Electronic invoice (e-invoice) compliance in Vietnam works as a near-real-time tax control mechanism rather than a conventional post-transaction billing routine. Under Decree 254/2026/ND-CP, an enterprise must register to use e-invoices before issuing its first one and must issue an e-invoice on every sale of goods or services. It is one part of tax administration and compliance within the wider Vietnam corporate tax system.
Unlike Western self-assessment regimes where businesses generate internal commercial invoices and submit aggregate summaries retrospectively, Vietnam requires invoices to be issued electronically, one by one. Coded e-invoices receive a code from the Tax Department of the Ministry of Finance before they reach the buyer; un-coded e-invoices are signed by the seller, sent to the buyer and transmitted to the tax authority no later than the next business day. A newly incorporated enterprise cannot lawfully issue invoices until its registration is accepted, so registration is the first operational checkpoint after licensing.
1. Statutory Transition Timeline for E-Invoicing
Foreign investors must distinguish historical rules from the controlling legal framework to apply the right rules to each invoice:
| Regulatory Parameter | Legacy Framework (Through June 30, 2026) | Governing Standard (Effective July 1, 2026) | Practical Impact on FDI Enterprises |
|---|---|---|---|
| Controlling Decree | Decree 123/2020/ND-CP and Decree 70/2025/ND-CP | Decree 254/2026/ND-CP (issued June 30, 2026) | Fully replaces Decrees 123 and 70 |
| Governing Law | Law on Tax Administration No. 38/2019/QH14 | Law on Tax Administration No. 108/2025/QH15 | E-invoice data is managed centrally and connected and shared with relevant agencies |
| Implementing Circular | Circular 32/2025/TT-BTC (which replaced Circular 78/2021/TT-BTC from 01/06/2025) | Circular 91/2026/TT-BTC | Updates XML data format rules |
| Sanction Framework | Decree 125/2020/ND-CP | Decree 125/2020/ND-CP (amended by Decree 310/2025/ND-CP) | Tiered penalty structure based on cumulative invoice volume; top tier at VND 70 million. Decree 310/2025 applies from 16/01/2026; Decree 125/2020 remains in force after 01/07/2026 (Decree 252/2026/ND-CP) |
E-invoices already issued under Decree 123/2020/ND-CP, Decree 70/2025/ND-CP or Circular 32/2025/TT-BTC that contain errors are corrected by adjustment or replacement as prescribed by the new Circular.
2. E-Invoice Registration and Technical Setup
Completing e-invoice registration represents the mandatory final prerequisite following Enterprise Registration Certificate (ERC) issuance in the Vietnam company setup sequence.
2.1. The 4-Step Registration Process
Most foreign-invested enterprises delegate e-invoice registration to licensed corporate tax compliance services to configure eTax portal credentials and certified T-VAN connections:
- Procure Digital Certificate: Obtain a licensed digital signature USB token or server-based HSM certificate from licensed certification authorities (VNPT, Viettel, FPT).
- Select Certified T-VAN Software: Engage an e-invoice service provider (often still called a T-VAN vendor) that meets the technical conditions of Circular 91, and offers bilingual English-Vietnamese reporting interfaces.
- Submit Registration Dossier (Form 01/ĐKTĐ-HĐĐT): Digitally sign and submit the electronic usage registration dossier through a licensed e-invoice service provider.
- Receive Tax Authority Approval Notice: After an automated cross-check, the tax office issues Form 01/TB-ĐKĐT accepting or rejecting the registration, at the latest on the next business day; a clarification request gives the taxpayer three business days to respond. Coded e-invoices (hóa đơn có mã) are the default; un-coded e-invoices (hóa đơn không có mã) are limited to the sectors listed in Article 6 of Decree 254 and to organizations that meet the IT infrastructure and software conditions of that point, except high-risk cases. Enterprises selling directly to consumers (retail, restaurants, hotels, passenger transport) issue e-invoices from cash registers connected to the tax authority, unless they have registered for coded or un-coded e-invoices.
The tax authority also matches the legal representative’s identity data, including biometrics, against national electronic identification records.
2.2. Mandatory Digital Infrastructure and Governance
Maintaining compliant invoicing operations requires three fundamental technical tools involving modest financial outlay but statutory legal significance:
| Statutory Tool | Operational Role | Estimated Cost | Governance and Risk Control |
|---|---|---|---|
| Digital Signature Token | Authenticates e-invoices, tax returns, and customs filings | VND 500,000 - 1,500,000/year | Equivalent to the corporate seal; restrict custody to the appointed Chief Accountant |
| T-VAN Invoice Software | Generates XML data packets, signs, and transmits records to tax portals | VND 200,000 - 500,000/month | Certified provider ensuring automated cloud archive and backup security |
| Electronic Tax Account (eTax) | Portal for formal tax notices, returns, and invoice reconciliation | Free (Tax Department portal) | Implement strict role-based access separating administration and billing staff |
Enterprises generating high daily invoice volumes (logistics, consumer goods distribution, e-commerce) should deploy Hardware Security Modules (HSM) integrated into ERP infrastructure, enabling concurrent automated batch signing without circulating physical USB tokens.
E-commerce companies issue an invoice for each order when goods are transferred to the buyer, including COD orders and orders where the customer does not ask for an invoice. A platform withholds tax only for household businesses, individual businesses and foreign suppliers, so a company selling on a platform still issues its own e-invoices. See our guide on tax for e-commerce companies in Vietnam.
3. Selecting Invoice Categories by Business Model
Using an invoice type that does not match the business model can lead to a rejected invoice and puts the purchaser’s VAT credit at risk.
3.1. Phased Classification Across Commercial Models
Foreign-invested companies adopt specific invoice templates aligned with their operational scope; non-resident offshore digital vendors remit taxes through the foreign supplier portal under the Foreign Contractor Tax (FCT) framework:
| Business Model | Primary Tax Invoice | Accompanying Transit Document | Statutory Issuance Trigger |
|---|---|---|---|
| Services and Advisory | VAT Invoice (template symbol 1) | Signed Acceptance Minutes | Upon service completion or advance payment receipt |
| Trading and Wholesale | VAT Invoice (template symbol 1) | Electronic Internal Transfer Note | Upon physical delivery and custody transfer |
| Manufacturing Export | Electronic commercial invoice (symbol 7), or VAT or sales e-invoice if its data-transmission conditions are not met | Customs Export Declaration | Set by the seller, no later than the next business day after customs clearance |
| Export Processing (EPE) | VAT Invoice (symbol 1) under the credit method; sales invoice (symbol 2) under the direct method | Electronic Internal Transfer Note | Upon domestic handover of liquidated goods |
Template symbols follow Appendix I to Circular 91 (1 = VAT invoice, 2 = sales invoice, 7 = commercial invoice); an export processing enterprise filing VAT under the credit method uses the VAT invoice.
4. Statutory Issuance Rules and Timing Discipline
Under Article 9 of Decree 254, invoice issuance timing follows the economic handover milestones:
- Sale of Goods: The exact moment legal ownership or usage rights transfer to the purchaser, regardless of whether payment has been collected.
- Provision of Services: The date service delivery is formally concluded. When advance consideration is collected prior to or during service execution, the invoice date is the exact payment collection date (excluding deposits under the Civil Code that secure performance of the service contract).
- Batch Invoicing: Invoices follow the handover milestones above. Issuing after a data reconciliation, for example by the 7th of the following month, is allowed only in the cases listed in Article 9 of the Decree.
- Cash-Register Invoices: Retail, dining and similar consumer businesses that issue invoices from cash registers send the invoice data to the tax authority at the end of each day (Article 15 of Decree 254).
5. Managing Invoicing Errors: Adjustment vs. Replacement
Circular 91 (Article 10) sets out how to correct defective invoices. It has no separate invoice “cancellation” route:
- Errors in Buyer Name or Address (Tax Code and Amounts Correct): The seller transmits explanatory notification Form 04/SS-HĐĐT to the tax office and notifies the purchaser. Reissuing a new invoice is not required.
- Errors in Tax Code, Monetary Sums, Tax Rates, or Specifications: The seller chooses one of two statutory remedies, after the seller and an organizational buyer sign a written agreement stating the error:
- Adjustment E-Invoice: Details positive or negative balance corrections linked directly to the original invoice serial, date, and number.
- Replacement E-Invoice: Fully supersedes the defective document, explicitly stating that it replaces invoice number X dated Y.
Enterprises must preserve original XML invoice data, digital signatures, and transmission receipts for the period required by accounting law.
6. Statutory Penalties and Risk Allocation (Buyer vs. Seller)
Corporate leadership must clearly distinguish between administrative sanctions imposed on the seller and the statutory deduction rights belonging to the buyer when untimely invoicing occurs.
6.1. Tiered Penalty Scale Under Decree 310/2025/ND-CP
Decree 310/2025/ND-CP amends Article 24 of Decree 125/2020/ND-CP, applying a progressive volume-based schedule per administrative violation case (fines for organizations; individuals pay half):
| Violated Invoice Volume Tier | Penalty for Sales of Goods and Services | Penalty for Promotional, Gift, and Internal Use | Statutory Basis |
|---|---|---|---|
| 01 invoice | VND 500,000 - 1,500,000 | Formal Warning (no monetary fine) | Decree 125/2020 amended by Decree 310/2025 |
| 02 to < 10 invoices | VND 2,000,000 - 5,000,000 | VND 500,000 - 1,500,000 | Decree 125/2020 amended by Decree 310/2025 |
| 10 to < 20 invoices | VND 5,000,000 - 15,000,000 | VND 2,000,000 - 5,000,000 (applies 10 - < 50) | Decree 125/2020 amended by Decree 310/2025 |
| 20 to < 50 invoices | VND 15,000,000 - 30,000,000 | VND 2,000,000 - 5,000,000 | Decree 125/2020 amended by Decree 310/2025 |
| 50 to < 100 invoices | VND 30,000,000 - 50,000,000 | VND 5,000,000 - 15,000,000 | Decree 125/2020 amended by Decree 310/2025 |
| 100+ invoices (highest tier) | VND 50,000,000 - 70,000,000 | VND 15,000,000 - 30,000,000 | Decree 125/2020 amended by Decree 310/2025 |
Not issuing an invoice at all is a separate violation with higher fines: from VND 1-2 million for one invoice up to VND 60-80 million for 50 invoices or more on sales of goods and services (Article 24.3 of Decree 125/2020/ND-CP, as amended by Decree 310/2025/ND-CP).
Where several untimely invoices are sanctioned in the same administrative violation case and are still within the limitation period, the seller receives one fine, set by the bracket for the total number of untimely invoices (Decree 125/2020/ND-CP, as amended by Decree 310/2025/ND-CP). If delayed issuance results in delayed tax liabilities, the seller is subject to tax reassessment and daily late payment interest of 0.03%.
6.2. Protection of Buyer Tax Deductions and VAT Credits
Fines for late issuance fall on the seller. The buyer’s input VAT credit and CIT deduction depend on three conditions under Law on VAT No. 48/2024/QH15, Decree 181/2025/ND-CP and Decree 320/2025/ND-CP:
| Condition | What it requires |
|---|---|
| Authentic transaction | Goods were delivered or services performed, evidenced by contracts, delivery logs or signed acceptance minutes |
| Valid invoice | A lawful invoice under Decree 254 that states the names, addresses and tax codes of both parties |
| Non-cash payment | Non-cash settlement for each purchase of VND 5 million or more, VAT included; several same-day purchases from one seller that total VND 5 million or more count together |
None of these provisions addresses late-issued invoices expressly, so confirm borderline cases with your adviser. The threshold rules are in our guide to the VAT non-cash payment rule, and refund consequences in VAT refunds for FDI.
Fiscal Year Accrual Alert: When services conclude in fiscal year N but the supplier issues invoices in year N+1, corporate accountants should record accrued expenses under matching principles, submit supplementary tax declarations if required and confirm the treatment with the adviser, to avoid disallowance resulting from improper multi-year expense allocation.
6.3. Disallowed Invoicing Scenarios for Corporate Buyers
FDI enterprises lose the CIT deduction and input VAT credit in the three cases below. The first two involve invoices that are not lawful; the third breaches the non-cash payment conditions:
- Fictitious Billing: Invoices generated without genuine underlying physical goods transfers or commercial service execution.
- Suppliers Not Operating at Their Registered Address (Status 06): Invoices dated on or after the day the tax authority determines that the supplier is not operating at its registered address are unlawful invoices (Decree 254/2026/ND-CP).
- Cash Payment Breaches: Cash settlements for purchases of VND 5 million or more.
Setting up e-invoicing for a new entity or a new system? Contact our Certified CPAs and tax compliance team through our corporate tax compliance services for e-invoice registration, T-VAN setup and ERP integration. Contact our specialists to plan the rollout.
This guide references the Law on Tax Administration No. 108/2025/QH15, Decree 254/2026/ND-CP, Circular 91/2026/TT-BTC, Decree 125/2020 (as amended by Decree 310/2025), Decree 181/2025/ND-CP, and Decree 320/2025/ND-CP.
