Under Article 7 of Circular No. 91/2026/TT-BTC, effective from 01/7/2026, the tax authority will identify a taxpayer as high-risk when registering to use e-invoices if the taxpayer exhibits any of the following indicators, even where the registration information matches and the taxpayer has completed confirmation on the system within the prescribed deadline:
(i) Invoice fraud or trading: the taxpayer's owner or legal representative, the representative of a household business, an individual business operator, or the owner of a private enterprise is concurrently the owner or representative of another taxpayer for which a competent state authority has issued a conclusion on invoice fraud or invoice trading recorded in the tax authority's database.
(ii) Suspicious transactions: the taxpayer's owner or legal representative, the representative of a household business, an individual business operator, or the owner of a private enterprise is included in a list of persons with suspicious transactions under the 2022 Law on Anti-Money Laundering.
(iii) Unclear head-office address: the taxpayer registers a head-office address without a specific address under the relevant administrative boundaries, or at an apartment in a condominium building (excluding an apartment or part of a condominium building permitted for business use), except for individual business operators.
(iv) Connection with a non-compliant or inactive taxpayer: the taxpayer's legal representative or owner is concurrently the representative or owner of another taxpayer whose TIN status is inactive but whose TIN deactivation procedures have not been completed, whose status is "not operating at the registered address", or who has committed tax, invoice, or document violations as prescribed in Circular No. 94/2026/TT-BTC of the Minister of Finance.
(v) Other risk indicators: the taxpayer has other risk indicators identified by the tax authority under Circular No. 94/2026/TT-BTC and has been notified to provide an explanation.