Key Highlights of Changes in Vietnam's new e-invoicing rules effective from 01 June 2025

Vietnam has recently introduced Decree 70/2025/ND-CP, effective June 1, 2025, which amends and supplements several provisions of Decree 123/2020/ND-CP regarding invoices and documents. This decree brings significant changes to the electronic invoicing (e-invoice) landscape in Vietnam.

Key Highlights of Changes in Invoicing Regulations effective from 01 June 2025

Key highlights include:

1. Expansion of eligible users for e-invoices

Foreign service providers (without a permanent establishment in Vietnam) engaged in e-commerce, digital platforms, or cross-border services may now voluntarily register to use e-invoices under the new regulation.

2. Authorization for e-invoice issuance by third parties

Household businesses and individuals may authorize a third party to issue e-invoices on their behalf.

The invoice must display the name of the authorizing party.
A written agreement must specify the purpose, duration, and payment method.
The tax authority must be notified of such authorization when registering e-invoice usage.
If using invoices without a tax authority’s code, data must be sent via an authorized service provider.

3. Adjustments to invoice issuance timing for specific industries

The draft proposes greater flexibility in determining invoice timing, especially for sectors with frequent or bulk transactions:

Mass/bulk service providers (e.g., e-commerce, banking, advertising, securities): Invoices may be issued after data reconciliation, but no later than:
- The 7th day of the following month, or
- 7 days after the end of an agreed settlement period.
Insurance services: Invoice to be issued when insurance revenue is recognized.
Lottery ticket distribution: Invoices must be issued after unsold tickets are recovered and before the next draw.
Casino & prize-winning electronic gaming:
- Invoice issuance deadline: 1 day after revenue recognition day (00:00–23:59 daily).
- Revenue data (net of player refunds) must be submitted alongside e-invoice data.
Loan interest collection:
- Invoice to be issued per interest collection period as agreed in the credit contract.
- If the borrower prepays interest: invoice is issued at prepayment time.
- If interest is overdue and off-balance sheet: invoice only upon actual collection.
Currency exchange and foreign remittance services:
- Invoice timing is the moment of transaction completion.
Gas pipeline sales (natural gas, coal gas, etc.):
- Invoice to be issued at volume confirmation time, but no later than the last day of the tax declaration deadline of the month in which the transaction occurred.

4. Clarification on e-signature timing for e-invoices

The digital signature timestamp must follow the DD/MM/YYYY Gregorian format.
If signing time differs from invoice issuance time, the signature and data submission to tax authority must occur by the next working day.
Seller declares tax based on invoice issuance date; buyer declares tax based on valid invoice receipt date.

5. Use of e-invoices generated from point-of-sale (POS) systems

Businesses engaging in direct-to-consumer sales (retail, supermarkets, restaurants, cinemas, personal services, etc.) are required to use e-invoices generated from cash registers or POS systems that are connected to the tax authority.

6. Two additional cases eligible for one-off tax-authority coded e-invoices

Entities may apply for individual issuance of e-invoices (with tax authority code) per transaction if:

They are undergoing bankruptcy proceedings but still conducting business under court supervision.
They are under tax risk review, specifically in the process of providing clarifications or documents.

7. Changes in Handling Incorrect E-invoices

Seller-Initiated Adjustments:

If the buyer's name/address is incorrect but the tax code and other details are correct:
- No need to reissue the invoice.
- Notify both buyer and tax authority using Form 04/SS-HĐĐT.
If errors involve tax code, amount, tax rate, or product/service description:
- Seller can choose to adjust or replace the e-invoice:
  - Adjustment: Issue a new e-invoice with the note “Adjustment for invoice form no... symbol... number... date...”
  - Replacement: Issue a new e-invoice with the note “Replacement for invoice form no... symbol... number... date...”
- For invoices without a tax code, send directly to the buyer; for those with a code, submit to the tax authority for re-issuance.
- One adjustment/replacement invoice can be issued for multiple incorrect invoices of the same buyer in a month, with an attached summary list (Form 01/BK-ĐCTT).
- A written agreement is required between buyer and seller for businesses; for individuals, seller must inform buyer or post on website.

Tax Authority-Initiated Adjustments:

If errors are found by the tax authority, it will notify the seller using Form 01/TB-RSĐT.
Seller must review and rectify the invoice per Section 1.

Notification Acknowledgement:

If seller notifies tax authority under Form 04/SS-HĐĐT, the Tax Department's portal will automatically issue a receipt notice (Form 01/TB-SSĐT).

Special Cases for Adjustments:

Price/value changes after final settlements due to state agency conclusions: issue new e-invoice for the difference.
Trade discounts based on quantity/sales volume: adjust on final or next invoice, ensuring the discount doesn't exceed invoiced amount.
Goods/service return:
- Seller issues adjustment invoice, unless buyer issues return invoice by agreement.
- For registered property (e.g., vehicles), buyer must issue return invoice if returning the registered item.
- Insurance refunds/commission reductions: seller issues adjustment invoice with written agreement; store with original invoice.
Service prepayment reversal: seller issues adjustment if a service contract is canceled.
Bank/financial institutions refunding card service fees: issue adjustment invoice (no reference to original invoice required).
Telecom services paid by prepaid card: telecom company issues adjustment invoice based on internal data or agreements.

Principles for Adjusted/Replacement Invoices:

If initial error was corrected via adjustment or replacement, continue using that same method for future corrections.
If the original invoice lacks form/symbol/number, only adjustment is allowed.
Adjusted invoice values must reflect actual change: increase (positive), decrease (negative).
Tax declaration for adjustments/replacements:
- For replacements (1.b): report in the original invoice’s tax period.
- For adjustments (Section 4): seller reports in adjustment period; buyer reports in the period they receive the adjustment invoice.