Section 158A of the Central Goods and Services Tax Act, 2017 provides a statutory framework for the consent-based sharing of information furnished by a registered person on the GST common portal with other systems notified by the Government.
The provision was introduced through the Finance Act, 2023 to enable GST data available on the common portal to be shared with specified external systems where the required consent is obtained. The GST Council explained that the provision was intended to support digital data sharing and initiatives such as easier credit assessment for businesses, while keeping consent at the centre of the mechanism.
Section 158A is particularly relevant for businesses because GST records contain valuable information about registration, returns, outward supplies, invoices and other transactions. The section establishes when such information may be shared and whose consent is required.
The provision currently contains three sub-sections. Section 158A(1) identifies the categories of information that may be shared. Section 158A(2) deals with obtaining consent from the supplier and, in specified cases, the recipient. Section 158A(3) provides protection to the Government and the common portal from liability arising from information shared under the section and clarifies that such sharing does not affect the liability to pay tax on the relevant supply or under the relevant return.
What Is Section 158A of the CGST Act?
Section 158A is titled “Consent based sharing of information furnished by taxable person.”
The section allows specified information furnished by a registered person to be shared by the common portal with other systems that are notified by the Government.
However, this sharing is subject to:
- recommendations of the GST Council;
- the consent requirements under Section 158A(2);
- the manner prescribed by the GST Rules; and
- the conditions prescribed under the law.
Therefore, Section 158A does not create a general permission to freely share all GST information with any third party.
The information can be shared only within the statutory framework established by Section 158A and the corresponding rules and notifications.
Why Was Section 158A Introduced?
The GST system is based heavily on electronic records.
Businesses provide information to the GST common portal through:
- registration applications;
- GST returns;
- outward supply details;
- invoices;
- e-way bill-related information; and
- other prescribed electronic records.
The GST Council recognised that this information could also be useful for other digital systems, particularly for facilitating access to finance and reducing information gaps between businesses and financial service providers.
The GST Council specifically discussed the potential use of GST data for flow-based lending and easier credit delivery to MSMEs. It noted that a consent-based data-sharing mechanism could allow GSTN data to be accessed through a standardised digital framework instead of requiring every lender to develop a separate process.
Thus, Section 158A creates a legal foundation for controlled and consent-based data sharing.
Section 158A(1) – Information That May Be Shared
Section 158A(1) begins with a non-obstante clause and allows specified details furnished by a registered person to be shared through the common portal with other systems notified by the Government.
The provision specifically covers three broad categories of information:
- Information furnished in the registration application or specified returns.
- Information uploaded for invoices, outward supplies and documents under the GST framework.
- Other details that may be prescribed.
The sharing is subject to the consent mechanism in Section 158A(2).
Information Under Section 158A(1)(a)
Section 158A(1)(a) covers particulars furnished by a registered person:
- in the application for registration under Section 25;
- in a return filed under Section 39; or
- in an annual return filed under Section 44.
Therefore, information provided through GST registration and specified returns can fall within the consent-based sharing mechanism.
For example, information contained in a taxpayer’s GST registration application or relevant return information may be shared with a notified system if the statutory consent conditions are satisfied.
Information Under Section 158A(1)(b)
Section 158A(1)(b) covers several types of information uploaded on the common portal, including:
- particulars uploaded for preparation of an invoice;
- details of outward supplies furnished under Section 37; and
- particulars uploaded for generation of documents under Section 68.
This is important because GST data is not limited to periodic tax returns.
The GST ecosystem also contains transaction-level information relating to invoices, outward supplies and documents associated with movement of goods.
Information Under Section 158A(1)(c)
Section 158A(1)(c) provides for such other details as may be prescribed.
This allows the statutory framework to accommodate additional categories of information through the prescribed rules.
It also means that the exact scope of information sharing is not determined solely by the wording of clauses (a) and (b); the Act allows additional categories to be prescribed subject to the requirements of the section.
What Is the “Common Portal”?
The common portal is the electronic GST platform through which taxpayers interact with the GST system.
Section 158A specifically places the information-sharing mechanism at the level of the common portal.
The common portal does not independently decide to share taxpayer information with any system merely because a third party requests it.
The sharing must operate through the legal framework of Section 158A, the applicable rules and the notifications issued for the relevant systems.
Section 158A(2) – Consent Is Central
Section 158A(2) deals with consent.
The Act requires consent for sharing information under Section 158A(1).
The person whose consent is required depends on the type of information involved.
The provision identifies:
- the supplier; and
- in specified circumstances, the recipient.
This is the central feature of Section 158A.
Consent of the Supplier
Section 158A(2)(a) provides that the consent of the supplier must be obtained for details furnished under clauses (a), (b) and (c) of Section 158A(1).
Therefore, where information furnished by the registered person is proposed to be shared under the provision, the supplier’s consent is required.
The consent must be obtained in the form and manner prescribed.
Consent of the Recipient
Section 158A(2)(b) deals with the recipient.
For information covered by Section 158A(1)(b), the recipient’s consent is also relevant.
The provision further deals with information under Section 158A(1)(c) where such information includes the identity information of the recipient.
Therefore, the law recognises that certain shared information may contain information relating to both sides of a transaction.
In such cases, the consent requirements extend beyond the supplier.
Supplier and Recipient Consent – Simple Example
Suppose Supplier A issues an invoice to Recipient B.
Supplier A’s GST records contain information relating to the transaction.
If that information is proposed to be shared with a notified system under Section 158A, the supplier’s consent is required.
Where the information falls within the categories for which recipient consent is also required, Recipient B’s consent must also be obtained.
The exact procedure for obtaining and communicating consent is governed by the applicable rules.
Rule 163 – Consent Based Sharing of Information
Section 158A is implemented through Rule 163 of the CGST Rules, 2017.
The GST Council’s published material describes Rule 163 as the rule dealing with consent-based sharing of information. The rule provides the procedural framework for a registered person who opts to share specified GST information with a requesting system.
The rule has been linked to information such as:
- FORM GST REG-01;
- FORM GSTR-3B for specified tax periods; and
- FORM GSTR-1, including amendments through FORM GSTR-1A, for specified tax periods and specified invoice, debit note and credit note information.
The requesting system must obtain the registered person’s consent and communicate the consent and relevant details to the common portal.
What Is a Requesting System?
Rule 163 refers to the system seeking the information as the “requesting system.”
A requesting system is a system that has been notified under the Section 158A framework and seeks information from the common portal after obtaining the required consent.
The common portal then communicates the relevant information to that system in accordance with the prescribed procedure.
Therefore, a private organisation cannot simply demand GST data from the GST portal and claim a right to receive it under Section 158A.
The system must fall within the statutory notification framework.
Account Aggregators Under Section 158A
One of the first important implementations of Section 158A was the notification of Account Aggregators.
Notification No. 33/2023-Central Tax dated 31 July 2023 notified “Account Aggregator” as a system with which information could be shared by the common portal under Section 158A. The notification was specified to come into force from 1 October 2023.
This implementation was particularly relevant to businesses seeking credit because GST information can help financial institutions understand the business’s transaction and compliance profile.
The GST Council’s communication specifically stated that consent-based sharing through Account Aggregators could help MSMEs obtain credit or business loans based on their GST registration information.
Public Tech Platform for Frictionless Credit
Another important development was the notification of the Public Tech Platform for Frictionless Credit.
Notification No. 06/2024-Central Tax dated 22 February 2024 notified the Public Tech Platform for Frictionless Credit as a system with which information may be shared by the common portal based on consent under Section 158A.
The GST Council described this platform as an enterprise-grade open architecture information technology platform conceptualised by the Reserve Bank of India and developed by its wholly owned subsidiary, Reserve Bank Innovation Hub, for facilitating access to information from multiple data sources through standardised digital interfaces.
This demonstrates how Section 158A can connect GST information with broader digital credit infrastructure, subject to consent and the prescribed framework.
Section 158A and MSME Credit
One of the practical objectives associated with Section 158A is reducing the information gap between businesses and lenders.
Traditionally, a lender assessing an MSME may need various documents to understand:
- sales;
- turnover;
- business activity;
- invoices;
- tax compliance;
- filing history; and
- transaction activity.
GST data can provide important information about a registered business.
A consent-based digital mechanism can allow relevant information to be shared through authorised systems instead of requiring the taxpayer to repeatedly submit the same information manually.
The GST Council specifically discussed the role of GSTN data in flow-based lending and efficient credit delivery to MSMEs.
Section 158A Does Not Mean Automatic Data Sharing
A very important point is that Section 158A does not mean that all GST information is automatically shared with banks, lenders or private platforms.
The provision is based on:
- a notified system;
- prescribed information;
- the required consent;
- the manner prescribed under the rules; and
- applicable conditions.
The GST Council’s implementation framework specifically describes consent as the basis for sharing.
Therefore, taxpayers should distinguish between:
GST information stored on the GST portal
and
GST information voluntarily shared through the Section 158A mechanism with a notified system.
Section 158A(3) – Protection From Liability
Section 158A(3) provides an important protection.
It states that, notwithstanding anything contained in any law for the time being in force:
- no action shall lie against the Government or the common portal in respect of any liability arising as a consequence of information shared under Section 158A; and
- there shall be no impact on the liability to pay tax on the relevant supply or according to the relevant return.
This provision separates data sharing from tax liability.
Sharing information with another system does not itself change the GST liability arising from the underlying supply or return.
Data Sharing Does Not Change GST Liability
Suppose a registered person consents to sharing GST information with an authorised credit platform.
The information may be used by the requesting system for its permitted purpose.
However, the act of sharing does not:
- create a new GST liability;
- reduce an existing GST liability;
- change the tax rate;
- alter the taxable value; or
- amend the taxpayer’s return.
The GST liability continues to be determined under the applicable GST provisions.
Section 158A(3) expressly protects this principle.
Section 158A and Taxpayer Privacy
Section 158A is significant from a data-governance perspective because GST information can contain commercially sensitive information.
For example, GST records may reveal:
- business turnover;
- customers;
- suppliers;
- invoices;
- transaction values;
- product or service information; and
- filing information.
The section therefore does not simply authorise unrestricted disclosure.
Instead, it establishes a consent-based statutory framework under which information may be shared with systems notified by the Government.
The GST Council’s implementation of Rule 163 specifically focuses on obtaining consent before the common portal communicates the relevant information to the requesting system.
Section 158A and Section 158
Section 158 deals generally with the disclosure of information by a public servant.
Section 158A is different.
Section 158
Section 158 establishes restrictions and exceptions concerning disclosure of information contained in statements, returns, accounts, documents and records under the GST law.
Section 158A
Section 158A creates a specific statutory mechanism for consent-based sharing of specified information furnished by a registered person with notified systems.
The two provisions therefore address different aspects of GST information management.
Section 158A also begins with a non-obstante clause, expressly stating that its mechanism operates notwithstanding Sections 133, 152 and 158, subject to the conditions contained in Section 158A itself.
Section 158A and Section 152
Section 152 contains restrictions concerning information collected under specified provisions of the CGST Act.
Section 158A specifically begins with the words “Notwithstanding anything contained in sections 133, 152 and 158”.
This means that the legislature created a specific statutory mechanism for the information-sharing arrangement covered by Section 158A.
However, this does not remove the other conditions of Section 158A.
Consent, notified systems and prescribed procedures remain central to the operation of the provision.
Section 158A and Section 133
Section 133 deals with liability of officers and certain other persons in relation to unauthorised disclosure of information.
Section 158A, on the other hand, provides a specific lawful route for sharing specified taxpayer information with notified systems where the required consent and conditions are satisfied.
Thus, authorised sharing under Section 158A should be distinguished from unauthorised disclosure of taxpayer information.
What Information Can Be Shared Under Section 158A?
The statutory categories can be broadly understood as follows:
| Category | Information covered |
|---|---|
| Registration | Particulars furnished in the registration application under Section 25 |
| Returns | Particulars furnished in returns under Sections 39 and 44 |
| Invoice information | Particulars uploaded for preparation of invoices |
| Outward supplies | Details furnished under Section 37 |
| Movement-related documents | Particulars uploaded for generation of documents under Section 68 |
| Other prescribed information | Additional details prescribed under the rules |
The actual information shared depends on the relevant notified system, the applicable rules and the consent provided.
How Does Consent-Based Sharing Work?
The basic process can be understood in the following steps:
Step 1 – A Notified System Requests Information
A system notified under Section 158A seeks specified GST information.
Step 2 – Consent Is Obtained
The required consent is obtained from the registered person and, where required, the relevant recipient.
Step 3 – Consent Details Are Communicated
Under Rule 163, the requesting system communicates the consent and relevant details to the common portal.
Step 4 – Common Portal Shares Information
The common portal communicates the specified information to the requesting system according to the prescribed process.
Step 5 – GST Liability Remains Unchanged
The sharing itself does not alter the taxpayer’s GST liability.
👉 Read More → Section 158A – Consent based sharing of information furnished by taxable person
Example – Business Loan Application
Suppose an MSME has been filing GST returns regularly and wants to obtain a business loan.
The lender or an authorised digital credit system may use a notified platform that operates within the Section 158A framework.
The MSME gives the required consent.
The common portal can then share the permitted GST information with the requesting system in accordance with the prescribed process.
The lender can use the authorised information as part of its credit assessment, while the taxpayer’s GST liability remains governed by the GST law.
The GST Council specifically identified easier credit delivery to MSMEs as an important potential benefit of this data-sharing framework.
Example – Invoice Information
Suppose Supplier A issues invoices to several customers.
Certain invoice information is available through the GST system.
If the relevant information falls within the Section 158A framework and the applicable consent requirements are satisfied, it may be shared with a notified requesting system.
Where the recipient’s identity information is involved and the statutory recipient-consent requirement applies, the recipient’s consent must also be addressed.
Example – GSTR-1 Information
Suppose a registered person wants specified GSTR-1 information to be shared with an authorised system.
The relevant information may fall within the Rule 163 framework.
The requesting system must obtain the registered person’s consent and communicate the required details to the common portal.
The GST Council’s Rule 163 material also recognises GSTR-1 information as amended through GSTR-1A, where applicable.
Section 158A and Account Aggregator – Practical Significance
The notification of Account Aggregators gave practical significance to Section 158A.
An Account Aggregator framework can enable a customer to consent to the sharing of financial information between participating entities.
In the GST context, the Government notified Account Aggregators as systems with which specified information could be shared through the common portal under Section 158A.
For businesses, this can reduce the need to manually provide the same GST records to multiple financial service providers when applying for credit, subject to the applicable consent and platform procedures.
Section 158A and Digital Lending
Section 158A can support digital lending by making verified GST information available through authorised digital systems.
A lender may use business information such as:
- turnover information;
- return information;
- invoice-related data;
- registration details; and
- other permitted GST information
to assist in assessing the financial profile of a business.
The GST Council has linked the mechanism with efforts to simplify credit delivery and reduce information asymmetry for MSMEs.
Is Consent Required Every Time?
The statutory framework requires consent in the manner prescribed for sharing under Section 158A.
The detailed operational procedure is governed by Rule 163 and the applicable notified-system framework.
Therefore, businesses should not assume that a third party can access their GST data merely because the business is GST-registered.
The specific consent and data-sharing procedure applicable to the requesting system should be checked before sharing information.
Can the Recipient’s Consent Be Required?
Yes.
Section 158A(2)(b) expressly requires the recipient’s consent for information covered by Section 158A(1)(b), and for information under Section 158A(1)(c) where that information includes the identity information of the recipient.
The detailed Rule 163 procedure also addresses recipient consent in connection with invoice, credit note and debit note information.
The GST Council’s published draft and implementation material explain that, in the relevant cases, the registered person must obtain the consent of recipients before giving consent for sharing such information.
Section 158A and GSTR-1A
The implementation framework has evolved with GST return changes.
The GST Council’s published material on Rule 163 refers to FORM GSTR-1 as amended in FORM GSTR-1A, if any, for specified tax periods and invoice-related information.
Therefore, when discussing current consent-based data sharing, it is appropriate to recognise GSTR-1A where it forms part of the applicable Rule 163 framework.
Is GST Data Shared With Every Bank?
No.
Section 158A does not establish unrestricted access for every bank or lender.
The information-sharing mechanism operates through systems notified by the Government and requires the applicable consent and prescribed procedure.
For example, Account Aggregators were notified in 2023, and the Public Tech Platform for Frictionless Credit was notified in 2024.
The existence of Section 158A therefore should not be interpreted as a general right of every financial institution to directly access the GST portal.
Does Sharing GST Data Automatically Approve a Loan?
No.
Section 158A only creates the legal mechanism for sharing specified GST information with a notified system based on consent.
Whether a loan or credit facility is approved is a separate decision of the relevant financial institution or credit provider.
GST data may form part of the information considered during credit assessment, but Section 158A does not create any statutory right to obtain a loan.
Does Section 158A Change a Taxpayer’s GST Return?
No.
Sharing information under Section 158A does not amend the taxpayer’s return.
The taxpayer’s return remains governed by the relevant provisions of the GST law.
Section 158A(3) specifically states that the sharing of information does not affect the liability to pay tax on the relevant supply or according to the relevant return.
Important Compliance Points for Businesses
Businesses using the Section 158A mechanism should keep the following points in mind:
1. Check the Requesting System
Verify that the system requesting GST information is covered by the applicable notification.
2. Understand the Information Being Shared
Review what information is requested and the relevant tax periods.
3. Check Consent Requirements
Determine whether supplier consent alone is sufficient or whether recipient consent is also required.
4. Use Authorised Channels
Consent should be provided through the prescribed mechanism rather than through informal sharing of GST credentials.
5. Do Not Share GST Login Credentials
A taxpayer should never provide GST portal username, password or authentication credentials merely because a third party wants GST information.
The Section 158A mechanism is designed around authorised consent-based data sharing.
6. Maintain Records
Businesses should maintain appropriate records of the consent and information-sharing process where relevant.
7. Review the Information
Before providing consent, the business should understand what GST information will be shared with the requesting system.
Section 158A – Difference From Ordinary Data Sharing
| Basis | Section 158A sharing | Ordinary third-party request |
|---|---|---|
| Legal basis | CGST Act and prescribed rules | May not have a GST statutory basis |
| System | Government-notified system | Any third party cannot automatically qualify |
| Consent | Required as prescribed | Depends on the separate legal arrangement |
| GST portal role | Common portal shares permitted information | No automatic portal access |
| Information | Specified information under Section 158A framework | Cannot automatically include all GST data |
| Tax liability | Remains unchanged | Depends on the underlying transaction and law |
Section 158A – Key Benefits
The consent-based data-sharing framework can provide several practical benefits.
Easier Credit Assessment
GST records can provide useful business information to lenders.
Reduced Documentation
Businesses may not need to repeatedly provide the same GST records manually when using an authorised digital system.
Faster Digital Processes
Standardised data sharing can support automated credit and financial workflows.
Better Information Availability
Lenders and other authorised systems can potentially receive verified information directly through the digital ecosystem.
Greater Control Through Consent
The taxpayer’s consent is an important part of the statutory mechanism.
The GST Council specifically associated Section 158A with reducing information asymmetry and facilitating more efficient credit delivery to MSMEs.
Limitations of Section 158A
Section 158A also has important limitations.
It does not:
- allow unrestricted sharing of GST data;
- give every private organisation access to the GST portal;
- automatically approve loans;
- change GST liability;
- amend GST returns;
- replace GST compliance obligations; or
- eliminate the need for consent.
The information-sharing process remains subject to the Act, rules, notifications and applicable conditions.
Relationship Between Section 158A and GSTN
GSTN operates the technology infrastructure associated with the GST common portal.
Section 158A provides the statutory framework under which specified information available through the common portal can be shared with notified systems after the applicable consent requirements are satisfied.
The GST Council’s discussions specifically referred to GSTN’s role in facilitating the digital data-sharing architecture and integrating GST information with authorised platforms.
Section 158A and the Digital GST Ecosystem
Section 158A represents an important development in the digital architecture of GST.
The GST system already generates substantial transactional information through:
- registration;
- returns;
- invoices;
- outward supplies;
- e-way bills; and
- other electronic records.
Section 158A provides a controlled mechanism for using some of this information beyond the immediate tax administration framework, where the Government has notified the relevant system and the required consent has been obtained.
This can support wider digital services while retaining a statutory consent requirement.
Key Takeaways of Section 158A
Section 158A can be summarised through the following points:
- Section 158A deals with consent-based sharing of information furnished by a registered person.
- It was inserted through the Finance Act, 2023.
- It operates through the GST common portal.
- Information can be shared with systems notified by the Government.
- Such sharing is subject to recommendations of the GST Council.
- The provision covers specified registration information.
- It covers specified information furnished in returns under Sections 39 and 44.
- It covers certain invoice-related information.
- It covers outward supply information furnished under Section 37.
- It covers certain information uploaded for generation of documents under Section 68.
- Other information may also be prescribed.
- Supplier consent is required under Section 158A(2)(a).
- Recipient consent is required in the circumstances specified under Section 158A(2)(b).
- Rule 163 provides the procedural framework for consent-based information sharing.
- Account Aggregators were notified under Notification No. 33/2023-Central Tax.
- The Account Aggregator notification came into force from 1 October 2023.
- The Public Tech Platform for Frictionless Credit was notified under Notification No. 06/2024-Central Tax.
- The mechanism can support digital credit assessment and lending.
- The GST Council has specifically discussed the potential benefits for MSMEs.
- Section 158A does not provide unrestricted access to GST data.
- Section 158A does not automatically approve loans or credit facilities.
- Information sharing does not alter the taxpayer’s GST liability.
- Section 158A(3) provides protection to the Government and common portal against liability arising from information shared under the section.
- Businesses should understand what information is being shared and through which notified system before providing consent.
- Section 158A should be read together with Rule 163 and the applicable notifications governing notified systems.
Conclusion
Section 158A of the CGST Act creates a statutory framework for the consent-based sharing of specified GST information with notified systems.
The provision is important because the GST common portal contains valuable business information relating to registration, returns, invoices, outward supplies and other transactions. Instead of allowing unrestricted access to this information, Section 158A establishes a controlled mechanism under which specified information can be shared when the applicable consent and procedural requirements are satisfied.
👉 Read More → Section 158 – Disclosure of information by a public servant
The provision covers information furnished through registration applications and specified returns, as well as certain invoice, outward supply and document-related information. Supplier consent is required, while recipient consent is additionally required in the circumstances specified by Section 158A(2). Rule 163 provides the operational procedure for consent-based sharing.
The implementation of Section 158A has included the notification of Account Aggregators under Notification No. 33/2023-Central Tax and the Public Tech Platform for Frictionless Credit under Notification No. 06/2024-Central Tax. These developments demonstrate the practical role of the provision in connecting GST data with authorised digital financial and credit infrastructure.
For businesses, one of the major potential benefits is easier digital credit assessment. GST Council discussions specifically identified the reduction of information asymmetry and improved credit delivery to MSMEs as important objectives associated with consent-based GST data sharing.
At the same time, Section 158A does not mean that every bank, lender or private organisation can access a taxpayer’s GST data. The system must fall within the notified framework, and the required consent and prescribed procedure must be followed.
Finally, Section 158A(3) makes an important distinction between data sharing and tax liability. Sharing information through the statutory mechanism does not change the taxpayer’s liability to pay GST on the relevant supply or according to the relevant return.
For taxpayers, the practical lesson is to understand the information being requested, verify the requesting system, review the applicable consent requirements and use only the authorised digital process. Section 158A therefore forms an important part of the evolving digital GST ecosystem, particularly in areas such as consent-based financial data sharing and business credit assessment.
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