E-Invoices and Electronic Documents from 1 July 2026: Key Changes under Decree No. 254/2026/ND-CP and Circular No. 91/2026/TT-BTC

On 30 June 2026, the Government issued Decree No. 254/2026/ND-CP, and the Ministry of Finance issued Circular No. 91/2026/TT-BTC on e-invoices and electronic documents, providing guidance on the implementation of Tax Administration Law No. 108/2025/QH15. Both instruments took effect on 1 July 2026, and their key changes were recently introduced in detail by the Tax Department in Official Letter No. 4831/CT-CS dated 15 July 2026. This new legal framework comprehensively replaces the existing regulations on invoices and documents and affects all enterprises and household businesses currently using e-invoices.

1. Expanded and restructured scope of e-invoice users

Under Article 6 of Decree No. 254/2026/ND-CP, enterprises operating in banking, securities, cryptoassets and services supporting transactions on carbon trading exchanges have been added to the category of users of e-invoices without a tax authority code (Point b, Clause 1, Article 6).

A notable clarification is that economic organisations, household businesses and individual business operators selling goods or services directly to consumers that have already registered to use e-invoices with or without a tax authority code under Points a and b, Clause 1, Article 6 are not required to make an additional registration for cash register-generated e-invoices.

For household businesses and individual business operators, Article 6 of Decree No. 254/2026/ND-CP provides that those with annual revenue exceeding VND 1 billion, or those selling assets subject to registration of ownership or use rights, must use either e-invoices with a tax authority code or cash register-generated e-invoices connected to the tax authority. Other cases may still register to use e-invoices where needed.

2. Revised definitions of “lawful invoices” and “unlawful use of invoices”

Clauses 5 and 7, Article 3 of Decree No. 254/2026/ND-CP revise two fundamental definitions. A lawful invoice or document is one that complies with the requirements on form and content prescribed by the Decree, with the word “complete” removed compared with Decree No. 123/2020/ND-CP. The definition of “unlawful use of invoices and documents” has also been rewritten: it no longer includes cases where an invoice or document does not contain all mandatory information, while adding the use of invoices that do not reflect the actual transaction value, as well as the issuance of fictitious invoices and forged invoices. Differences in value among copies of an invoice apply only to paper invoices issued before the transition to e-invoices. This is significant when assessing input-invoice risks: an invoice missing a mandatory item of information is no longer automatically classified as being used unlawfully.

3. First-time introduction of cases where e-invoices are not required

Article 7 of Decree No. 254/2026/ND-CP is an entirely new provision listing cases in which e-invoices are not required. Notable examples include: household businesses required to prepare purchase statements for goods and services under corporate income tax regulations; household businesses deriving income from leasing real estate or providing digital content products and services to overseas organisations and individuals; lottery, insurance and multi-level marketing agents whose taxes have been withheld at source; receipts from reinsurance, deposits, issuance of valuable papers, debt sales, foreign-exchange and derivative transactions; capital contributions made with assets; internal asset transfers arising from division, separation, consolidation or merger; lending machinery and equipment free of charge; and the cases specified in Points a and b, Clause 1, Article 6 and Point b, Clause 1, Article 14 of Decree No. 181/2025/ND-CP on VAT.

4. Invoice issuance timing: additional sector-specific rules

Article 9 of Decree No. 254/2026/ND-CP introduces the following important provisions:

Where a deposit is collected under the Civil Code to secure the performance of a service contract, no invoice is required, resolving the long-standing uncertainty over invoicing deposits.

Clause 4, Article 9 expands the list of services for which invoice issuance may be deferred by seven days due to data-reconciliation requirements (Point a). These include maritime pilotage, advertising in online newspapers, digital technology services, digital platforms, information technology, cryptoassets, services supporting carbon exchange transactions, insurance, security services and passenger transportation by taxi, contract vehicle or two-wheeled motorcycle using transport-connection software, when provided to enterprise or organisational customers. Data-related products and services requiring reconciliation must be invoiced no later than two months from the month in which they arise (Point b, Clause 4).

Point o, Clause 4, Article 9 introduces specific rules for co-insurance contracts. When insurance premiums are collected, each co-insurer issues an invoice to the customer for the portion of the premium it receives. Where one insurer is authorised to collect premiums on behalf of the others, that insurer issues an invoice to the customer for the full contract value, while the other insurers issue invoices to the collecting insurer for their respective shares of the premium under the agreement. Where goods or services are purchased for claims settlement or other payments relating to the co-insurance contract and one insurer is authorised to make payments on behalf of the others, the paying insurer issues invoices when recovering the relevant amounts from the other co-insurers.

Point r, Clause 4, Article 9 introduces a Transaction Details Statement mechanism (Form No. 01/TTGD in Appendix III to Circular No. 91/2026/TT-BTC) for a range of services provided to individual consumers, including banking, payment intermediation, securities, insurance, e-wallets, e-commerce, postal services supporting e-commerce, public transport, taxis, parking and cinema services, provided that the supplier has a software system capable of managing the details of each transaction.

A seller without automated invoicing software that enters into transactions during night-time business hours may issue the invoice no later than the next working day.

5. Invoice content: stricter buyer-information requirements

Under Article 10 and the Appendix to Decree No. 254/2026/ND-CP:

Where a consumer provides their name, address and personal identification number, the invoice must include such information. A foreign national may instead provide their passport number and nationality. If the information is not provided, the invoice must state “Sale to consumer”. Importantly, an invoice without buyer information or an invoice issued to a consumer cannot be used by another organisation or household business for expense recognition or tax finalisation purposes.

A household business using the same tax identification number for multiple stores must clearly state the name, code and address of each business location on the invoice. Petrol and oil businesses must state the code and address of the business location issued by the competent authority.

For transportation services, invoices for domestic road transport must state the vehicle registration number and route. However, enterprises providing transport services or vehicle rental services under fixed-route contracts are not required to include the vehicle registration number or route (Appendix to Decree No. 254/2026/ND-CP), representing a relaxation compared with the previous requirements under Decree No. 70/2025/ND-CP.

Invoices for the sale of cars and motorcycles that contain complete buyer information, chassis number, engine number and quality certificate number constitute the basis for the tax authority to determine and notify the registration fee payable.

6. Sellers’ data-transmission obligations

Article 15 of Decree No. 254/2026/ND-CP requires sellers using e-invoices with a tax authority code to transmit data from cash register-generated e-invoices to the tax authority at the end of each day. For sellers using e-invoices without a tax authority code, Article 16 of Decree No. 254/2026/ND-CP introduces a method for transmitting the transaction-detail database using the Transaction Details Statement referred to in Point r, Clause 4, Article 9 of the Decree, within the deadline for filing the VAT return.

Article 18 of Decree No. 254/2026/ND-CP also gives buyers the right to participate in invoice-use incentive programmes organised by sellers or tax authorities and confirms that an invoice requested and received by a buyer from a seller constitutes a basis for determining the seller’s tax obligations to the State Budget.

7. System incidents and force majeure

Article 14 of Decree No. 254/2026/ND-CP provides that, where the tax authority’s invoice-coding system experiences an incident, the Tax Department must activate the backup system and publicly announce the affected scope and expected resolution time. In force majeure cases under Clause 21, Article 4 of the Tax Administration Law, or where risks are not attributable to the seller, the seller may issue and submit invoices to the tax authority within three working days from the date the incident is resolved. Such delay is treated as arising from force majeure and is not subject to penalties for late issuance or submission.

8. E-commerce: new rights for sellers on platforms

Article 17 of Decree No. 254/2026/ND-CP gives sellers the right to request e-commerce and digital platform operators to provide buyer information, transaction information, delivery times and confirmation that orders have been completed for invoicing purposes. Correspondingly, Article 19 of Decree No. 254/2026/ND-CP imposes this responsibility on organisations authorised to issue invoices, including e-commerce platform operators. Article 9 of Circular No. 91/2026/TT-BTC allows household businesses and individual business operators to authorise economic organisations, including e-commerce platform operators, to issue e-invoices. The authorised organisation must notify the tax authority of the list of authorising household businesses using Form No. 01/ĐKTĐ-HĐĐT in Appendix III to Circular No. 91/2026/TT-BTC.

9. Electronic documents: a range of new provisions

Under Article 24 of Decree No. 254/2026/ND-CP, no personal income tax withholding certificate is required for income earned by individual investors from securities transfers, capital investments, digital assets, gold bars, copyright, commercial franchising, winnings, inheritances or gifts, provided that the paying organisation has withheld and paid the relevant tax at source.

The Decree adds two new articles: Article 26 on methods for preparing electronic documents, and Article 27 on connecting and transmitting electronic-document data to the tax authority. Where a technical incident occurs, the data must be transmitted within three working days after the incident is resolved. Article 28 adds two categories eligible for free electronic-document services: household businesses employing fewer than ten employees that are not required to use e-invoices, and household businesses eligible for free e-invoice services under Article 11 of Decree No. 254/2026/ND-CP. Article 29 replaces reports on receipt usage with a requirement to submit a summary of e-receipt data on the date the receipt is issued.

10. Incentives for obtaining invoices and rewards for reporting violations

Article 41 of Decree No. 254/2026/ND-CP, a new provision mandated by the Tax Administration Law, provides rewards for consumers who report sellers that fail to issue and provide invoices, provided that the information is truthful and sufficiently substantiated and the tax authority has issued an administrative penalty decision based on the report. Reward amounts, procedures and formalities are governed by Article 14 of Circular No. 91/2026/TT-BTC.

In parallel, Article 13 of Circular No. 91/2026/TT-BTC maintains the monthly and year-end “Lucky Invoice” programme, under which cash prizes are awarded for invoices issued to consumers. The total annual funding for incentive measures must not exceed VND 150 billion (Clause 2, Article 13).

11. Registration, suspension of use and correction of erroneous invoices under Circular No. 91/2026/TT-BTC

Registration and changes to registered information (Article 6): Changes to e-invoice registration information, other than discontinuation or temporary suspension, must be made using Form No. 01/ĐKTĐ-HĐĐT in Appendix III to Circular No. 91/2026/TT-BTC and are subject to biometric verification. The time limit for providing explanations or supplementary information at the tax authority’s request has been extended from two to three working days.

High-risk cases (Article 7): The criteria relating to registered office addresses have been revised. Registration at an apartment that is not permitted to be used for business purposes, or at a location without a specific address under the administrative geography system, is considered high risk, except in the case of individual business operators.

Discontinuation and temporary suspension (Article 8): A household business granted a tax identification number before 1 July 2025 whose tax registration information does not match the National Population Database will be required to provide supplementary information within ten working days. Failure to do so will result in the temporary suspension of its use of e-invoices. Where a taxpayer has responded to a second notice but cannot demonstrate that its invoices have been used in accordance with regulations, the tax authority will issue a notice discontinuing e-invoice use. The tax authority will also send notices of discontinuation or temporary suspension to the party authorised to issue invoices.

Handling incorrectly issued invoices (Article 10): Where the name, address, amount in words or other information is incorrect, but the tax identification number, amount, tax rate, tax amount and goods or services are correct, the seller only needs to notify the buyer and submit Form No. 04/SS-HĐĐT in Appendix III to the tax authority; the invoice does not need to be reissued. In certain cases, including data transmitted through a summary statement, a Transaction Details Statement or transactions conducted through an e-commerce platform, the seller is not required to prepare a written agreement before adjusting or replacing the invoice. An incorrectly issued cash register-generated invoice or invoice for the sale of an asset subject to ownership registration must be replaced.

Article 10 of Circular No. 91/2026/TT-BTC also introduces several special handling rules. Where a Transaction Details Statement previously submitted to the tax authority is incomplete or incorrect, a supplementary Transaction Details Statement must be submitted. For adjustments to wholesale electricity prices between Vietnam Electricity and power corporations, and between power corporations and power companies, any difference determined upon settlement must be reflected in a newly issued invoice that accurately represents the underlying economic transaction. Where an insurance company has issued invoices for insurance premiums that remain unpaid, it must use the unpaid-premium data to issue a consolidated adjustment invoice for the previous month’s unpaid premiums, accompanied by a list of the relevant invoice numbers, amounts and adjusted tax amounts. Where natural gas is sold in Vietnam under a contract denominated in a freely convertible foreign currency but payment and invoicing are made in Vietnamese dong, an invoice that was correctly issued must subsequently be adjusted for any difference arising when the actual payment is converted into Vietnamese dong.

Similarly, Article 20 of Circular No. 91/2026/TT-BTC provides guidance on handling incorrectly prepared electronic documents. Where the name, address, amount in words or other information is incorrect, but the tax identification number and amount are correct, the issuer must notify the recipient using Form No. 04/SS-CTĐT and is not required to reissue the document. In other cases, a replacement electronic document must be prepared.

Invoices issued on a transaction-by-transaction basis (Article 15): A taxpayer eligible to receive a coded invoice for the sale of public assets is not required to declare or pay the tax arising on the invoice application. A household business with a fixed business location, including an e-commerce business or a business with multiple stores in different provinces, must submit its application to the tax authority directly managing the head office stated in its business registration certificate. A household business without a fixed business location must submit its application to the tax authority where it resides.

12. Electronic stamps and access to invoice information

Article 21 of Decree No. 254/2026/ND-CP adds responsibilities for the directly managing tax authority in managing electronic-stamp data for the prescribed retention period. It also requires tax authorities, relevant State management agencies and sellers to communicate, provide guidance and facilitate consumers’ exercise of their invoice-related rights and responsibilities.

Regarding access to and use of e-invoice information, Article 36 of Decree No. 254/2026/ND-CP expands the users of such information to include organisations authorised under civil law by economic organisations, household businesses and individual business operators acting as sellers. Article 37 of Decree No. 254/2026/ND-CP adds parties authorised to issue invoices to the list of information users and introduces direct queries to the Tax Administration Information System, provided that the relevant criteria applicable to organisations providing e-invoice data receipt, transmission and storage services are satisfied.

13. Transitional provisions requiring immediate attention

Under Article 44 of Decree No. 254/2026/ND-CP, tax authority-printed invoices ceased to be valid from 1 July 2026. Any unused invoices must be destroyed in accordance with the procedures set out in Circular No. 91/2026/TT-BTC. Self-printed and externally printed paper receipts under Decree No. 123/2020/ND-CP may continue to be used until 31 December 2026. From 1 January 2027, all remaining paper receipts must be destroyed and replaced by e-receipts in the prescribed standard format.

Under Article 24 of Circular No. 91/2026/TT-BTC, where an invoice issued under Decree No. 51/2010/ND-CP or Decree No. 04/2014/ND-CP contains an error, the parties must prepare a written agreement and issue a new replacement e-invoice. Invoices issued under Decree No. 123/2020/ND-CP, Decree No. 70/2025/ND-CP and Circular No. 32/2025/TT-BTC must be adjusted or replaced in accordance with the applicable regulations.

💡 Immediate actions for enterprises

1. Review the applicable invoice regime under Articles 6 and 7 of Decree No. 254/2026/ND-CP, particularly for household businesses with annual revenue exceeding VND 1 billion and enterprises in newly added sectors such as cryptoassets and carbon trading exchanges.
2. Update consumer invoicing procedures by collecting personal identification numbers or stating “Sale to consumer”. Note that invoices without buyer information cannot be used for expense recognition.
3. Review invoice issuance timing for specific services, including data reconciliation, deposits, co-insurance and night-time transactions, as well as the Transaction Details Statement mechanism under Point r, Clause 4, Article 9 of Decree No. 254/2026/ND-CP, where applicable.
4. Revise procedures for handling erroneous invoices under Article 10 of Circular No. 91/2026/TT-BTC, including updating Form No. 04/SS-HĐĐT and removing the written-agreement step in cases where it is no longer mandatory.
5. Immediately deal with any remaining tax authority-printed invoices, which ceased to be valid from 1 July 2026, and plan the transition from paper receipts before 31 December 2026 in accordance with Article 44 of Decree No. 254/2026/ND-CP.

>>> Download Decree 254/2026/ND-CP

>>> Download Circular 91/2026/TT-BTC

>>> Download Official Letter No. 4831/CT-CS

This newsletter has been prepared by Crowe Vietnam for general information and reference purposes only. It does not constitute legal, tax or accounting advice in relation to any specific circumstances. Laws and regulations may be amended or may no longer be in effect at the time this newsletter is accessed. Readers should consult the original legal instruments and seek advice from Crowe Vietnam’s professionals before applying the information to any particular situation. Crowe Vietnam accepts no responsibility for any loss arising from reliance on the information contained in this newsletter without obtaining appropriate professional advice.