Electronic Invoice 2026: What E-commerce sellers Need to Prepare

1. What Decree No. 254/2026/ND-CP changed on 1 July 2026

On June 30, 2026, the Vietnamese Government issued Decree No. 254/2026/ND-CP, providing detailed guidance for implementing the Law on Tax Administration No. 108/2025/QH15 regarding electronic invoices (e-invoices) and electronic documents. The Decree takes effect on July 1, 2026, replacing Decree No. 123/2020/ND-CP and Decree No. 70/2025/ND-CP.

For e-commerce businesses, the new regulations on electronic invoices clarify the entities required to use different types of electronic invoices, the conditions for applying each type, and introduce new provisions such as e-commerce invoices and updated rules on the timing of invoice issuance for specific business activities.

These changes affect more than just the process of issuing electronic invoices. They also require businesses to review their accounting workflows and data management processes to ensure compliance once Decree No. 254/2026/ND-CP officially comes into effect.

2. Which Electronic Invoice Category Applies to Your E-commerce Business?

Under Article 6 of Decree No. 254/2026/ND-CP, businesses are classified into three categories of electronic invoice users. Identifying the correct category from the outset is essential, as each category has its own eligibility requirements and rules for issuing electronic invoices.

2.1 Businesses Using Electronic Invoices with Tax Authority Codes

This is the most common category, covering enterprises, other organizations, household businesses, individual businesses, and entities classified as having a high tax risk under regulations issued by the Ministry of Finance. Most small and medium-sized e-commerce businesses fall into this category.

2.2 Businesses Using Electronic Invoices Without Tax Authority Codes

Businesses operating in e-commerce, along with sectors such as electricity, petroleum, telecommunications, finance and banking, insurance, supermarkets, transportation, and several other industries specified under regulations, may be eligible to issue electronic invoices without tax authority codes. Companies must satisfy all required conditions, including conducting electronic transactions with the tax authority, maintaining appropriate IT infrastructure, using compliant accounting and e-invoice software, and ensuring data can be transmitted to both buyers and the tax authority. These provisions do not apply to businesses classified as high tax risk or those that have already registered to use tax authority-coded electronic invoices.

2.3 Businesses Eligible to Use Cash Register-Generated Electronic Invoices

This covers organisations, business households, and individual traders selling goods or services directly to consumers: shopping centres, supermarkets, retail, food and beverage, restaurants, hotels, passenger transport, entertainment services, and other personal services. It matters most to sellers running hybrid models: online storefronts plus physical points of sale. A business already registered for an electronic invoice under either category above is not required to register separately for cash-register issuance.

3. Household Businesses with Annual Revenue Above VND 1 Billion: A Threshold You Need to Monitor

Under Article 6 of Decree No. 254/2026/ND-CP, household businesses and individual businesses with annual revenue exceeding VND 1 billion, or those selling assets subject to ownership or usage registration, are required to use tax authority-coded electronic invoices or cash register-generated electronic invoices connected to the tax authority's system. Businesses that are not yet subject to this requirement may still voluntarily register to use electronic invoices.

For e-commerce sellers - especially those operating across multiple sales channels, the real challenge is not the VND 1 billion threshold itself, but accurately tracking when that threshold is reached. Revenue is often spread across different marketplaces, payment gateways, and settlement periods. When each sales channel is managed through separate spreadsheets or reports, businesses may not realize they have exceeded the threshold for mandatory electronic invoice adoption until much later.

Instead of reviewing revenue only at year-end, businesses should consolidate sales data and reconcile it on a regular basis. This helps determine the correct time to transition to electronic invoices under the regulations while reducing the risk of errors in tax filing and compliance.

4. Updated Rules on Electronic Invoice Issuance Timing

One of the new regulations on electronic invoices that has the greatest impact on e-commerce businesses is the revision of invoice issuance timing under Article 9 of Decree No. 254/2026/ND-CP. For businesses handling a high volume of transactions or requiring data reconciliation before recognizing revenue, these changes are particularly important.

4.1. Deposits Do Not Require an Electronic Invoice

For service transactions, an electronic invoice must be issued when the service is completed or when payment is collected in advance or during the service period. However, a security deposit made to ensure the performance of a contract under the Civil Code is not considered a basis for issuing an electronic invoice.

4.2. New Rules for Services Requiring Data Reconciliation

Decree No. 254/2026/ND-CP introduces a new provision for services involving a high volume of recurring transactions that require data reconciliation between the service provider and the customer before an electronic invoice is issued. In these cases, the invoice may be issued no later than the 7th day of the following month or within 07 days after the end of the agreed reconciliation period.

This applies to digital technology services, digital platforms, information technology services, online advertising on electronic newspapers, digital asset services, and several other sectors specified in the Decree. The change is particularly relevant to businesses operating on digital platforms.

4.3. Clarified Rules for After-Hours Transactions

If a seller does not use an automated electronic invoice system, the invoice may be issued no later than the next working day, in accordance with Clause 5, Article 9 of Decree No. 254/2026/ND-CP.

4.4. Expanded Cases for End-of-Day Consolidated Electronic Invoices

Article 9 also expands the cases in which an electronic invoice may be issued as a consolidated end-of-day invoice. Healthcare facilities using hospital management software may issue a single electronic invoice covering all services provided during the day when patients do not request individual invoices. 

If a patient later requests an invoice, the healthcare provider must still issue and deliver an electronic invoice in accordance with the regulations.

5. Why Manual Electronic Invoice Issuance Breaks as Your Business Scales

The new regulations on electronic invoices under Decree No. 254/2026/ND-CP not only change how businesses issue electronic invoices, but also place greater emphasis on data accuracy and the timing of invoice issuance. For e-commerce businesses handling a high volume of transactions, manual invoicing processes are becoming increasingly difficult to maintain.

Common issues include:

• The timing of electronic invoice issuance does not match the marketplace's transaction confirmation or reconciliation date, causing revenue to be recorded in the wrong accounting period.

• Product returns and order cancellations occur after an electronic invoice has already been issued, requiring invoice adjustments or replacements in accordance with the regulations.

• Marketplace fees, discounts, and other deductions are withheld before the seller receives payment, meaning the amount received does not reflect the actual revenue that should be invoiced.

• Transactions in multiple currencies require conversion using the applicable exchange rate at the time of the transaction, rather than the rate used when accounting data is entered.

• Sales data downloaded from multiple marketplaces or different settlement periods increases the risk of duplicate, missing, or incorrectly recorded orders.

Individually, these discrepancies may seem insignificant. However, when a business processes thousands of transactions each month, they can create differences between electronic invoice records, accounting data, and actual sales figures. These hidden costs are often one of the biggest risks of relying on spreadsheets for accounting and may only become apparent during a tax review or audit.

6. What Should Businesses Review Now?

Although some technical requirements under the new regulations on electronic invoices will be further clarified by the Ministry of Finance, businesses should not wait for additional guidance before taking action. Reviewing internal processes early will help ensure compliance with Decree No. 254/2026/ND-CP while reducing implementation risks.

Businesses should prioritize the following:

• Determine the correct electronic invoice category under Article 6 of Decree No. 254/2026/ND-CP and retain supporting documentation.

• Review existing accounting and e-invoice systems to ensure they meet requirements for data standardization, storage, transmission, and system connectivity.

• Reconcile sales revenue across all sales channels with the figures reported in tax filings for at least the two most recent reporting periods.

• Standardize internal procedures for handling product returns, cancelled orders, invoice adjustments, and electronic record retention in accordance with the regulations.

• For household businesses approaching the VND 1 billion annual revenue threshold, prepare a transition plan before becoming subject to mandatory electronic invoice requirements.

6. Genbook: From marketplace data to compliant electronic invoice in one system

Complying with the new regulations on electronic invoices is not just about using the right invoicing software, it starts with having accurate and reliable sales data. When revenue is spread across multiple marketplaces, settlement periods, and payment channels, managing data through spreadsheets often leads to discrepancies between sales records, electronic invoices, and accounting data.

Genbook consolidates sales data from multiple e-commerce marketplaces into a single platform and standardizes it in line with accounting principles. Once the data has been reconciled, businesses can issue electronic invoices directly from verified transaction records while using the same data source to generate general ledger entries and financial reports. This eliminates the need for manual reconciliation between sales data, invoices, and accounting records.

Start your free 1-month Genbook trial to standardize your sales data and stay prepared for the new regulations on electronic invoices.