GST

Foreign Apps Using Freemium Models Need OIDAR Registration

Foreign Apps Using Freemium Models Need OIDAR Registration

Introduction

Freemium models are a popular way for foreign apps to quickly attract a large user base in India. However, when these apps provide automated digital services, they may fall under OIDAR rules in India. Many foreign founders assume that offering free plans means GST compliance is not required. In practice, this assumption often leads to issues. When users are located in India and the core service is digital, the law treats the activity as a taxable supply. This makes it essential for foreign apps to understand how freemium models interact with OIDAR registration requirements.

 

In Brief

  • Freemium models are still treated as a digital supply if paid features, subscriptions, or upgrades are offered.
  • OIDAR registration becomes mandatory even if there is only one paying user located in India.
  • Foreign apps must collect GST, file GSTR-5A every month, and maintain accurate transaction reports.
  • Non-compliance can result in GST notices, penalties, and operational restrictions for foreign apps.
  • Ebizfiling supports global founders at every stage of OIDAR registration and ongoing compliance.

What OIDAR Means and Why It Covers Freemium Models ?

OIDAR stands for Online Information and Database Access or Retrieval. Under Indian GST rules, it covers digital services delivered online with minimal human involvement.

Examples of OIDAR services include:

  • SaaS tools such as CRM and project management apps

  • Cloud based storage, email automation, workflow tools

  • Digital content, paid filters, templates, and media libraries

  • Online learning platforms that deliver automated courses

  • Mobile apps that offer digital upgrades or in app purchases

When a foreign app provides such services to Indian users, OIDAR rules apply. This is true even if the base service is free. OIDAR is determined by the nature of the service, not by its pricing structure.

GST Council Flyer on OIDAR (www.gst.gov.in)

Why Freemium Models Still Need OIDAR Registration ?

Freemium models create a common misunderstanding. Founders often believe that if the basic service is free, GST is not involved. In practice, this is where most compliance issues begin.

1. Paid upgrades convert free users into taxable recipients  

A freemium app becomes taxable the moment an Indian user pays for any premium feature. One upgrade is enough for the service to fall under OIDAR rules.

2. No turnover threshold for foreign apps  

Foreign apps do not get a GST threshold. OIDAR registration becomes compulsory from the first rupee earned from an Indian user.

3. User location decides the tax  

If the user is in India, the place of supply is India. Server location or payment gateway does not matter. Paid Indian users require IGST collection and GSTR 5A filing.

4. 2023 changes widened OIDAR coverage  

After the 2023 clarification, even partly automated or hybrid digital services can fall under OIDAR. Most freemium tools now fit this definition.

5. Payment channel does not remove liability  

Whether payment comes through Apple, Google Play, Stripe, or any foreign gateway, GST still applies if the subscriber is in India.

What are the Compliance Requirements for Foreign Apps with Freemium Models ?

Once OIDAR rules apply, the following obligations become mandatory.

 1. GST Registration via Form REG 10   

Foreign apps must register under OIDAR rules using Form REG 10 on www.gst.gov.in.If the company has no presence in India, it must appoint an authorized representative in India.

 2. Monthly Filing of GSTR 5A   

Every month, foreign OIDAR providers must file GSTR 5A with details of:

  • Indian users

  • Subscriptions

  • Value of taxable supply

  • IGST collected and paid

Even if there are no new sales in a month, a nil return is required.

 3. GST Collection Obligations   

  • For B2C: Indian users, the foreign app must collect and pay IGST.

  • For B2B: Users with a valid GSTIN, tax is paid under reverse charge by the Indian business.

 4. No Input Tax Credit Allowed   

OIDAR registrants cannot claim ITC, so taxes paid become an expense.

 5. Record Keeping Requirements   

Foreign apps must maintain details such as:

  • User billing addresses

  • IP logs

  • Invoices

  • Payment method details

  • Subscription history

These records support compliance during audits or GST notices.

What Happens When Foreign Apps Ignore OIDAR ?

Based on compliance patterns that Ebizfiling has observed in the last few years, the most common risks include:

  • Tax authorities issue notices for non-registration after detecting India-based payments.

  • Late filing penalties accumulate when GSTR 5A is missing.

  • IGST demands include interest from the start of supply.

  • Apps risk suspension of paid features for Indian users.

  • Refunds or account restrictions may occur on digital marketplaces.

For fast-growing foreign apps, these issues interrupt business momentum and reduce trust among Indian users.

How Ebizfiling Helps Foreign Apps Stay OIDAR Compliant ?

  • We review your freemium model and confirm whether OIDAR applies.

  • We help register your app under OIDAR using Form REG 10.

  • We assist in appointing an authorized representative in India if required.

  • We manage GSTR 5A filing every month and ensure consistency.

  • We help maintain compliance records such as invoices and user data.

  • We support you in responding to any GST notices from authorities.

Conclusion   

Freemium models are smart for user acquisition, but foreign apps must understand that Indian GST rules look at the nature of the service, not the pricing tier. Once paid features reach users in India, OIDAR registration becomes essential. To avoid compliance risks, foreign founders should treat India as an active tax jurisdiction and prepare accordingly. Ebizfiling supports them through straightforward and reliable compliance services.

Suggested Read :

OIDAR for Fintech Tools

OIDAR Compliance Roadmap for Foreign Startups 

GST Registration for OIDAR Service Providers in India

Why User Location Matters for OIDAR India?

FAQs

1. Does a free tier alone create OIDAR liability?

No. If you never charge an Indian user and do not monetise through advertisements, GST may not apply. However, once paid features, subscriptions, or upgrades are introduced, OIDAR rules become applicable.

2. What if only one Indian user buys a premium upgrade?

OIDAR registration becomes mandatory even if only one Indian user makes a payment. Foreign apps do not get any minimum turnover exemption under OIDAR provisions.

3. Does Google Play or the Apple App Store handle GST on my behalf?

In some cases, platforms may handle GST collection, but the legal responsibility remains with the foreign app if the platform is not treated as the supplier. Your commercial and contractual model must be reviewed carefully.

4. What is the GST rate applicable to OIDAR services?

An 18 percent IGST rate is applicable to most OIDAR and digital services consumed by users located in India.

5. How is the user’s location identified for OIDAR purposes?

User location is identified using indicators such as billing address, IP address, bank or card details, and device or SIM information to confirm that the user is located in India.

6. What happens if OIDAR registration is ignored?

Ignoring OIDAR registration may lead to GST notices for short payment of tax, along with interest and penalties imposed by the tax authorities.

7. Can Input Tax Credit be claimed after OIDAR registration?

No. OIDAR registrants are not eligible to claim Input Tax Credit under Indian GST laws.

8. Do freemium apps with in-app purchases require OIDAR registration?

Yes. In-app purchases are treated as a digital supply to Indian users, which makes OIDAR registration mandatory for foreign apps.

9. Is reverse charge applicable when Indian business users purchase the service?

Yes. If an Indian business entity with a valid GSTIN purchases the service, GST is paid by the Indian buyer under the reverse charge mechanism.

10. How does Ebizfiling assist in OIDAR compliance?

Ebizfiling manages OIDAR registration, monthly GSTR-5A filings, record maintenance, and responses to GST notices, helping foreign app owners remain fully compliant.

Steffy A

Steffy Alvin is a Content Writer at Ebizfiling who turned her passion for writing into a full-time career. She holds a Bachelor's degree in English Literature from MS University, Baroda, and later pursued her post-graduation in Journalism and Mass Communication from the same university. With a strong command of both content writing and copywriting, Steffy enjoys creating simple, clear, and engaging content that helps readers understand complex topics with ease. Outside of work, Steffy spends her time journaling, writing poetry, capturing photos, and shooting videos. She is also an active digital creator.

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