Vietnam Introduces New Regulatory Framework for e-Invoices and e-Documents

Effective July 1, 2026, Vietnam has implemented a revised legal framework governing electronic invoices and electronic documents to deepen the digitalization of the country’s tax administration. The framework is set out in Decree No. 254/2026/ND-CP (“Decree 254”), issued by the Government on June 30, 2026, and in Circular No. 91/2026/TT-BTC (“Circular 91”), issued by the Ministry of Finance on the same date. Together, the two instruments implement provisions of the Law on Tax Administration No. 108/2025/QH15 and replace the e-invoicing regime previously set out under Decree 123.

The new rules introduce more detailed data-integration requirements, standardized electronic formats, and broader compliance obligations. Businesses operating in Vietnam are expected to reassess their invoicing and reporting processes accordingly.

Scope and Eligible Users

• Circular 91 amends the definition of “illegal use of invoices and documents,” excluding cases where an invoice or document simply lacks a mandatory field.
• Voluntary e-invoice registration is now open to e-commerce platform operators, foreign digital platform operators, and other providers of taxable services in Vietnam.
• Mandatory e-invoicing applies to household businesses and individual businesses with annual revenue exceeding VND 1 billion, or when they sell assets whose ownership or use rights are subject to registration.
• Additional guidance addresses invoice issuance from cash registers in designated sectors, as well as how revenue and expenses should be invoiced between parties to business cooperation contracts.

Transactions Excluded from the E-Invoicing Requirement

Transactions that fall outside the e-invoicing obligation under the new rules include:

• Capital contributions made in the form of assets by organizations or individuals to economic entities
• Asset transfers between a parent company and its dependent units, and transfers between dependent units within the same enterprise
• Asset transfers arising from a division, separation, consolidation, merger, or conversion of an enterprise
• Machinery, equipment, tools, or instruments lent free of charge for use as fixed assets or for goods-processing purposes, where ownership is not transferred
• Financial and insurance transactions, along with certain transactions carried out by household and individual businesses
• Specified cases where invoice issuance is not required under value-added tax regulations.

While these exemptions may ease the administrative burden in qualifying cases, businesses still need to confirm that a given transaction meets the stated criteria and retain the supporting documentation to evidence this.

Timing of Invoice and Document Issuance

Several practical adjustments have been made to when an e-invoice or e-document must be issued:

• A deposit taken solely to secure performance of a service contract, in line with the Civil Code, no longer requires issuing an invoice at the time the deposit is received.
• Sellers without automated invoicing software who carry out sales of goods or services during night-time hours may issue the corresponding e-invoice no later than the following working day.
• For a defined group of services supplied to corporate and organizational customers – including online newspaper advertising, digital technology services, digital platform services, IT services, insurance services, security services, and connected passenger transport services under road transport regulations – invoices may be issued periodically, once the relevant data has been reconciled or finalized.

Invoice Content Requirements

• Household and individual businesses operating more than one outlet, as well as entities engaged in petroleum trading, must now state the code and address of the relevant business location.
• Where an individual consumer does not provide their name, address, or personal identification number, the invoice must instead be marked “sold to consumer.”
• Additional provisions cover the description of goods and services, the sale of automobiles and motorcycles, and domestic road transport services.
• Foreign suppliers using an electronic signature must ensure it complies with Vietnam’s regulations on electronic transactions.
• Separate provisions address the correction of e-invoices and e-documents that contain errors or incorrect information, along with transitional arrangements and the circumstances in which the use of e-invoices may be suspended or temporarily suspended.

Conversion to Paper Format

E-invoices may be converted into paper form only for audit, inspection, or accounting record-keeping purposes; the resulting paper copies cannot be used for commercial transactions or payments, except in specific cases such as invoices generated through point-of-sale systems. Paper receipts may still be used until December 31, 2026. Electronic receipts become mandatory as of January 1, 2027.

Consumer Reporting and Reward Mechanism

For the first time, consumers have a formal route to report sellers who fail to issue an e-invoice, through channels operated by the tax authorities or through public service portals. Where such a report leads to an administrative penalty being imposed, the individual who submitted it may qualify for a reward of up to VND 10 million per case, subject to the conditions set out in the regulations. The mechanism is intended to widen compliance monitoring and encourage greater transparency in business transactions.

Other Notable Provisions

Circular 91 also clarifies that a Personal Income Tax withholding certificate is not required for certain categories of income already taxed at source, such as gains from securities transfers, capital investments, crypto-asset transfers, gold bar transfers, royalties, and franchising activities. In addition, a new requirement obliges taxpayers to prepare and submit a Detailed Transaction Information Statement to the tax authority for certain services provided to individual consumers.

Implications for Businesses

Decree 254 and Circular 91 are designed to strengthen transparency, efficiency, and data connectivity within Vietnam’s tax administration system, while also introducing new compliance obligations across sectors. Businesses operating in Vietnam should review their transaction classifications, invoice issuance procedures, and internal systems against the new requirements, with a view to limiting compliance risk once the framework takes full effect.

There’s more you should know about e-invoicing in Vietnam – learn more about the new and upcoming regulations.