Vietnam E-Invoices: Operational Setup Before the First Sale

Before a new Vietnam company accepts its first service advance or delivers its first order, finance should have a working e-invoice process, not merely a software subscription. Registration, signing, tax authority transmission and customer delivery are separate steps. A regional accounting system that produces a PDF does not, by itself, complete those steps.

The current framework includes Decree 254/2026/ND-CP and Circular 91/2026/TT-BTC, both effective from 1 July 2026. Decree 254 replaced Decree 123/2020/ND-CP and Decree 70/2025/ND-CP. These are enacted rules, not the earlier consultation draft. Teams should therefore check the legal version behind their provider's onboarding instructions.1 2 3

This guide concerns a foreign-invested company established in Vietnam. It should not be confused with the separate voluntary registration route for foreign suppliers operating from overseas.1 2 For the preceding incorporation steps, see the Vietnam foreign business registration guide.

Choose the invoice route before configuring software

Distinguish the invoice's tax function from its transmission method. A value added tax (VAT) invoice and a sales invoice serve different VAT accounting methods. Separately, an e-invoice can have a tax authority code or operate without one under the applicable conditions. For a coded invoice, the authority issues the code before the seller sends the invoice to the buyer.1

Do not assume foreign ownership determines the route. Decree 254 provides a coded route for economic organisations, with an uncoded route available subject to the stated business and technology conditions and tax-risk restrictions. Using an overseas enterprise resource planning system does not automatically establish eligibility.1

Consumer-facing operations need a further check. The decree identifies activities such as retail, restaurants and hotels for cash-register e-invoices, but also contains an exception where the business has already registered for the specified ordinary coded or uncoded route. This is not a blanket requirement for every company to buy a physical till.1

Ask the accountant and provider to document the selected invoice type, coding route and transmission process. Include how corporate customers will receive invoices and how consumer transactions will be handled. Keep that decision with the registration file.

Complete registration and protect signing access

For an ordinary new company, Circular 91 provides for registration through an e-invoice service provider using Form 01/ĐKTĐ-HĐĐT. Direct transmission and specified free-service arrangements have different channels. The tax system's receipt notice is distinct from its notice accepting or rejecting registration.2

Prepare consistent company and representative information before submission. Confirm that the registered email address and telephone number are accessible to the appropriate person. Article 6 provides for matching representative information, including biometric information under the electronic identification rules, and a confirmation request. The taxpayer must confirm within the working day or, at the latest, the following working day. Missing or unsuccessful confirmation can lead to rejection.2

Where information needs explanation or risk indicators arise, the authority may request documents or verify actual activity at the registered address. The circular gives three working days to provide requested explanations or supplementary information. Do not turn a provider's estimate into a guaranteed activation date.2

For a foreign legal representative, establish the applicable identity-verification workflow with the provider and managing tax office before scheduling launch. Do not assume a domestic identity workflow transfers unchanged or that foreign nationality creates an exemption.

Ordinary company invoices generally use the company's digital signature, subject to statutory exceptions. Cash-register invoices do not require a digital signature. That exception does not remove the separate registration and transmission requirements.1

As an internal control, record the certificate owner, expiry date, authorised users and recovery arrangements. Separate invoice preparation from release where staffing permits. An external accountant's involvement should not leave the company unable to retrieve its invoices or control signing access.

Trigger invoices from transactions, not month-end routines

Configure timing around the actual activity:

• Domestic goods: the usual trigger is transfer of ownership or use rights, whether or not payment has arrived.
• Services: the usual trigger is completion, including services supplied to overseas customers. Receiving payment before or during supply generally triggers an invoice on receipt, except for a Civil Code deposit securing performance of the service contract.
• Partial delivery or staged services: each delivery or handover requires an invoice for the corresponding goods or services.
• Exported goods: the seller determines the invoice time, but no later than the next working day after customs clearance.1

The deposit distinction deserves contract review. Calling an advance a “deposit” in a payment request does not establish that it is a qualifying security deposit. Give finance the contract terms before money arrives.

Special timing rules exist for defined activities, including certain recurring services requiring reconciliation. A customer's request for consolidated monthly billing does not, on its own, establish that the transaction qualifies.1

Invoice creation and digital signing also have separate timestamps. Where they differ, the ordinary rule requires signing and submission for coding, or transmission of uncoded invoice data, no later than the next working day after invoice creation. Specified summary and detailed-transaction reporting arrangements are exceptions. This is not permission to delay creating an invoice that was already due.1

Set alerts for completed deliveries without invoices and created invoices still awaiting signing or transmission. For payment collection arrangements, the Vietnam corporate banking guide provides adjacent context, but a bank receipt is not an e-invoice.

Set a correction procedure before mistakes occur

Do not overwrite an issued invoice or replace it with an edited PDF. Article 10 of Circular 91 distinguishes errors that require notification from those requiring adjustment or replacement.2

For ordinary invoices, specified errors such as the buyer's name or address can be notified to the buyer without reissuing the invoice if the tax code, amounts, tax rate, tax amount and goods information remain correct. The seller also submits Form 04/SS-HĐĐT to the authority. Errors in the tax code, relevant goods particulars, amounts or tax figures generally follow adjustment or replacement procedures.2

Before the ordinary adjustment or replacement procedure for a business buyer, the parties must record the error in a written agreement. Defined exceptions include goods transactions on e-commerce and other digital platforms. Individual buyers instead require notification. Cash-register invoices and invoices for assets subject to ownership or use registration have specific replacement rules, so do not apply the ordinary decision tree indiscriminately.2

Give one person responsibility for classifying errors. Preserve the original invoice, correction reference, required agreement or notification and transmission evidence together. Link corrections to the accounting entry so that a replacement does not become a second sale.

First-sale readiness checklist

Before releasing the first live transaction, confirm that:

• The company has the appropriate tax authority acceptance notice, not only a submission receipt.
• Signing access works, certificate expiry is monitored and a responsible backup is identified.
• Buyer details, Vietnamese descriptions, VAT treatment and invoice timing have been checked against realistic transactions.
• Provider testing covers signing, coding or transmission, customer delivery and accounting import without issuing fictitious live sales.
• Daily reconciliation identifies missing, rejected or duplicate invoices, and original electronic data can be exported and retrieved.

Decree 254 requires electronic records to remain secure, complete and unaltered, with storage as data messages and availability for retrieval or printing. Retaining only a display PDF is therefore not an adequate archive strategy.1 These transaction controls complement, rather than replace, the broader Vietnam accounting and tax compliance guide.

Focused FAQs

Can we wait until the customer pays to invoice a completed service?

Normally, no. Completion is the usual service trigger regardless of payment. An advance can trigger an earlier invoice, while defined activities have special timing rules. Configure the applicable rule before using payment status as the trigger.1

Does outsourcing invoice preparation transfer responsibility?

No. Decree 254 places responsibility for invoice accuracy on the seller. Formal third-party invoice authorisation is permitted, but Circular 91 requires a written arrangement and tax authority notification. Software support and formal delegated issuance should not be treated as interchangeable.1 2

References

• 1 Government of Vietnam: Decree 254/2026/ND-CP on electronic invoices and electronic documents
• 2 Official Gazette: Circular 91/2026/TT-BTC on electronic invoices and electronic documents
• 3 KPMG Vietnam: Decree 254 and Circular 91 on electronic invoices, 15 July 2026