E-Invoice Compliance in 2025: Regulations, Requirements, and Best Practices

Posted by Written by Vu Nguyen Hanh and Doan Thi Yen Luy Reading Time: 9 minutes
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Vietnam mandates the use of e-invoice (electronic invoice) for all taxpayers. This article provides essential guidance and notes the step-by-step compliance requirements for businesses implementing e-invoicing.

In 2025, several significant updates were introduced regarding Vietnam’s provisions on e-invoices, which were originally promulgated under Law on Tax Administration 2019. These amendments are prescribed under the following directives:

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Starting July 1, 2022, all enterprises, economic organizations, household businesses, and individuals paying tax under the declaration method in Vietnam must use e-invoices, except for certain cases.

Following several years of implementing the e-invoice system, the government has issued new invoice regulations, effective from June 1, 2025, to address practical issues and gaps identified during the application of the 2022 regulations. The update aims to enhance clarity, align with the amended VAT Law, improve tax administration efficiency, and adapt to the increasing use of e-invoices and digital transactions.

Types of e-invoices in Vietnam

By nature, e-invoices in Vietnam are categorized into two main types, including:

  • Authenticated e-invoice: An e-invoice that is granted an authentication code by the tax authority before being sent to the buyer by the goods seller or service provider; and
  • Unauthenticated e-invoice: An e-invoice that is sent to the buyer by the goods seller or service provider without the tax authority’s authentication code.

By purpose of usage, e-invoices share the same classification as their printed counterparts. Specifically, Article 8 of Decree 123, which outlines e-invoice types in Vietnam, has been adjusted by Decree 70, as presented under this table:

E-Invoice Type

Original Regulation under Decree 123

Update from Decree 70

E-VAT (electronic value-added tax) invoice

Used by organizations declaring VAT using deduction method for:

  • Domestic goods/services;
  • International transport;
  • Export to free trade zones (FTZs) and other exports; and
  • Export of goods and services to overseas markets.

Expanded to include:

  • E-commerce or digital platform-based services and other services provided by foreign suppliers without permanent establishments in Vietnam; and
  • Export Processing Enterprises (EPEs) that perform other business activities and apply deduction method.

E-sales invoice

Used by organizations or individuals applying direct VAT method for:

  • Domestic goods/services;
  • International transport;
  • Export to FTZs; and
  • Export of goods and services to foreign markets.

Also applies to entities in FTZ; must be marked with the phrase “For organizations/individuals in free trade zones”.

EPEs that perform other business activities and declare VAT using direct method shall use sales invoices.

E-commerce

Not specified in Decree 123

New invoice type added:

  • Used by exporters of goods/services;
  • Must meet technical conditions for data transmission to tax authorities; and
  • Must contain adequate information as prescribed and be issued in the standard data format.

If conditions are unmet, the exporter may use an e-VAT invoice or an e-sales invoice instead.

Cash-register-generated e-invoice

Not specified in Decree 123

New invoice type added:

  • Business households and individuals with an annual revenue of VND 1 billion (US$38,462) and above; and 
  • Businesses that offer goods and services in commercial centers, supermarkets, retail (excluding vehicles), food and beverage services, restaurants, hotels, passenger transport, and various personal services as defined by Vietnam’s Economic Sector regulations.

E-invoice for public property sales

Used when selling:

  • State/public property (including housing);
  • Infrastructure property;
  • Public project assets;
  • All-people ownership assets;
  • Appropriated public assets; and
  • Raw materials from the disposal of public property.

Simplified language, implementing a broad application to the sale or transfer of public property under laws on public asset management.

E-invoice for reserve goods sales

Used by state reserve agencies/units when selling national reserve goods.

No update

Other e-invoice
  • Stamps, tickets, and cards;
  • Receipts: air freight, international transport charges, banking services. Exceptions apply where international format is mandated.

No update

Invoice-like electronic records
  • Delivery/internal transfer notes; and
  • Notes for goods sent to agents.

No update

What information must be contained on the e-invoice

As per Article 10 of Decree 123, amended by Decree 70, an eligible e-invoice must contain the following information:

  • Name of e-invoice, serial number of e-invoice;
  • E-invoice number;
  • Name, address, and tax code number of the seller;
  • Name, address, and tax code number of the buyer;
  • Electronic signature by the seller and buyer;
  • E-invoice issuance date;
  • Signature date;
  • Name and tax code of e-invoice provider; and
  • Transaction details, including the description of goods or services aligned with specified cases:
    • Food and beverage service: The e-invoice must show the food and beverage items;
    • Transportation services: The e-invoice must show the vehicle’s plate number and voyage (place of departure – place of arrival); and
    • Transportation businesses providing transportation services on a digital platform: The e-invoice must show e-commerce activities, the name of the transported goods, and the name, address, tax code, or identification number of the senders.

For e-invoices generated from POS cash registers, mandatory information include:

  • Name, address, and tax code of the seller;
  • Name, address, tax code/personal identification number/telephone number of the buyer according to regulations (if requested by the buyer);
  • Name of goods, services, unit price, quantity, payment price. In case the sellers apply the deduction method, the price exclusive of VAT, VAT rate, VAT amount, and total payment amount must be shown;
  • Time of invoice issuance; and
  • Tax authority code or electronic data that allows the buyer to access and declare information contained in the e-invoice generated by the POS cash register.
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E-invoices must be stored and archived according to the regulations to ensure they are accessible for future reference and tax audit.

The invoiced text must be in Vietnamese. If foreign language text is needed, it should be placed in parentheses (_) to the right or below the Vietnamese text and formatted in a smaller font. When omitting diacritics in Vietnamese, care must be taken to avoid misinterpretation.

Numbers on the invoice must use Arabic numerals: 0, 1, 2, 3, 4, 5, 6, 7, 8, 9.

In the event of errors on either authenticated or unauthenticated e-invoices, Article 19 of Decree 123, amended by Point 13, Article 1 of Decree 70, guides on how to address these discrepancies.

For additional details on key amendments from Decree 70 regarding overall invoice compliance in Vietnam, please read: Invoice Compliance in Vietnam: Key Changes under Decree 70

E-invoice registration process

For e-invoice registration, enterprises in Vietnam need to follow the steps implemented under Article 15, Decree 123/2020/ND-CP, amended by Point 11b, Article 1 of Decree 70. These are listed below.

Step 1: Applying through e-invoice service providers

Companies must prepare the registration form for using e-invoices according to Form No. 01/DKTD-HDDT in Appendix IA, enclosed with this decree. In this form, the enterprise must specify information about:

  • The invoice type (with or without the tax authority’s authentication code);
  • An active email address for the tax authorities to send notifications on registration results; and
  • Other related information.

Applications for free-of-charge use of authenticated e-invoices may be submitted via the web portal of the General Department of Taxation (GDT) or an e-invoice service provider entrusted by the GDT to provide free-of-charge authenticated e-invoices.

If enterprises transmit e-invoice data directly to tax authorities, they shall apply to use e-invoices via the GDT web portal.

Step 2: Acknowledging the application form

The electronic portal of GDT will send an electronic notification confirming the receipt of the enterprise’s registration for using e-invoices.

Step 3: Obtaining result notification

Within 01 working day from the date of receiving the registration, the tax authority will send an electronic notification according to Form No. 01/TB-DKDT in Appendix IB issued with the decree, particularly:

  • If the registered information does not match the data in the National Population Database or the Electronic Identification and Authentication System, the tax system’s portal will automatically send a refusal notice to the taxpayer either on the same working day or by the end of the next working day.
  • If the registered information matches, the tax system portal will automatically send a verification request to the taxpayer via email or phone. The subsequent actions are as follows:
    • Within the verification request timeline (either the same working day or by the end of the next working day): If the taxpayer is not on the list of companies with tax violations, suspended operations, or in the process of dissolution, the e-invoice registration is approved. Otherwise, the taxpayer must provide an explanation and supporting documents within two working days of receiving the notification from the tax authority; or
    • If the verification timeline is exceeded, a notice of application denial will be automatically sent from the tax system portal to the taxpayer within the same working day or by the end of the next working day.

Please be advised that all the steps above can be taken by the Company or via an e-invoice provider on behalf of the Company.

Key purposes and timing for issuing invoices

Decree 70/2025/ND-CP amends Article 9 of Decree 123/2020/ND-CP and sets the latest time for issuing invoices in certain cases, such as:

  • Sale of goods (including transfer of public assets): Invoices are issued when ownership transfers to the buyer, regardless of whether payment has been made.
  • Export of goods: The seller determines the timing of issuance, which must be no later than the next business day after customs clearance.
  • Provision of services: Invoices are issued when the service is completed, regardless of payment status. If payment is received in advance (excluding deposits), invoices are issued at the time of payment.

Decree 70 prescribes that for tax declaration purposes:

  • The seller must declare tax based on the invoice issuance date; and
  • The buyer declares tax based on the date they receive the invoice, provided that the invoice is in the correct format and contains all the required information.

Suspension of e-invoice use

According to Article 16 of Decree 123/2020/ND-CP, amended by Point 12, Article 1 of Decree 70, enterprises, business entities, organizations, or individual businesses must suspend the use of authenticated and unauthenticated e-invoices in the following circumstances:

  1. The entity’s Tax Identification Number (TIN) has been invalidated.
  2. The entity is not operating at the registered location, as confirmed by the tax authority.
  3. The entity has submitted a notification of business suspension to a competent authority.
  4. The tax authority has prohibited using e-invoices to enforce tax debt payments.
  5. E-invoices are utilized to sell smuggled, banned, counterfeit goods, or goods violating intellectual property rights, as reported by competent authorities.
  6. E-invoices are used for fraudulent short selling of goods or services as detected and reported by competent authorities.
  7. A business registration authority or relevant authority has requested the suspension of operations in a conditional business line due to non-compliance with legal business conditions.
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  1. The tax authority notifies that cease using e-invoices generated from cash registers if the business does not meet the conditions for using e-invoices generated from cash registers
  2. The taxpayer has committed acts of tax evasion, has been established for the purpose of trading in, using unlawful e-invoices, or unlawfully using e-invoices to evade taxes as prescribed.
  3. The taxpayer is classified as having a very high level of tax risk.

Penalties for violations related to e-invoice issuance

Penalties for violations of regulations on issuing invoices upon the sale of goods or provision of services are provided under Article 24 of Decree 125/2020/ND-CP.

Penalty

Violation

Penalty cautions
  • Issuing invoices at the wrong time but not to the extent of causing any deferred fulfillment of tax obligations under any mitigating circumstance;
  • Issuing a continuous series of invoices in ascending numerical order by exercising disagreeing invoicing authorizations, although entities or individuals have managed to cancel invoice books containing less numbered invoices after the discovery of such a situation; and
  • Issuing wrong types of invoices that have already been handed to buyers or been used for completion of tax declaration procedures, although sellers and buyers have discovered the issuance of the wrong types of invoice and replaced them with the correct ones before the competent authority’s issuance of their decisions to conduct tax inspection and examination at the defaulting taxpayer’s offices or premises, and this situation does not affect the determination of tax obligations.

 

Fines from VND500,000 to VND1,500,000

(about US$20-60)
  • Failing to issue general invoices under regulations on invoices for the sale of goods or provision of services, except as provided in points a of clauses 1 of this Article;
  • Failing to invoice promotional, advertising, or sample goods or services; and
  • Failing to invoice goods and services used as gifts, donations, presents, swaps, or employee’s payment-in-kind wages, except for internally circulated or consumed goods for further production purposes.

 

Fines from VND3,000,000 to VND5,000,000

(about US$118-197)

 
  • Issuing invoices at the wrong time but not to the extent of causing any deferred payment of tax obligations.

Fines  from VND4,000,000 to VND8,000,000

(about US$157-315)

 
  • Issuing invoices at the wrong time in breach of laws on invoices for the sale of goods or provision of services, except as provided in points a of clauses 1 and 3 of this Article;
  • Issuing invoices without conforming to the statutory ascending numerical sequence, except when the penalty in the form of caution prescribed in point b of clause 1 of this Article is imposed;
  • Issuing invoices with the invoicing dates coming ahead of the dates of purchase of invoices from tax authorities;
  • Issuing invoices not conforming to classifications prescribed in law on invoices for sale of goods and provision of services if these invoices have already been handed to buyers or used for the completion of tax declaration procedures, except in the case of imposition of the penalty in the form of caution as provided in point c of clause 1 of this Article;
  • Issuing e-invoices when having not yet received notices of consent from tax authorities or before the dates of consent to using e-invoices with/without tax authority’s codes from supervisory tax authorities;
  • Issuing invoices for the sale of goods and provision of services during the period of temporary business closure, except when issuing invoices to clients to implement contracts signed before the date of notification of such temporary business closure;
  • Issuing e-invoices by using cash registers without network connection or transfer of electronic data to tax authorities; and
  • Issuing invoices that do not contain all compulsory contents as prescribed.

 

Fines  from VND10,000,000 to VND20,000,000

(about US$392-784)

 
  • Any act of failing to issue invoices upon sale of goods or provision of services to buyers as required by laws, except the acts prescribed in point b of clause 2 of this Article.

(With inputs from Mia Pham, Corporate Accounting Services, Dezan Shira & Associates Vietnam.)

This article was originally published on October 25, 2024. It was last updated on August 8, 2025.

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