makes four changes, all taking effect on a date to be separately notified:
Rule 16A inserted (after Rule 16 of the CGST Rules): A new rule titled "Grant of temporary identification number" is inserted. Where a person is not liable to registration under the Central Goods and Services Tax Act, 2017 ('CGST Act') but is required to make any payment under the Act, the proper officer may grant that person a Temporary Identification Number and issue an order in Part B of FORM GST REG-12. This is the core change — it creates a statutory home for the TIN mechanism.
FORM GST REG-12 substituted in full: The pre-existing FORM GST REG-12, which covered temporary registration orders (suo motu registration in seizure/detention scenarios), is replaced with a two-part form. Part A retains the existing temporary registration order: where the proper officer believes a person is liable for registration, the person is registered temporarily and directed to file for regular registration within 90 days. Part B is entirely new: it is the TIN issuance order for non-registerable persons who owe a payment, capturing name, address, PAN (if available), mobile, email, and other identity details, along with the effective date and the assigned TIN. (Full substituted form text in corpus entry [CGST_07_2025] on Veritect Legal AI.)
Rule 19(1) amended: Sub-rule (1) of Rule 19 of the CGST Rules (which deals with amendments to registration) is amended to add, after "FORM GST REG-10", the phrase "or in the intimation furnished by the composition taxpayer in FORM GST CMP-02". This means that a composition taxpayer's intimation filed in FORM GST CMP-02 can also serve as an amendment application — reducing the compliance steps for composition taxpayers who switch categories or update registration details through the intimation pathway.
Rule 87(4) amended: Rule 87 governs the electronic credit/cash ledger and payments through the common portal. Sub-rule (4) is amended to add, after "common portal", the words "as per rule 16A". This ties payment through the common portal by a TIN holder directly to the new Rule 16A mechanism, ensuring that the electronic payment infrastructure recognises and processes TIN-based payments.
Who is affected
The Rule 16A TIN pathway is designed for a specific, narrow category of persons. It is relevant to:
- Non-resident persons and foreign entities that incur an occasional GST liability in India — for example, a foreign company that provides online services to Indian business customers in a transaction where the Indian business is not itself registered and no reverse charge mechanism applies.
- Persons below the registration threshold under Section 22 of the CGST Act (currently ₹40 lakh aggregate turnover for goods in most states, ₹20 lakh for services) who nonetheless incur a one-time GST payment obligation — for instance, a casual transaction that is taxable under the Act but does not meet the mandatory registration threshold.
- Persons not required to register under Sections 22 to 24 of the CGST Act but who fall into a payment liability through a specific provision — for example, Section 9(3) or Section 9(4) reverse charge mechanism scenarios where the recipient is unregistered and must discharge tax but cannot register because the aggregate turnover threshold is not met.
- Composition taxpayers updating registration details via FORM GST CMP-02 — the Rule 19(1) amendment directly affects how their intimation filings interact with the registration amendment procedure.
- Proper officers handling seizure and detention proceedings — the substituted FORM GST REG-12 now clearly separates temporary registration orders (Part A) from TIN issuance orders (Part B), reducing the risk of cross-form confusion in enforcement actions.
Practical implications
Fills a structural gap in the payment architecture. Prior to this amendment, no formal mechanism existed in the CGST Rules to assign an identifier to a non-registerable person who owed a GST payment. In practice, such payments were either handled through ad hoc AO discretion or routed through the registrant who was counterparty to the transaction. Rule 16A provides a statutory pathway and a specific form, removing that discretionary gap.
TIN is not equivalent to registration. This distinction matters for several downstream GST compliance questions. A TIN holder under Rule 16A is not a "registered person" for the purposes of the CGST Act. As a result: (a) the TIN holder cannot issue tax invoices or collect GST on outward supplies under Section 31 of the CGST Act; (b) no Input Tax Credit accrues to or is claimable by the TIN holder under Section 16 of the CGST Act; (c) the TIN holder is not subject to the regular return-filing obligations under Section 39 of the CGST Act; (d) the TIN holder does not appear as a registered supplier in GSTR-2A/2B of the counterparty, which means ITC availability for the counterparty must be assessed through the applicable RCM or self-invoicing route.
Interaction with Section 9(3) and Section 9(4) RCM. The most likely practical use of Rule 16A is in reverse charge mechanism scenarios. Under Section 9(3) of the CGST Act, certain notified supplies attract GST on the recipient. Under Section 9(4), supplies from unregistered persons to registered persons can attract RCM in notified circumstances. If the unregistered supplier is below the registration threshold and cannot register, Rule 16A gives a formal mechanism for the proper officer to assign a TIN so that the supplier can comply with a directed payment — rather than leaving the entire liability on the recipient or creating an unresolved payment obligation.
E-invoicing system is not implicated. TIN holders are outside the e-invoicing framework. E-invoicing under Rule 48(4) of the CGST Rules applies to registered persons above the notified turnover threshold (currently ₹5 crore, per Notification No. 10/2023-Central Tax). Since TIN holders are not registered persons, they do not generate Invoice Reference Numbers (IRN) and are not captured in the e-invoice portal ecosystem.
Composition taxpayer impact. The Rule 19(1) amendment is largely administrative. It codifies in the CGST Rules that a FORM GST CMP-02 intimation by a composition taxpayer can serve as an amendment application — previously this may have required a separate FORM GST REG-14 in some field formations. The practical effect is a marginal compliance-process simplification for composition taxpayers who change their tax category status or update registration details through the intimation pathway.
Operational caution: the effective date has not been notified. All four changes in Notification No. 07/2025-Central Tax are subject to a deferred activation clause: each takes effect on "a date to be notified". As of April 2026, no CBIC gazette notification has activated Rule 16A or the related amendments. The notification was published in the Official Gazette on 23 January 2025, but the operative provisions are not yet in force. Any advice to clients about TIN availability or the amended FORM REG-12 should be hedged accordingly until the activation notification is published.
Effective date and transitional provisions
Notification No. 07/2025-Central Tax was published in the Official Gazette on 23 January 2025. Clause 1(2) of the notification states that the rules "shall come into force on the date of their publication in the Official Gazette" — however, each operative clause (Rule 16A insertion, Rule 19 amendment, Rule 87(4) amendment, and FORM REG-12 substitution) carries an individual override: "with effect from a date to be notified". This override clause suspends the general publication-date commencement for all four substantive changes.
The consequence is that:
- Existing FORM REG-12 (Part A only, prior to the 2025 substitution) remains the operative form for temporary registration and suo motu orders in seizure/detention proceedings until the activation notification is published.
- Rule 16A is not yet available as a ground for a proper officer to issue a TIN — any purported TIN issuance before the activation date would lack a valid rule basis.
- Rule 19(1) amendment and Rule 87(4) amendment are similarly suspended.
Practitioners should set a calendar alert to monitor the CBIC notifications listing at gstcouncil.gov.in/cgst-tax-notification for the activation gazette. When the activation notification is published, it will carry a G.S.R. number and a specific effective date — that date becomes the operative date for all four changes simultaneously (unless the activation notification itself provides for staggered commencement).
Founder checklist
- Monitor the CBIC notifications listing at
gstcouncil.gov.in/cgst-tax-notificationfor the Rule 16A activation gazette — set a calendar alert for a monthly check until the notification publishes.- If your business has foreign or non-resident counterparties who may owe GST payments in India, brief them on the TIN pathway so they can engage the proper officer once Rule 16A is activated.
- Do not use the new two-part FORM GST REG-12 format in any proceeding until CBIC publishes the activation notification — the substituted form has no operative basis before that date.
- For composition taxpayers: review your FORM GST CMP-02 intimation workflows once Rule 19(1) is activated; the amendment allows the CMP-02 intimation to serve as a registration amendment application, which may simplify your existing REG-14 process.
- Update your GST compliance manual to flag that TIN holders are not registered persons — they cannot issue tax invoices, claim ITC, or appear in GSTR-2A/2B of their counterparties.
FAQ
What is a Temporary Identification Number (TIN) under Rule 16A of the CGST Rules?
A Temporary Identification Number (TIN) is a payment identifier issued by a proper officer under Rule 16A of the Central Goods and Services Tax Rules, 2017. It is granted to a person who is not liable to registration under the CGST Act but who is required to make a payment under the Act. The TIN is recorded in Part B of FORM GST REG-12. Unlike a regular GST registration number, a TIN does not authorise the holder to collect GST from customers or claim Input Tax Credit.
Can a TIN holder claim Input Tax Credit (ITC) on purchases?
No. A TIN issued under Rule 16A of the CGST Rules is a payment-only identifier. The holder is not a registered taxable person under Section 25 of the CGST Act and therefore cannot claim Input Tax Credit under Section 16 of the CGST Act, nor is the holder permitted to issue tax invoices or collect GST on outward supplies. The TIN is strictly a one-way payment channel for discharging a GST liability.
When does Rule 16A come into force?
Notification No. 07/2025-Central Tax, issued on 23 January 2025, provides that Rule 16A and the related amendments to Rules 19 and 87(4) of the CGST Rules shall come into force "with effect from a date to be notified". As of April 2026, CBIC has not issued a separate activation notification. Practitioners should monitor the CBIC notifications listing at gstcouncil.gov.in/cgst-tax-notification for the operative date gazette.
How does FORM GST REG-12 differ after the 2025 amendment?
The substituted FORM GST REG-12 now has two parts. Part A is the existing order for grant of temporary registration or suo motu registration — applicable where the proper officer has reason to believe a person is liable for registration (for example, in seizure or detention proceedings) and directs that person to file for regular registration within 90 days. Part B is entirely new: it is the order granting a Temporary Identification Number to a person who is not liable for registration but owes a GST payment, capturing name, address, PAN, and other identity details along with the effective date and the assigned TIN.
Does Rule 16A affect regular GST registration under Section 22 of the CGST Act?
No. Rule 16A applies only to persons who are not liable to registration under the CGST Act — that is, persons who fall outside the thresholds and categories in Sections 22 to 24 of the CGST Act. It does not alter the registration threshold (currently ₹40 lakh for goods and ₹20 lakh for services in most states under Section 22), nor does it modify the liability to register for persons who cross those thresholds. A TIN holder who subsequently meets the registration threshold must still register under Section 25 of the CGST Act.
Sources
- Notification No. 07/2025-Central Tax (Central Goods and Services Tax (Amendment) Rules, 2025), CBIC, 23 January 2025. PDF — gstcouncil.gov.in
- Central Goods and Services Tax Act, 2017 (Act 12 of 2017), as amended. indiacode.nic.in
- Central Goods and Services Tax Rules, 2017 (G.S.R. 610(E), 19 June 2017, as amended through G.S.R. 626(E), 8 October 2024). gstcouncil.gov.in — CGST notifications listing
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