How to invoice without a GST/HST number in Canada
A source-backed guide to creating a clear Canadian invoice after confirming that the supplier is not registered for GST/HST, including practical fields, a precise no-tax note, client requests, Québec GST/QST, and status-change controls.
First confirm why GST/HST is not being charged
A no-tax invoice can reflect different legal situations. An ordinary small supplier that is not registered generally does not collect GST/HST on most taxable supplies. A registered supplier may instead make a taxable supply at 0%, while an exempt supply follows another set of rules. Those routes can affect the C$30,000 calculation, input tax credits, registration duties, and the words that belong on the invoice.
Before using an unregistered-supplier note, confirm both ordinary C$30,000 tests, include the required worldwide taxable supplies and applicable associates, and check mandatory-registration exceptions. Voluntary registration also changes the answer: once registered, a small supplier generally has charging, filing, and remittance duties for applicable taxable supplies.
Treat the invoice as the output of a dated status check, not as proof of that status. Keep unresolved supply classifications visible and confirm material or unusual facts with CRA, Revenu Québec where relevant, or a qualified adviser.
| Confirmed situation | Possible invoice treatment | Do not infer |
|---|---|---|
| Supplier is not registered and is not required to register | No GST/HST collected; explain the registration status | That the supply is exempt or zero-rated |
| Registered supplier makes a valid zero-rated supply | GST/HST applies at 0% and registration details may still matter | That the supplier is unregistered |
| Supply is legally exempt | No GST/HST is charged under the applicable exemption | That all of the supplier’s revenue is exempt |
Include the ordinary commercial invoice facts
A useful invoice should identify the supplier and customer, carry a unique invoice number, show the issue date and payment due date, describe the goods or services, and state quantities, rates, subtotal, total, currency, and payment terms as applicable. Add the business address and contact details that the contract or customer process requires.
These are practical recordkeeping fields, not a universal legal checklist for every industry. Contracts, procurement portals, regulated activities, provincial taxes, and special sales can require more. Keep the agreement, scope, delivery evidence, payment record, and any credit or revision connected to the same invoice reference.
Do not add a GST/HST amount or a tax-total line that could look collectible if the confirmed reason is that the supplier is not registered. A clean subtotal and total, plus a separate no-tax note, is usually clearer than inserting a fictional 0% tax calculation.
- Supplier and customer legal or operating names and contact details
- Unique invoice number, issue date, and payment due date
- Clear description, quantity or hours, rate, subtotal, total, and currency
- Payment method or terms and a precise no-tax status note
Use a precise no-tax note
For a confirmed unregistered supplier outside Québec, a clear operational note is: ‘GST/HST not charged. The supplier is not registered for GST/HST.’ It says why no tax was collected without assigning a supply classification that has not been reviewed.
For a confirmed Québec supplier that is neither registered nor required to register for both files, a possible note is: ‘GST and QST not charged. The supplier is not registered for GST/HST or QST.’ Confirm the two files separately before using that version because the GST and QST are distinct systems with their own exceptions.
Avoid ‘tax exempt,’ ‘zero-rated,’ ‘GST included,’ or ‘0% GST’ unless the underlying treatment has actually been established. No tax shown on an invoice does not, by itself, prove any of those conclusions.
Do not invent, borrow, or substitute a number
A GST/HST program account is not interchangeable with a nine-digit business number, a Québec enterprise number, a QST number, or a Social Insurance Number. Do not turn one identifier into another, append an RT suffix yourself, borrow another business’s account, or place a personal identifier on a commercial invoice to satisfy a tax-number field.
If a customer form requires a GST/HST number, explain that no number exists because the supplier is not registered and ask the customer to mark the field not applicable or document the exception. If the customer expects to claim an input tax credit for tax allegedly paid, the correct response is not to invent supporting information: no GST/HST was charged by the unregistered supplier.
Keep any business number or Québec enterprise number only in the field and format where it is genuinely relevant. Their presence does not represent GST/HST or QST registration.
Keep the status evidence with the invoice
Save the dated one-quarter and four-quarter calculations, the supplies included and excluded, associate review, special-category check, and any agency or adviser confirmation used to support the unregistered conclusion. Link that evidence to the invoice number or monthly review record without sending private working papers to every customer.
A customer may reasonably ask why no tax number appears. A short status statement is usually more useful than a broad tax opinion: the supplier is not registered and did not charge GST/HST. If procurement needs more, provide only the non-sensitive business evidence actually requested and retain the exchange.
Review the invoice after changes to ownership, associated entities, business activities, location, customer facts, or supply classification. A reusable template should preserve consistency, not freeze an old conclusion.
Stop before the next invoice when the status changes
Under CRA’s ordinary single-quarter rule, the supply that makes the total exceed C$30,000 can itself be the point when small-supplier status ends and tax must be charged if the supply is taxable at a positive rate. Under the four-quarter route, status ends later and the first subsequent taxable supply made in Canada helps set the effective date. Do not keep issuing the old no-tax invoice while the dates remain unresolved.
When a test crosses, a voluntary registration becomes effective, or a mandatory exception is discovered, pause the invoice, identify the effective date and supply treatment, complete the required registration step, and update the template only after those facts are confirmed. A valid zero-rated supply may still show 0%, but that is a classification decision—not the old unregistered-supplier reason.
Use the registration deadline calculator as a timeline aid, then confirm the effective date and first affected invoice with the relevant agency or a qualified adviser. Québec businesses should review both the GST and QST files.
What to do now
- 01
Confirm that the supplier is not registered and is not currently required to register under either ordinary threshold test or a special rule.
- 02
Identify the actual reason no tax is charged instead of assuming the supply is exempt or zero-rated.
- 03
Complete the ordinary invoice facts and add the precise unregistered-supplier note that matches the confirmed files.
- 04
Leave GST/HST, QST, BN, NEQ, and personal identifiers out of fields where they do not belong.
- 05
Save the dated status calculation and supporting review with the invoice record.
- 06
Recheck before the next invoice when revenue, activities, associates, location, or registration status changes.
Get a fact-specific review when…
- Either C$30,000 test is close to or already above the ordinary limit.
- The supplier has voluntarily registered, applied to register, or received an effective date.
- Taxi, ride-sharing, admissions, real property, non-resident, platform, or another special rule may apply.
- The supply may be zero-rated, exempt, made outside Canada, or connected to a different province.
- The customer requires a tax number or says it will claim an input tax credit for this invoice.
- The business operates in Québec and both GST and QST files have not been confirmed.
Check the rule behind the guide.
Ordinary small-supplier status, the two C$30,000 tests, crossing supplies, effective dates, and registration timing.
Open official guidance Canada Revenue AgencySmall Suppliers — GST/HST Memorandum 2-2The treatment of unregistered small suppliers, worldwide taxable supplies, exclusions, and special situations.
Open official guidance Canada Revenue AgencyInput tax creditsThe documentary information a registrant needs to support an input tax credit when GST/HST is actually paid or payable.
Open official guidance Canada Revenue AgencyBusiness number and CRA program accountsThe distinction between a nine-digit business number and a GST/HST RT program account.
Open official guidance Revenu QuébecDetails Concerning Small SuppliersThe ordinary Québec small-supplier position, optional registration, and categories that need separate review.
Open official guidance Revenu QuébecPreparing invoicesQuébec invoice-document information used by registrant customers to support GST/QST credits and refunds.
Open official guidance