Effective July 1, 2026,
Decree No. 254/2026/ND-CP replaces
Decree No. 123/2020/ND-CP, establishing specific requirements regarding eligible users and the conditions for using e-invoices with and without tax authority codes.
The applicable invoice type depends on the taxpayer's status, system capabilities, and relevant regulatory requirements. This article explains the differences between the two types of e-invoices and outlines the eligibility requirements for each under Vietnamese regulations effective in 2026.
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Differences Between E-Invoices With and Without Tax Authority Codes
Both e-invoices with and without tax authority codes are legally valid when they comply with applicable regulations. However, the main differences lie in the tax authority's code issuance process, data transmission requirements, and eligibility criteria.
1.1. E-Invoices With Tax Authority Codes
An e-invoice with a tax authority code is
an electronic invoice assigned to a code by the tax authority before the seller sends it to the buyer. The tax authority code consists of a unique transaction number generated by the tax authority's system and an encrypted character string created by the tax authority based on the information entered by the seller on the invoice.
The tax authority assigns a code to the invoice before it is sent to the buyer. However, receiving a tax authority code does not relieve the seller of responsibility for ensuring the accuracy of the invoice content. Sellers must therefore verify the information provided and the details recorded on the invoice before issuing it.
1.2. E-Invoices Without Tax Authority Codes
An e-invoice without a tax authority code is
an electronic invoice issued by an organization selling goods or providing services and sent to the buyer without a code assigned by the tax authority. For this type of invoice, the seller prepares, digitally signs, and sends the invoice to the buyer without waiting for the tax authority to assign a code. However, the invoice data must still be transmitted to the tax authority in accordance with applicable regulations. Businesses are responsible for ensuring the completeness, accuracy, and timely transmission of invoice data.
1.3. Comparison of E-Invoices With and Without Tax Authority Codes
E-invoices with and without tax authority codes differ in their issuance procedures, data transmission requirements, technical infrastructure, and scope of application. The two types can be identified by their invoice symbols. Under Appendix I of
Circular No. 91/2026/TT-BTC, an e-invoice symbol consists of six characters, with the first character indicating the invoice type:
“C” for invoices with tax authority codes and
“K” for invoices without tax authority codes.
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Criteria
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E-Invoices With Tax Authority Codes
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E-Invoices Without Tax Authority Codes
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First character of the invoice symbol
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C
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K
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Invoice preparation and delivery process
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The seller prepares the invoice and submits it to the tax authority for code assignment before sending it to the buyer.
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The seller prepares, digitally signs, and sends the invoice directly to the buyer without obtaining a tax authority code. However, invoice data must still be transmitted to the tax authority as required.
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Technical infrastructure requirements
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Systems or software capable of preparing and submitting invoices for tax authority code assignment.
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Accounting and e-invoicing software capable of preparing, retrieving, storing, and transmitting invoice data.
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Scope of application
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Applies to entities specified in Point (a), Clause 1, Article 6 of Decree No. 254/2026/ND-CP, subject to the prescribed exceptions.
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Applies to businesses and organizations meeting the requirements under Point (b), Clause 1, Article 6 of Decree No. 254/2026/ND-CP, subject to the prescribed exclusions.
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Entities Generally Using Coded E-Invoices and Cases Requiring Conversion
E-invoices with tax authority codes apply to economic organizations, other organizations, business households, and individual business operators under Point (a), Clause 1, Article 6 of
Decree No. 254/2026/ND-CP, as well as taxpayers identified by the Ministry of Finance as posing a high tax risk when selling goods or providing services, subject to the prescribed exceptions. Four cases are particularly relevant:
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General category: Economic organizations, other organizations, business households, and individual business operators selling goods or providing services, except for the specific cases provided for in Points (b) and (c), Clause 1, Article 6 of Decree No. 254.
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Household businesses and individual business operators with annual revenue exceeding VND 1 billion: Must use e-invoices with tax authority codes or e-invoices generated from cash registers connected to the tax authority's data system. This requirement has been applied since January 1, 2026, pursuant to Clause 5, Article 8 of Decree No. 68/2026/ND-CP, as amended by Decree No. 141/2026/ND-CP.
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Household businesses and individual business operators selling assets subject to ownership or usage rights registration: are required to use e-invoices pursuant to Point d, Clause 1, Article 6 of Decree No. 254/2026/ND-CP, effective July 1, 2026.
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High-risk taxpayers: Taxpayers currently using e-invoices without tax authority codes who receive a conversion notice from the tax authority using Form No. 01/TB-KTT in Appendix IV of Circular No. 91/2026/TT-BTC must update their e-invoice registration information within 10 working days of the tax authority's notification (Clause 2, Article 11 of Circular No. 91/2026/TT-BTC).
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Businesses voluntarily switching from e-invoices without tax authority codes to those with tax authority codes (Clause 1, Article 11 of Circular No. 91/2026/TT-BTC).
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Entities Eligible to Use E-Invoices Without Tax Authority Codes
Under Point (b), Clause 1, Article 6 of
Decree No. 254/2026/ND-CP, businesses and economic organizations falling within the specified categories may use e-invoices without tax authority codes if they meet the applicable requirements. There are two main groups:
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Businesses operating in specified sectors: These include electricity, petroleum, postal services, telecommunications, clean water supply, banking and finance, securities, crypto-assets, services supporting transactions on carbon exchanges, insurance, healthcare, e-commerce, supermarkets, trading, and transportation activities as specified in Point (b), Clause 1, Article 6 of Decree No. 254/2026/ND-CP.
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Economic organizations meet technical infrastructure requirements: These organizations have conducted or will conduct electronic transactions with the tax authority and possess the necessary IT infrastructure, accounting systems, and e-invoicing software to prepare, retrieve, and store invoices while ensuring that invoice data can be transmitted to buyers and the tax authority.
Exclusions: Taxpayers classified as high-risk under Ministry of Finance regulations or those already registered to use e-invoices with tax authority codes are not eligible to use e-invoices without tax authority codes under Point (b), Clause 1, Article 6. The determination of high-risk status and the procedures for switching invoice types are governed by
Circular No. 91/2026/TT-BTC.
When using e-invoices without tax authority codes, businesses prepare, digitally sign, and send invoices to buyers electronically through a method agreed upon by both parties. They must also fulfill their obligations to transmit invoice data to the tax authority in accordance with applicable regulations.
The criteria for identifying high-risk taxpayers during e-invoice registration are specified in Article 7 of
Circular No. 91/2026/TT-BTC. The identification of high-risk cases requiring a switch from e-invoices without tax authority codes to those with tax authority codes is governed by
Circular No. 94/2026/TT-BTC and Clause 2, Article 11 of
Circular No. 91/2026/TT-BTC.
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E-Invoicing Regulations for E-Commerce Sellers
E-commerce sellers must determine their legal status and assess the applicable eligibility requirements before choosing between e-invoices with and without tax authority codes.
4.1. Business Households and Individual Business Operators
Business households and individual business operators selling on e-commerce platforms such as
Amazon,
Etsy,
Shopee, or
TikTok Shop must comply with the regulations applicable to their taxpayer category rather than automatically assuming they can use e-invoices without tax authority codes simply because they operate in the e-commerce sector.
Under Point (d), Clause 1, Article 6 of
Decree No. 254/2026/ND-CP, business households and individual business operators with annual revenue exceeding VND 1 billion must use e-invoices with tax authority codes or e-invoices generated from cash registers connected to the tax authority's data system. The applicable invoice type for these taxpayers is determined by their revenue level and the regulations governing business households and individual business operators.
4.2. Businesses Selling Across Multiple Channels
Businesses selling through multiple channels may use e-invoices without tax authority codes if they fall within the prescribed industries or eligible categories, meet the applicable IT infrastructure and software requirements, and are not classified as high-risk taxpayers or registered to use e-invoices with tax authority codes.
For multichannel sellers, e-invoicing procedures should be supported by effective transaction and invoice data controls:
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Monitor eligibility requirements: Businesses using e-invoices without tax authority codes should be aware that a high-risk tax classification may require them to switch to e-invoices with tax authority codes within the prescribed timeframe.
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Reconcile invoice and transaction data: Sales revenue, refunds, platform fees, and settlement payments may be recorded at different times. Businesses need to reconcile these data sources to identify and resolve discrepancies.
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Review and correct invoice errors: When an invoice needs to be adjusted or replaced, businesses should be able to retrieve the relevant transaction information and original supporting documents to follow the correct procedures under Circular No. 91/2026/TT-BTC.
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Ensure proper invoice delivery and data transmission: Depending on the applicable invoice type, businesses must follow the required procedures for sending invoices to buyers and transmitting invoice data to the tax authority.
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Genbook Supports E-Commerce Accounting and Invoice Data Management
For e-commerce sellers, managing order, invoice, and revenue data across multiple platforms is essential for transaction reconciliation and accounting operations. Maintaining consistent data controls throughout invoice preparation, issuance, and reconciliation helps reduce errors, regardless of whether a business uses e-invoices with or without tax authority codes.
Genbook is an accounting software solution that helps standardize transaction data from e-commerce platforms, automate journal entries, and reconcile revenue and fees to support accounting records and financial reporting. Its
GenInvoice feature also helps
Amazon and
Etsy sellers centralize order data, prepare and issue e-invoices in batches, and track invoice statuses, making it easier to reconcile invoice data with revenue and accounting records.
Contact
Genbook to learn more about accounting and e-invoicing data management solutions for e-commerce sellers.
