Tax & Compliance

Vietnam E-Invoice Requirements: 2026 Guide

Vietnam's e-invoicing rules under Decree 254 and Circular 91, which replaced Decree 123 and 70 in July 2026: coded e-invoices, types, timing, corrections.

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Topics:Tax & ComplianceVietname-invoicingDecree 254Circular 91Decree 123

Vietnam e-invoice requirements have applied nationwide since July 1, 2022, and since July 1, 2026 they sit in Decree 254/2026/ND-CP and Circular 91/2026/TT-BTC, both issued under the Law on Tax Administration No. 108/2025/QH15. These replaced Decree 123/2020/ND-CP, the decree that launched the national regime, together with its amending Decree 70/2025/ND-CP and Circular 32/2025/TT-BTC (the government's full text of Decree 254/2026/ND-CP is published in Vietnamese). For a finance team, the rules now in force come down to five points:

  • Coded e-invoices are the default. Sellers use e-invoices carrying the tax authority's code unless they qualify for another form.
  • Non-coded e-invoices are open to enterprises in listed sectors, such as electricity, telecoms, banking, insurance and e-commerce, whose systems meet the technical conditions, and never to taxpayers the tax authority classes as high risk.
  • Cash-register e-invoices are required for sellers dealing directly with consumers in retail, food and beverage, hotels, passenger transport, entertainment and personal services, unless they already use coded or non-coded e-invoices.
  • The invoice type follows the seller's VAT method: a VAT invoice from a seller on the credit (deduction) method, a sales invoice from one on the direct method, and an e-commercial invoice available to exporters.
  • Timing follows the transaction, not the payment: goods are invoiced when ownership or the right to use them passes to the buyer, services when they are completed, or earlier if payment is collected first.

Decree 123 Has Been Replaced: What Decree 254 Kept and Changed

If a contract, an audit checklist or an older guide sends you to Decree 123/2020/ND-CP, the text it means stopped applying on July 1, 2026. Article 43 of Decree 254 ends Decree 123, Decree 70/2025/ND-CP and Article 1 of Decree 41/2022/ND-CP from that date, and Article 25 of Circular 91 does the same for Circular 32/2025/TT-BTC, which had itself replaced Circular 78/2021/TT-BTC. Decree 254 is a full replacement rather than another amendment, and much of the procedure, including registration, data formats and corrections, now sits in Circular 91 instead of the decree.

Much of what finance teams knew from Decree 123 carries over: coded e-invoices as the default, the same invoice types, the goods and services timing rules, export invoices no later than the next working day after customs clearance, and the cash-register e-invoices Decree 70 brought in from June 1, 2025. What changed:

  1. Non-coded eligibility is listed and conditioned. Article 6(1)(b) names the sectors, now including securities, crypto-assets, carbon-exchange support services and health, and excludes high-risk taxpayers. A non-coded user that the tax authority notifies as high risk must move to coded invoices within 10 working days, and may apply to return only after 12 months (Circular 91, Article 11(2)).
  2. Household businesses have a VND 1 billion line. Business households and individuals with annual revenue over VND 1 billion, or selling assets whose ownership or use rights must be registered, must use coded or cash-register e-invoices (Article 6(1)(d)). Below that line, e-invoicing is voluntary.
  3. A standalone list of cases that need no e-invoice. Article 7 collects them, among them capital contributions in kind, transfers of assets within a company or in a restructuring, reinsurance, securities issuance and foreign-exchange transactions.
  4. Deposits no longer trigger an invoice for any service. Decree 70 confined the deposit carve-out to certain professional services. Under Article 9(2), a deposit under the Civil Code that secures any service contract needs no invoice.
  5. Consumer invoices read "Sold to consumer" when the buyer gives no details, and such an invoice cannot support a business's expense claim (the decree's appendix, item 4).
  6. Old paper formats end. Invoices printed to order by the tax authority stopped being valid on July 1, 2026, and unused paper receipts (biên lai) can be used only until December 31, 2026 (Article 44).
  7. Corrections moved to Article 10 of Circular 91, which also applies to invoices issued under Decree 123 and Decree 70.

Registration has also tightened. It goes through an e-invoice service provider and is matched against the National Population Database, including the legal representative's biometric data, before the taxpayer confirms it (Circular 91, Article 6). Neither text requires existing e-invoice users to register again: a business files a change when its circumstances change, or when the tax authority moves it onto coded invoices.

For comparison, Thailand's e-tax invoice compliance model structures digital invoicing differently, so Southeast Asian regimes should not be treated as interchangeable.

Coded, Non-Coded or Cash-Register: Which E-Invoice Form a Seller Uses

Article 6 of Decree 254, in English translation, sets out three forms of e-invoice, and which one a seller uses is the first thing to establish:

FormWho uses itHow the data reaches the tax authority
With the tax authority's codeThe default for organizations, business households and individuals, and compulsory for high-risk taxpayersEach invoice is sent to the tax authority, which assigns its code
Without the codeEnterprises in listed sectors (electricity, petroleum, post, telecoms, water, banking and finance, securities, crypto-assets, insurance, health, e-commerce, supermarkets, commerce and transport) whose IT, accounting and invoicing software meet the prescribed conditions; never high-risk taxpayersFull invoice data no later than the next working day after the invoice is created, or a monthly or quarterly summary for sectors such as post, telecoms, banking, insurance, air transport, and foreign sellers on e-commerce and digital platforms
From a cash register connected to the tax authoritySellers dealing directly with consumers in retail, food and beverage, hotels, passenger transport, entertainment and personal services, unless already registered for coded or non-coded invoicesThe day's invoice data at the end of each day

A non-coded issuer connects directly to the tax authority only if it averages at least 1,000,000 invoices a month or is a parent company running a central system for its group. Everyone else transmits through an e-invoice service provider (Article 16(3)). For coded and non-coded invoices, where the seller signs after the invoice is created, it must sign and send the invoice for its code, or transmit its data, no later than the next working day.

Overseas suppliers have their own provisions. A foreign supplier may sign with an electronic signature under Vietnam's electronic-transactions law rather than a digital signature (the appendix, item 6). Services supplied through e-commerce and digital platforms by overseas suppliers without a permanent establishment in Vietnam are named under the VAT invoice in Article 8(1), and foreign sellers on those platforms may send their invoice data as a periodic summary.

Which Invoice Type Applies: VAT, Sales, Export, or Cash Register

Before you assess timing or corrections, classify the invoice type. That first step determines what kind of document you are looking at and what validation logic should follow.

The most common distinction readers need to grasp is Vietnam VAT invoice vs sales invoice, and Article 8 of Decree 254 settles it by the seller's VAT method. A seller that declares VAT by the credit (deduction) method issues a VAT invoice (hóa đơn giá trị gia tăng) for domestic sales, international transport, exports and sales into non-tariff zones. A seller on the direct method, whether an organization, a business household or an individual, issues a sales invoice (hóa đơn bán hàng) for the same activities. Sellers located in a non-tariff zone, such as an export processing zone, issue sales invoices marked "For organizations and individuals in the non-tariff zone". If your team processes Vietnamese invoices without first checking whether the seller should be issuing a VAT invoice or a sales invoice, downstream review becomes unreliable, because the expected tax treatment differs.

The VAT invoice is still widely called the "red invoice" (hóa đơn đỏ), after the red copy in the paper invoice booklets the tax authority once supplied. The name survived the move to electronic invoicing, so a Vietnamese colleague or supplier asking whether you need a red invoice means a VAT e-invoice issued with your company's details on it. The decree itself does not use the term.

Export transactions add another category that should not be folded into an ordinary domestic rule set. A Vietnam export e-commercial invoice is available to exporters of goods and services that can transmit its data to the tax authority electronically in the standard data format. An exporter that cannot do so issues an electronic VAT invoice or sales invoice instead (Article 8(3)). Our guide to Vietnam's export e-commercial invoice decision rules breaks out when exporters can use that document, when they need a fallback invoice type, and how the timing rules differ for goods and services.

Article 8 also covers invoices for sales of public assets and national reserve goods, stamps, tickets and cards, and documents that follow international practice, such as air freight receipts and bank-fee receipts. Cash-register e-invoices are strictly a form rather than a separate type, but in practice they are classified alongside the others, and they get their own section below. The practical lesson is straightforward: identify whether the document is a VAT invoice, sales invoice, export e-commercial invoice, or a cash-register generated invoice first. Once the type is clear, the rest of the compliance analysis becomes more dependable.

What a Vietnamese E-Invoice Must Show, and Why Buyer Details Decide Whether You Can Book It

Article 10 of Decree 254 and its appendix set the contents of an invoice. These are the points that most often decide whether an invoice you receive is usable:

  • Buyer details exactly as registered. A business buyer's name, address and tax code must match its business or tax registration certificate. Long names may be shortened with standard abbreviations such as "TNHH" or "CP", provided the buyer stays clearly identifiable.
  • "Sold to consumer" invoices. A consumer who gives a name, address and personal identification number gets them on the invoice. One who gives nothing gets an invoice marked "Bán cho người tiêu dùng" ("Sold to consumer"). The appendix states that an invoice with no buyer information, or one issued to a consumer, has no value for an organization, business household or business individual to record as an expense or use in tax finalization.
  • Foreign buyers. A passport or immigration document number and nationality can take the place of the address and personal identification number. The buyer's digital signature is not required, including on sales to customers abroad.
  • Language and currency. Invoices are in Vietnamese. Any other language appears in brackets to the right of the Vietnamese or directly below it in smaller type. Amounts are in Vietnamese dong; where a transaction may lawfully be priced in a foreign currency, the invoice shows that currency with the exchange rate to VND.
  • Numbering. Invoice numbers run up to eight digits within a serial and restart at 1 on January 1 each year.
  • When each side declares. The seller declares tax by the invoice's creation date. The buyer declares when it receives an invoice that is correct and complete in form and content.

The buyer-details rule is the one that catches expense claims. A company that wants to claim a restaurant bill, a hotel stay or a food-delivery order gives its name, tax code and address at the time of purchase, because an invoice already issued as "Sold to consumer" cannot be booked as a business expense.

Vietnam E-Invoice Timing Rules for Goods, Services, and Exports

Timing is one of the most important parts of Vietnam's e-invoicing rules because it shapes both compliance and period-end controls. Article 9 of Decree 254 sets the triggers:

TransactionWhen the invoice is created
Sale of goodsAt the transfer of ownership or the right to use the goods, regardless of whether payment has been received
ServicesWhen the service is completed, regardless of whether payment has been received; if payment is collected before or during the service, at the time of payment
Deposit securing a service contract under the Civil CodeNo invoice for the deposit
Export of goodsSet by the seller, but no later than the next working day after customs clearance
Staged deliveriesOne invoice per delivery or stage, for the volume and value delivered
Construction and installationAt acceptance or handover of the works, whether or not payment has been made
Reconciliation-based services, such as electricity, telecoms, e-commerce, logistics, digital and IT services, and insuranceWhen the data reconciliation is completed, no later than the 7th of the following month or 7 days after the agreed period
Night-shift sales by a seller without automatic invoicing softwareNo later than the next working day

Those rules matter because a document can look complete on its face and still raise a control issue if the issuance point does not line up with the underlying transaction. A finance team reviewing Vietnamese invoices should therefore ask two questions in sequence: what type of invoice is this, and did it appear at the right point in the commercial process? An invoice dated before a service was delivered is normal when it records an advance payment. A services invoice dated weeks after completion usually is not, outside the reconciliation-based sectors. That logic helps with exception handling around cut-off, VAT review, and month-end reconciliation.

Malaysia's rules on when consolidated e-invoices are allowed show how another regime handles grouping and timing, but those rules do not apply in Vietnam, where the issuance triggers above govern.

Who Must Use Cash-Register E-Invoices

Cash-register e-invoices became one of the most visible practical themes in Vietnam's e-invoicing rules when Decree 70 brought them in from June 1, 2025, and Decree 254 keeps them. For readers researching Vietnam cash register e-invoices, the reason is scale: Vietnam has a very large population of business households and consumer-facing businesses where the government wants invoice issuance to be immediate and traceable.

At the end of 2024, Vietnam had 3.6 million business households under tax administration, and about 2 million of them paid tax under the lump-sum method in early 2025, according to Vietnam News reporting on the June 2025 cash-register e-invoice rollout. That is the population the rollout was built for, which is why cash-register generated invoices are not a niche footnote.

Under Decree 254, two rules decide scope. Article 6(1)(c) requires them from organizations, business households and individuals selling directly to consumers in shopping centres, supermarkets and retail stores (motor vehicles excepted), food and beverage, restaurants, hotels, passenger transport, entertainment, cinemas and other personal services, unless they already use coded or non-coded e-invoices. Article 6(1)(d) adds the VND 1 billion revenue line for business households and individuals, who above it choose between coded and cash-register e-invoices.

A cash-register e-invoice also works differently from an ordinary e-invoice. It must be identifiable as created from a connected cash register, it needs no digital signature, and it counts as a valid invoice for the buyer's expenses when its information is retrieved from the tax authority's system (Article 8(9)). The buyer's tax code, personal identification number or phone number appear on it only if the buyer asks, so a business buyer asks at the till. And the seller sends the day's cash-register invoice data to the tax authority at the end of each day (Article 15(3)). If you need the operational detail, this breakdown of cash-register e-invoice requirements for Vietnam retailers and restaurants goes deeper on scope, the VND 1 billion threshold, invoice content and the day-end data transfer.

Their layout and point-of-sale identification also differ from standard B2B VAT or sales invoices, so document classification and matching workflows should treat them as a category of their own.


Replacement vs Adjustment Invoices in Vietnam's Correction Workflow

Corrections are part of normal invoice operations, not an exception you can ignore until something goes wrong. Since July 1, 2026, Article 10 of Circular 91/2026/TT-BTC sets three routes for an issued invoice that turns out to be wrong, and cancelling it is not one of them:

  • Notify only. If the error is limited to the buyer's name, the address or the amount in words, and the tax code, goods, amounts, tax rate and tax amount are right, the seller notifies the buyer and sends Form 04/SS-HDDT to the tax authority. No new invoice is issued.
  • Adjust or replace. Any other error calls for an adjustment invoice or a replacement invoice, carrying the prescribed line that identifies the original invoice by form, serial, number and date. Invoices from cash registers and invoices for assets whose ownership must be registered can only be replaced.
  • Batch the same error. Where the same incorrect information appears on several invoices issued to one buyer in the same month, one adjustment or replacement invoice can cover them all, with the invoices listed on Form 01/BK-DCTT.

With a business buyer, the parties normally sign a written agreement on the error before the adjustment or replacement is issued; an individual buyer is notified. Invoices issued before July 1, 2026 under Decree 123, Decree 70 and Circular 32 are adjusted or replaced under the same Circular 91 procedure (Article 24).

In plain workflow terms, a replacement invoice takes the place of the earlier document as the operative record. An adjustment invoice keeps the original invoice in the history and records the change against it, such as a corrected amount or tax rate.

That distinction matters for extraction, posting, and reconciliation. If a document has been replaced, the team should be careful not to keep treating the original invoice as the live version. If it has been adjusted, the team needs to preserve the relationship between the original and the correcting document so totals, tax positions, and reporting logic still make sense. A workflow that captures only the latest PDF without the correction trail can create posting errors and duplicate counting. Teams that need the narrower operational test can use our guide to Vietnam's adjustment-versus-replacement rules under Circular 91, which breaks the decision down by error type, buyer notice, and declaration timing.

Keep original and corrected records linked, confirm which document is currently operative, and review whether the correction changes taxable amounts or totals before loading data into downstream reports.

What Foreign Operators and Finance Teams Should Check Before Processing Vietnamese Invoices

For cross-border teams, the best way to use this guide is as a review checklist. Before you process a Vietnamese invoice, confirm seven basics:

  • Legal basis by date: An invoice issued from July 1, 2026 falls under Decree 254 and Circular 91; one issued earlier was governed by Decree 123 and Decree 70, though any correction to it now follows Circular 91.
  • E-invoice form: Is it coded, non-coded, or generated from a cash register, and does that fit the seller's sector and profile?
  • Invoice type: Is it a VAT invoice, sales invoice, export e-commercial invoice, or a cash-register generated invoice, and does the seller's VAT method support that type?
  • Buyer details: Does it carry your company's name, address and tax code as registered, rather than "Sold to consumer"?
  • Timing: Does the issuance point match the goods rule, the services rule, or the sector-specific trigger that applies?
  • Correction status: Are you looking at the original invoice, an adjustment invoice, or a replacement invoice?
  • Workflow fit: Does your finance process treat this document according to Vietnam-specific rules rather than a generic global template?

For teams comparing multiple markets, South Korea's Hometax electronic tax invoice workflow is another example of how electronic invoicing systems can look similar at a distance while operating very differently in practice. Vietnam-specific document types should be identified before extraction or posting. Otherwise, a sales invoice can be forced into VAT logic, or a replacement invoice can be treated like an untouched original.

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