Regulations on electronic invoices and documents

I. OVERVIEW OF THE REGULATION

• Reference number: 254/2026/NĐ-CP

• Date of issue: 30 June 2026

• Effective date: 1 July 2026

• Issuing Authority: The Government

• Replaces / Amends: Decree No. 123/2020/NĐ-CP, Article 1 of Decree No. 41/2022/NĐ-CP and Decree No. 70/2025/NĐ-CP

Executive summary:

Decree No. 254/2026/NĐ-CP completely replaces the current legal framework for electronic invoices and documents, setting out detailed provisions in accordance with the Tax Administration Law No. 108/2025/QH15. Key changes include the complete abolition of pre-printed paper invoices issued by tax authorities, the expansion of the scope and thresholds for the application of electronic invoices (including digital assets and carbon trading platforms), and the introduction of several new mechanisms regarding the timing of invoice issuance tailored to specific sectors.

Special note: From 1 July 2026, pre-printed invoices issued by the tax authorities will no longer be valid; therefore, businesses, economic organisations, business households and self-employed individuals who still hold any of these invoices must destroy them immediately. Self-printed or pre-printed paper receipts, however, may be used until 31 December 2026.

II. KEY NEW PROVISIONS

Point 1. Abolition of paper invoices pre-printed by the tax authorities

• Content: Pre-printed invoices issued by the tax authority cease to be valid from the date the Decree comes into force; self-printed or pre-printed paper receipts may be used until 31 December 2026.

• Previous regulations: Pre-printed paper invoices issued by the tax authority may still be sold and used in parallel with electronic invoices for those entities and in those circumstances where the purchase of invoices from the tax authority is permitted.

• New regulations: From 1 July 2026, pre-printed invoices issued by the Tax Authority will no longer be valid, and there will be no transition period; organisations, business households and self-employed individuals with remaining stock must destroy them in accordance with the procedures laid down by the Ministry of Finance.  Self-printed or pre-printed paper receipts may be used until 31 December 2026; from 1 January 2027, they must be destroyed and the transition to electronic receipts must be completed.

Point 2. Adjustment of the conditions for exemption from issuing invoices when payment is received prior to the provision of services

• Content: The term ‘advance payment’ is removed from the list of items previously exempt from the requirement to issue an invoice for specific services; only ‘deposits’ as defined in the Civil Code are now excluded.

• Previous regulation: A deposit OR advance payment made to secure the performance of a contract for the provision of six specific categories of services (accounting, auditing, financial/tax consultancy, valuation, technical surveying/design, supervision consultancy, and preparation of construction investment projects) was exempt from the requirement to issue an invoice upon receipt of payment.

• New regulations: These apply to all contracts for the provision of services (no longer limited to the six industry sectors as before), but the term ‘advance payment’ has been removed from the list of exemptions, and only ‘deposits as defined in the Civil Code’ are now exempt from the obligation to issue an invoice immediately upon receipt of payment.

Point 3. Framework for four categories of entities, with the addition of digital assets and carbon trading platforms

• Content: Decree 254 directly codifies the scope of users of electronic invoices, dividing them into four groups and incorporating the provisions on cash registers into a single set of guidelines.

• Previous provisions: Reference was made to Article 91 of the Tax Administration Law No. 38/2019/QH14 (now repealed); provisions relating to cash registers were set out separately.

• New regulations: Entities required to use electronic invoices include (a) economic organisations using coded electronic invoices; (b) electricity and petroleum companies, as well as those dealing in digital assets and providing transaction services on carbon trading platforms, which use uncoded electronic invoices; (c) direct retail to consumers using point-of-sale terminals; (d) revenue thresholds. Cryptocurrencies and carbon markets are entirely new sectors that have not been covered by previous regulations.

Point 4. Regulations on the use of electronic invoices by business households and sole traders

• Content: The threshold of VND 1 billion per year remains unchanged, but the scope of application of this threshold has been expanded.

• Previous regulations: The revenue threshold of VND 1 billion per year applied only to the obligation to use electronic invoices generated by cash registers.

• New regulations: Business households and sole traders with an annual turnover exceeding VND 1 billion, OR who sell assets subject to registration of ownership or usage rights (such as cars, property, etc.), must use electronic invoices with a code or electronic invoices generated by a cash register connected to the tax authorities’ system, even if their turnover has not yet reached the VND 1 billion threshold.

Point 5. Regulations on electronic invoices for foreign suppliers

• Content: The criterion for determining whether a foreign supplier is required to register for electronic invoicing has been changed from ‘having no permanent establishment in Vietnam’ to ‘generating taxable turnover in Vietnam’.

• Previous regulations: Overseas suppliers without a permanent establishment in Vietnam that engage in e-commerce or business on digital platforms may voluntarily register to use electronic invoices.

• New regulations: Foreign organisations (including operators of e-commerce platforms and digital platforms based overseas) that conduct business activities via e-commerce platforms and other services, and which generate taxable revenue in Vietnam, may voluntarily register to use electronic invoices.

Point 6. Narrowing the scope of entities eligible for one-off sales invoices for merchandise

• Content: Remove the category of entities that were previously issued invoices on a transaction-by-transaction basis when they did not meet the requirements to use electronic invoices

• Previous regulation: Permitted the issuance of invoices on a transaction-by-transaction basis to business households or sole traders who did not meet the criteria for using electronic invoices with a code but required invoices to issue to customers.

• New regulations: The mechanism for issuing invoices on a case-by-case basis to groups of business households or sole traders who do not meet the criteria for using electronic invoices has been abolished. Where there is a need to use electronic invoices, businesses must register to use electronic invoices bearing a code issued by the tax authority, or electronic invoices generated by a cash register connected to the tax authority’s data system.

Point 7. Systematisation of cases where electronic invoices need not be issued

• Content: Decree 254, for the first time, brings together in a single Article the cases where electronic invoices need not be issued.

• Previous regulations: There was no specific provision governing cases where an electronic tax invoice need not be issued (purchases of merchandise/services from sole traders, rental of property from private individuals, commissions from lottery agents, insurance agents or multi-level marketing schemes where tax has already been deducted, reinsurance premiums, receipt of deposits, sale of receivables, foreign exchange and derivatives transactions, capital contribution by means of assets, internal asset transfers, and lending of machinery and equipment) were scattered across previous documents and inferred from VAT legislation.

• New provisions: Consolidated into a single, standalone Article 7, listing eight cases where electronic invoices are not issued, with additional reference to Decree 181/2025/NĐ-CP on VAT.

Point 8. Change the identifier for individual purchasers to the personal identification number

• Content: For buyers who are individual consumers, the invoice must state the individual identification number rather than the personal tax code as previously required.

• Previous regulations: The tax identification number was the primary means of identifying the purchaser; the personal identification number was merely supplementary information provided voluntarily by the purchaser.

• New regulations: Where the purchaser is a consumer who provides their name, address and personal identification number, the invoice must show the personal identification number (foreign nationals may use their passport number); if this information is not provided, the invoice must state ‘Sold to a consumer’.  Invoices that do not contain the purchaser’s details or are issued to a consumer are not valid for the purposes of accounting for expenses or tax settlement.

Point 9. Amendments/additions to the provisions on the timing of invoice issuance

1. Content: The deadline of ‘no later than the 7th day of the following month or 7 days from the end of the accounting period’ has been extended to cover a wider range of cases

• Previous regulations: Applicable to the following sectors: air transport support services, aviation fuel supply, electricity, rail and water transport support services, television, e-commerce, postal and courier services, telecommunications, logistics, information technology, banking (excluding lending), securities, electronic lotteries, road tolls, etc.

• New regulations: Retain all the above industry groups and maintain the deadline of 7 days/the 7th day of the following month; add the following sectors: maritime pilotage, online advertising, digital technology/digital platforms, cryptocurrency, carbon trading platform services, insurance, security services, industrial catering, merchandise exchanges, credit information, and passenger transport by taxi, contract cars or two-wheeled motorcycles using transport-hailing apps.

2. Content: Telecommunications/IT reconciliation: addition of data services

• Previous regulation: Applied only to telecommunications and information technology (including payment intermediaries operating on telecommunications/IT platforms).

• New regulation: ‘Data products and services’ have been added to the scope of the two-month reconciliation mechanism, alongside telecommunications and IT.

3. Content: Introduction of a mechanism for issuing invoices based on transaction data for digital consumer services

• Previous regulations: There was no corresponding mechanism for this group of digital consumer services.

• New regulations: Applicable to businesses providing services to individual consumers: digital banking, e-wallets, cryptocurrencies, e-commerce, ride-hailing services, bus/tram tickets, car parking, cinema screenings, etc. The date of invoice issuance is determined based on the detailed transaction data submitted to the tax authorities, rather than a fixed date as under the traditional reconciliation mechanism.  Condition: the business must have a software system that manages each transaction in detail and stores all relevant data.

4. Content: Addition of provisions on invoicing for night-time transactions not processed via automated software

• Previous regulation: None

• New regulation: Sellers without automated invoicing software who conduct transactions during night-time working hours as defined by the Labour Code may postpone the invoicing deadline until no later than the next working day.

III. RECOMMENDATIONS FOR BUSINESSES

01. Continue to keep abreast of guidance from the Ministry of Finance: Certain provisions previously set out in Decrees 123 and 70 regarding the correction and replacement of invoices are no longer covered in Decree 254. You should therefore continue to keep abreast of the Ministry of Finance’s guidance on this matter, as well as guidance on other aspects of the implementation of electronic invoicing solutions.

02. Review the terms relating to deposits and advance payments in contracts for services: Reconcile the terminology and nature of the payments (deposits as defined in the Civil Code and advance payments) in contracts for services to determine the invoicing obligations from 1 July 2026.

03. Update the regulations on cases where invoices do not need to be issued: Adjust the invoicing software and processes to comply with the new regulations regarding cases where invoices do not need to be issued.

04. Update regulations on the timing of invoice issuance: Review the amended or supplementary provisions regarding the timing of invoice issuance to ensure the correct reconciliation procedures are applied or that invoices are issued in accordance with transaction data, etc., thereby avoiding the issuance of invoices at the wrong time.

CONTACT US FOR ADVICE

• Mr Nguyen Bao Anh – Deputy General Director in charge of Tax, Transfer Pricing & Outsourcing Services

Email: anh.nb@a-c.com.vn

• Ms Nguyen Thi Thu Thao – Senior Manager, Tax and Accounting Services

Email: thao.ntt@a-c.com.vn