Introduction

E-way Bill is an electronic trace of movement of goods which is mandated by rule 138 of the CGST Rules, 2017. This rule mandates a form EWB-01 which prescribes what details are required to filled up. GSTN has issued an advisory dated 20.05.2026 whereby it has been stated that from 1st August 2026 it would be mandatory to mention either GSTIN / URP against the ‘Ship to’ address in case the E-way bill is for Bill to Ship to transaction.

Lets take a deep dive and see whether what GSTN has announced is legally plausible

Exactly Who is GSTN?

GSTN is merely a Common Portal as notified under section 146 of the CGST Act.

146. The Government may, on the recommendations of the Council, notify the Common Goods and Services Tax Electronic Portal for facilitating registration, payment of tax, furnishing of returns, computation and settlement of integrated tax, electronic way bill and for carrying out such other functions and for such purposes as may be prescribed.
Accordingly it is merely a facilitator of various procedural aspects, it has not been vested with any power whatsoever to make or announce any change in any procedural aspect. On this count alone the advisory of 20th May 2026 is illegal. Having said so, if the e-way bill portal makes these changes live and the GST officers on the roads take it as gospel truth, it will lead to unnecessary hassle whereby goods in transit will be held hostage which will lead to costly litigation.

Are the changes legally plausible?

Now lets see these changes from another lens, does the law, rules and the e-way bill form as notified permit GSTN to make these changes in the form no less announce it?

a. Rule 138 of CGST rules mandates the procedural aspects of e-way bill issuance. Sub-rule 1 thereof suggests that one has to provide information as specified in Part A of Form GST EWB-01.

b. Notified Part A of EWB 01 is placed below for all to see and witness. As per this notified Part A one is required to furnish GSTIN of only 2 persons:

  • Supplier
  • Recipient

c. As per section 2(93) of CGST Act the person who is liable to pay the consideration to the supplier is the recipient. Only in case of transactions where there is no consideration, the person receiving delivery is considered as the recipient, such transactions are not subject matter of this discussion.

d. Further, Part A also allows mentioning of Address of Place of dispatch and Place of Delivery, but conspicuously it doesn’t seek GSTIN of these two addresses.

e. In case of ‘Bill to Ship to Transaction’ there are 3 addresses as under:

  • Bill from : Supplier
  • Bill to : Recipient
  • Ship to: Place of Delivery

f. As explained above, Part A of EWB-01 seeks GSTIN of only the Supplier and Recipient, it has no prescription whatsoever for mentioning of GSTIN of Place of Delivery.

g. Further, Notes below Part A provide some clarifications, note 6 is relevant to this discussion and reads as under:

“6. Where the supplier or the recipient is not registered, then the letters “URP” are to be filled-in in column A.1 or, as the case may be, A.3.”

A.1 is for GSTIN of Supplier and A.3 is for GSTIN of Recipient. Again there is no prescription to mention URP in case of ‘Ship to’ address.

Conclusion

To summarize,

a. GSTN doesn’t have the powers to issue any advisory which makes any change to anything which is mandated by law, it is just a facilitator and not a regulator.
b. Notified form EWB-01 does not prescribe mentioning GSTIN / URP for ‘Ship to’ address.

So on both counts, the advisory issued by GSTN is illegal and doesn’t deserve to be given any weightage, in the recent past, GSTN had issued an advisory mandating change in IGST utilisation, they had to unceremoniously withdraw that advisory as it wasn’t legally sound. I had argued against it as well on Linkedin (see link) and there was a huge debate on it as well.

In the guise of stated virtues of “strengthening data integrity, improving traceability of goods movement” GSTN cannot overlook the legally mandated forms and its rightful place in law which doesn’t allow it to make changes in how business documentation is done.

I would sincerely urge the Government and the GST council to ask GSTN to resist from issuing such advisories in the future

Form EWB-01 – Part A is attached below for ease of reference