Vietnam E-Invoice (Hóa Đơn Điện Tử) Compliance 2026: A Complete Guide for FDI Companies

From 1 July 2026, Vietnam’s entire legal framework for electronic invoicing is replaced. This is not a partial amendment like previous rounds — all three tiers of legislation change at once: the law, the decree and the circular. For foreign-invested enterprises, every internal procedure, template and guidance document that cites the old rules needs its legal basis updated.

This article is the overview. For each specialised topic we link to a dedicated analysis.

1. The legal framework from 1 July 2026

Decree No. 254/2026/ND-CP was issued on 30 June 2026, comprising 5 chapters and 45 articles plus an appendix, and provides detailed implementation of Law on Tax Administration No. 108/2025/QH15 on electronic invoices and documents. It replaces Decree No. 123/2020/ND-CP and Decree No. 70/2025/ND-CP.

See the detailed analysis in Vietnam’s new e-invoice rules under Decree 254/2026, and the wider context in Vietnam Tax Administration Law 2026 — key highlights.

2. Three types of e-invoice and who uses which

• E-invoice with a tax authority code — the most common category, used by economic organisations, other organisations, business households and individuals when selling goods or services, except where they qualify for code-free invoices or cash-register invoices. Taxpayers classified as high tax risk also fall into this category.
• E-invoice without a tax authority code — for enterprises in specific sectors with adequate IT infrastructure: electricity, petroleum, post and telecommunications, clean water, banking and finance, securities, insurance, healthcare, e-commerce, supermarkets and transport. The new list adds crypto assets and services supporting transactions on carbon exchanges — two areas not previously named.
• E-invoice generated from a cash register — for business households and individuals with annual revenue above VND 1 billion, and enterprises selling directly to consumers. The new rules clarify a long-standing question: an entity that has already registered to use coded or code-free e-invoices is not required to separately register for cash-register invoices.

3. Cases where no invoice is required

Previously businesses had to piece together several documents to work out when no invoice was required. Decree No. 254/2026/ND-CP consolidates these into a dedicated provision at Article 7 — a considerable practical improvement.

The cases include: business households and individuals preparing purchase lists; income from property leasing and digital content services supplied to foreign organisations; lottery, insurance and multi-level marketing agents already subject to withholding; reinsurance premiums, deposits, financial activities, debt sales, foreign exchange and derivatives; capital contribution in assets; asset transfers between a parent company and dependent accounting units, or on division, separation, consolidation and merger; and machinery and equipment lent as fixed assets, and tools serving processing activities, provided no payment is collected and no ownership is transferred.

Note for FDI companies: the lending of machinery and equipment for processing is particularly relevant to export processing arrangements. Review all current asset-lending contracts against both conditions — no consideration collected, and no transfer of ownership.

4. Timing of invoice issuance

The general principles in Article 9 carry over: for goods, the time of transfer of ownership or right of use; for services, the time of completion, or the time of collection if payment is taken in advance; for exports, determined by the seller, at the latest the working day following customs clearance; for multiple deliveries, an invoice per delivery.

Unchanged rules do not mean reduced risk. Incorrect invoice timing remains one of the most commonly disallowed items in tax audits.

Key change: deposits under service contracts

This is the change with the broadest impact on service contracts. Under the old rules, deposits and advances were excluded only for seven designated service types — accounting, audit, financial and tax consulting; valuation; technical survey and design; construction supervision; and investment project preparation.

From 1 July 2026, a deposit taken under the Civil Code to secure performance of a service contract does not require an invoice at the time it is received, and this applies to all service contracts, with no sector restriction.

The dividing line is legal substance, not the label on the payment order. An amount described as “advance of 10% of contract value” and offset directly against the service fee risks being treated as prepayment — in which case an invoice must be issued and output VAT declared. Review the wording in your standard contracts before relying on this treatment.

5. Mandatory invoice content

Under Article 10, an invoice must show: invoice name, symbol and number; the seller’s name, address and tax code; the buyer’s name, address and tax code, budget relationship code or personal identification number; item description, unit, quantity, unit price, amount before VAT, VAT rate, VAT amount and total payable; the seller’s signature; the time of issuance and the time of digital signing; and the tax authority code where applicable.

The buyer’s digital signature is not mandatory unless the parties agree otherwise.

Warning: invoices marked “sold to consumer”

This needs to reach purchasing, administration and anyone who travels on business.

If the buyer does not provide a name, address and personal identification number, the invoice is marked “sold to consumer”. Such an invoice cannot be used to record expenses or for tax finalisation by organisations, business households or business individuals.

The practical consequence is real: an employee pays a hotel bill on a business trip but forgets to give the company details, and the invoice is issued marked “sold to consumer” — that cost risks being non-deductible, with no input VAT credit either. For a company with many small travel and entertainment expenses, the annual total is not trivial.

Certain retail settings are exempt from recording buyer details where the customer does not provide them — invoices issued at supermarkets, shopping centres, cinemas and petrol stations.

Recommendation: issue an internal instruction requiring staff to always provide the company name, address and tax code when incurring costs, and to check the invoice before leaving the counter.

6. Item descriptions must be in Vietnamese

Names of goods and services on invoices must appear in Vietnamese. Foreign wording, if any, goes in parentheses or below the Vietnamese line in a smaller font, and each category must be itemised.

This rule is not new but compliance is poor. Many FDI companies still record item names in English or show only a part number — a frequent basis for disallowance in audits. Deal with it during this round of product-catalogue updates in your invoicing software.

7. Consolidated invoices for promotional goods and gifts

Under the old rules an invoice was required for each promotion, gift or donation. From 1 July 2026 these may be covered by a consolidated invoice for the month or quarter, aligned with the VAT declaration period — provided a detailed list is retained and produced on request.

For the conditions and mechanics, see consolidated invoices for promotional goods and gifts in 2026.

8. Correcting invoices already issued

Circular No. 91/2026/TT-BTC widens the category of errors that require only a notification rather than a replacement invoice: beyond the buyer’s name and address as before, it now covers the amount in words and certain other content — provided there is no error in the tax code, amounts, tax rate, tax amount or goods. This materially reduces the workload for high-volume issuers.

For errors that must be corrected, the seller may choose between an adjustment invoice and a replacement invoice. For cash-register invoices and invoices for assets subject to ownership registration, a replacement invoice is mandatory — adjustment is not available.

For the corresponding VAT return treatment, see amending the VAT return and indicators [37] and [38].

9. Registration and biometric verification

The registration process under Circular No. 91/2026/TT-BTC is shortened for taxpayers not flagged as risky. The step that catches companies out: the system automatically verifies the legal representative’s details, including biometric data, against the National Population Database or the electronic identification and authentication system. A mismatch means immediate rejection.

Newly established companies, or those that have just changed legal representative, should confirm the details match before filing.

10. What to do now

1. Update the legal references in all internal procedures, templates and guidance — remove citations to Decrees No. 123/2020/ND-CP and 70/2025/ND-CP.
2. Review invoicing software: personal identification number field, the “sold to consumer” marking, and new templates.
3. Standardise deposit clauses in service contracts, clearly distinguishing them from advances or prepayments.
4. Check machinery and equipment lending contracts for processing against Article 7.
5. Convert item names to Vietnamese in the product catalogue.
6. Issue internal guidance on buyer details for staff incurring travel and entertainment costs.
7. Verify the legal representative’s details against the National Population Database.

For penalties, see administrative penalties for tax and invoice violations in 2026.

This article was prepared by Trustlineax based on Law on Tax Administration No. 108/2025/QH15, Decree No. 254/2026/ND-CP dated 30 June 2026 and Circular No. 91/2026/TT-BTC. It is for information purposes only and does not replace the original legal documents or tailored tax advice.

How TrustlineAX Can Help

TrustlineAX assists FDI companies with e-invoice system registration, GDT portal setup, ERP localisation advice, and ongoing invoice management. Our accounting team ensures your e-invoices are issued correctly and on time — protecting your input VAT credits and keeping your company clear of penalties.