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E-Invoices Types Under Current Regulations in Vietnam

E-Invoices Types Under Current Regulations in Vietnam

Many Amazon and Etsy sellers may already issue invoices for every transaction but still need to make large-scale adjustments or replacements during tax reconciliation in Vietnam. The issue is often not missing invoices but using types of e-invoices that do not match the applicable tax calculation method or the nature of the underlying transaction. 

From July 1, 2026, Decree 254/2026/ND-CP officially replaces Decree 123/2020/ND-CP and sets out the types of e-invoices under the Law on Tax Administration No. 108/2025/QH15. Businesses therefore need to understand the different invoice types, who they apply to, and when they should be used so that sales data, accounting records, and tax returns remain consistent.

1. Key Factors to Consider When Issuing E-Invoices in Vietnam

When order volumes are still manageable, sellers can often review transactions individually and confirm whether an invoice has been issued. As sales scale, particularly across multiple marketplaces or markets, this approach becomes increasingly difficult to manage. 

Businesses then need to determine:

  • Which transactions require an invoice: Not all orders are handled in the same way, particularly cancelled, returned, or adjusted transactions.

  • Which type of invoice should be used: Under Article 8 of Decree No. 254/2026/ND-CP, the appropriate invoice type is determined based on the seller’s status, applicable tax calculation method, and the nature of the transaction. Businesses therefore need to determine the appropriate invoice type before issuance, particularly for export transactions and e-commerce sales. 

  • Whether the invoice should carry a tax authority code in Vietnam: Under Article 6 of Decree No. 254/2026/ND-CP, economic organizations, household businesses, and individual businesses are generally required to use types of e-invoices with a tax authority code. However, certain enterprises, including those engaged in e-commerce, may use types of e-invoices without a tax authority code if they meet the prescribed requirements for technology infrastructure, invoicing software, and invoice data transmission.  

  • Invoice issuance timing: Article 9 of Decree 254/2026/ND-CP sets different issuance points depending on the transaction. For ordinary sales of goods, the invoice is generally issued when ownership or the right to use the goods is transferred to the buyer. For exported goods, the seller determines the issuance time, but no later than the next working day following customs clearance. Sellers should therefore identify the underlying transaction and applicable legal trigger rather than relying only on marketplace payout dates.

2. Types of E-Invoices Under Decree 254/2026/ND-CP

Article 8 of Decree 254/2026/ND-CP provides that the types of e-invoices used by the seller depends on the applicable tax method and the nature of the business activity.

In other words, the invoice type is determined by the seller’s tax treatment and business model, rather than by the buyer’s preference.

2.1. Value-Added Tax Invoice

Under Clause 1, Article 8 of Decree 254/2026/ND-CP, value-added tax invoices are used by economic organizations that declare VAT using the credit method.

This type of invoice applies to activities such as domestic sales of goods and services, international transportation, sales into non-tariff zones, exports of goods, provision of services overseas, and certain e-commerce activities carried out by foreign suppliers without a permanent establishment in Vietnam.

A key feature of a VAT invoice is that the tax component is shown separately and clearly, including the VAT rate, VAT amount, and total amount payable including tax. Based on this information, the buyer may use the VAT amount stated on the invoice as the basis for input VAT deduction, provided the applicable conditions are met.

In addition to standard VAT invoices, the regulations also recognize certain other forms, such as VAT invoices combined with tax refund declarations and VAT invoices combined with receipts.

2.2. Sales Invoice

Sales invoices are used by economic organizations, household businesses, and individual business operators that calculate VAT using the direct method.

Unlike VAT invoices, sales invoices do not separately state a VAT amount for the buyer to deduct because tax is calculated directly on the seller’s revenue.

The main distinction between a VAT invoice and a sales invoice therefore lies in the seller’s VAT calculation method. If a business changes from the direct method to the credit method, the applicable invoice type must also change accordingly.

2.3. E-Commercial Invoice

Under Clause 3, Article 8 of Decree 254/2026/ND-CP, an e-commercial invoice applies to economic organizations, household businesses, and individual business operators that export goods or provide services overseas, provided they are able to transmit commercial invoice data electronically to the tax authority.

An e-commercial invoice must also meet the content requirements under Article 10 of Decree 254/2026/ND-CP. These generally include basic information such as:

  • invoice name and number;

  • seller and buyer information;

  • description of goods or services;

  • quantity, unit price, and transaction value;

  • tax information, where applicable;

  • invoice issuance time; and

  • other required information depending on the transaction.

The invoice must also follow the required standardized data format so that it can be transmitted electronically to the tax authority.

In this context, “e-commercial invoice” refers specifically to a commercial invoice issued in electronic form for export transactions. The term does not refer to an invoice automatically applicable to all orders processed through an e-commerce marketplace.

 

This type of invoice does not necessarily require the buyer’s personal identification number or digital signature. For exported goods, the seller may determine the issuance time, but the invoice must be issued no later than the next working day following customs clearance.

2.4. Public Asset Sales Invoice and National Reserve Goods Sales Invoice

These invoice types are used when government agencies or organizations sell public assets or national reserve goods. They are generally not relevant to marketplace sellers.

2.5. Other Types of Invoices and Documents Under Invoice Regulations

The regulatory framework also covers other types of e-invoices and invoice-related documents. Under Clause 6, Article 8 of Decree No. 254/2026/ND-CP, these include stamps, tickets, cards, air transportation charge receipts, international freight charge documents, and banking service fee documents, subject to the conditions prescribed by law.

Clause 7, Article 8 Decree No. 254/2026/ND-CP further provides for warehouse delivery notes used for internal transportation and goods delivered to sales agents, which are subject to the same registration, use, and management requirements as invoices.

For Amazon and Etsy sellers, these documents are less commonly encountered than VAT invoices, sales invoices, or electronic commercial invoices, but they may still apply depending on the nature of the transaction.

3. Classification by Tax Authority Management Method in Vietnam

In addition to classification by invoices and types of e-invoices are also categorized based on how invoice data is transmitted to and managed by the tax authority in Vietnam.

  • Types of e-invoices with a tax authority code: These invoices are issued with a code from the tax authority before being sent to the buyer. The invoice can therefore only be officially issued after the coding process has been completed.

  • E-invoices without a tax authority code: These invoices are created and sent directly to the buyer by the seller, while invoice data is transmitted to the tax authority in accordance with the prescribed process. Decree 254/2026/ND-CP expands the group of eligible users to include certain businesses operating in e-commerce, finance, and securities, provided they meet the required technology and data transmission conditions and are not classified as high-risk taxpayers.

  • E-invoices generated from cash registers: These are designed for businesses that sell directly to consumers, with invoice data generated from cash registers connected to the tax authority.

For household businesses and individual business operators in Vietnam, revenue is an important factor in determining the applicable invoicing method. Where annual revenue exceeds VND 1 billion, the business operator must use either types of e-invoices with tax authority codes or types of e-invoices generated from cash registers with data connections to the tax authorities. Further details on the applicable categories of taxpayers are summarized by the Government Electronic Newspaper based on Decree No. 254/2026/ND-CP.

4. Determining the Appropriate Invoice Type for Amazon and Etsy Sellers

For Amazon and Etsy sellers, the correct invoice type is not determined by the marketplace itself.

Instead, businesses need to consider their legal form, VAT calculation method, and the nature of each transaction. Understanding these factors is essential before determining which types of e-invoices should be used.

4.1. Businesses Applying the VAT Credit Method

Businesses applying the VAT credit method use VAT invoices for transactions that require this invoice type. For exported goods, businesses may use electronic commercial invoices if they meet the prescribed requirements for invoice issuance and data transmission. Where these requirements have not been met, businesses may use electronic VAT invoices or electronic sales invoices, depending on the applicable circumstances.

4.2. Household Businesses and Individual Business Operators

For transactions subject to sales invoice requirements, household businesses and individual business operators that declare and calculate VAT under the direct method must use sales invoices in accordance with Clause 2, Article 8 of Decree No. 254/2026/ND-CP.

However, where household businesses or individual business operators export goods or provide services overseas and meet the requirements for electronically transmitting commercial invoice data to the tax authorities, they may use electronic commercial invoices under Clause 3, Article 8 Decree No. 254/2026/ND-CP.

In addition, household businesses and individual business operators with annual revenue exceeding VND 1 billion, or those selling assets subject to ownership or usage rights registration, must use e-invoices with tax authority codes or types of e-invoices generated from cash registers connected to the tax authorities, pursuant to Point d, Clause 1, Article 6 Decree No. 254/2026/ND-CP.

4.3. Determining the Invoice Type Based on the Nature of the Export Transaction

The fact that a buyer is located overseas does not mean that all transactions conducted through Amazon or Etsy require the same invoice type. Businesses must determine whether a transaction involves the export of physical goods or the provision of services or digital products to overseas customers, as each may be subject to different requirements regarding invoice types and issuance dates.

For exported goods, businesses must also consider customs clearance requirements and their ability to transmit electronic commercial invoice data to the tax authorities. For services or digital products supplied to overseas customers, businesses must accurately determine the nature of each transaction before selecting the appropriate types of e-invoices.

An important consideration for household businesses and individual business operators is that not all digital products or services supplied overseas give rise to an obligation to use types of e-invoices. Clause 2, Article 7 of Decree No. 254/2026/ND-CP stipulates that household businesses and individual business operators earning income from the provision of digital information content products or services, including entertainment, video games, digital films, digital images, digital music, and digital advertising, to overseas organizations or individuals are not required to use e-invoices in these circumstances.

4.4. Do Not Use Marketplace Settlement Amounts as the Basis for Invoice Value

One important point for marketplace sellers is that the invoice value should not be determined solely by the amount transferred by Amazon or Etsy.

Marketplace payouts may already reflect deductions for platform fees, processing fees, refunds, or other adjustments, while the invoice still needs to reflect the actual value of the underlying sale in accordance with the applicable rules.

Businesses should therefore separate order value, revenue, and marketplace fees before issuing invoices and ensure that invoice data can be reconciled with accounting records and transaction data.

This also provides a stronger basis for selecting the correct invoice type and reducing discrepancies in invoice management.

5. Common Mistakes When Selecting an Invoice Type

Choosing the correct invoice type depends not only on the business model but also on the applicable tax method, the nature of the transaction, and the way revenue is recorded.

Some errors may not be immediately visible and only become apparent when businesses reconcile their data later. Regular reviews are therefore important to identify and correct issues early.

Common mistakes include:

  • Using an invoice type that does not match the applicable tax method: For example, a business that has switched to the VAT credit method may continue using sales invoices even though the invoice type is no longer appropriate.

  • Misunderstanding e-commercial invoices: Some sellers assume that every order placed through Amazon or Etsy requires an e-commercial invoice, even though the appropriate invoice type still depends on the transaction itself and whether the relevant legal conditions are met.

  • Using the marketplace settlement amount as revenue for invoicing: Marketplace payouts typically already include deductions for fees, refunds, and other adjustments. Using the net payout amount as the invoice value may therefore understate the actual transaction value.

  • Failing to monitor the revenue threshold for household businesses and individual business operators: When annual revenue exceeds VND 1 billion, the business operator needs to review the invoicing method to ensure continued compliance.

  • Applying inconsistent exchange rates: Revenue figures may differ across invoices, accounting records, and tax returns if businesses use different exchange-rate methods without a consistent policy.

These issues show that understanding invoice types alone is not enough. Businesses also need to control the quality of input data, apply consistent revenue recognition methods, and ensure that sales data, invoice records, accounting books, and tax returns remain aligned.

6. Standardizing Multi-Marketplace Data to Support Correct E-Invoicing

hành của doanh nghiệp.

When selling across multiple marketplaces, businesses may need to process thousands of orders each month alongside various platform fees and other adjustments. Relying on spreadsheets to determine revenue, reconcile data, and issue invoices for individual transactions can be time-consuming and prone to errors.

Genbook, a partner of Sliner, is a sales data and accounting management solution for Amazon and Etsy sellers. Genbook consolidates marketplace data and standardizes revenue, fees, returns, and other adjustments in line with accounting practices, providing a consistent data source for invoice issuance and accounting records.

GenInvoice is an e-invoicing feature integrated into Genbook that supports automated e-invoice issuance for Amazon and Etsy orders, reducing manual data entry and helping businesses process invoices according to the applicable invoice type for each transaction.

Contact the Genbook team to learn more about data management and e-invoice automation solutions suited to your business operations.