Vietnam's Updated E-invoice Regulations
From 1 July 2026, Vietnam’s e-invoice regulations will introduce several important changes, including additional cases where invoices are not required, revised invoice issuance timelines for services requiring reconciliation, and the option for e-commerce sellers to authorize marketplaces to issue invoices in certain cases.
Alongside these changes, businesses will need to pay closer attention to the consistency of data across invoices, orders, cash flows, and marketplace records. This article summarizes the key updates to the 2026 e-invoice regulations from an e-commerce operations perspective and highlights the areas businesses should review to ensure compliance.
1. Key Updates to E-Invoice Regulations Under Decree 254/2026/ND-CP and Circular 91/2026/TT-BTC
On 30 June 2026, the Government issued Decree 254/2026/ND-CP, providing detailed guidance on the Law on Tax Administration No. 108/2025/QH15 regarding e-invoices and electronic documents. Decree 254/2026/ND-CP took effect on 1 July 2026 and consists of five chapters, 45 articles, and one appendix. The Decree also replaces Decree 123/2020/ND-CP, which had governed e-invoice requirements in previous years. On the same day, the Ministry of Finance issued Circular 91/2026/TT-BTC, which provides detailed guidance on implementing the e-invoice requirements under Decree 254/2026/ND-CP. The Circular includes five chapters, 25 articles, and five appendices. Later, on 15 July 2026, the Tax Department issued Official Letter No. 4831/CT-CS to introduce key updates and provide implementation guidance, as summarized in the Government Portal’s overview of the new e-invoice and electronic document regulations. In simple terms, Decree 254/2026/ND-CP establishes the overall legal framework, while Circular 91/2026/TT-BTCprovides detailed instructions on how these requirements should be applied in practice. Therefore, when reviewing their e-invoice processes, businesses should consider both documents together to fully understand the compliance requirements and implementation procedures.2. Entities Subject to the New E-Invoice Regulations
2.1. Revenue Threshold Calculated Across All Sales Channels
For enterprises, there are no significant changes to the current e-invoice requirements. The main changes apply to households and individuals conducting business activities, particularly those exceeding the annual revenue threshold of VND 1 billion. These businesses are required to use e-invoices with tax authority codes or e-invoices generated from cash registers connected to tax authority data systems. If their revenue has not exceeded this threshold, business households and individuals may still register to use e-invoices if they wish. Individuals conducting business activities without a registered business household are also allowed to register for e-invoice use under the regulations. When determining whether the VND 1 billion revenue threshold is reached, the tax authority considers the total revenue generated by the same business entity across all sales channels, rather than assessing each channel separately. According to the tax and e-invoice seminar on e-commerce held on 20 July 2026, revenue from physical stores, websites, social media platforms, and e-commerce marketplaces is aggregated. For example, if a seller generates VND 600 million in revenue from Shopee and VND 500 million from TikTok Shop, the total revenue has exceeded the VND 1 billion threshold, even though neither individual channel exceeds the threshold on its own. Once the threshold is exceeded, the business must register to use e-invoices within 30 days.2.2. Cases Not Required to Use E-Invoices
Article 7 of Decree 254/2026/ND-CP consolidates cases where e-invoices are not required into a separate provision, making it easier for businesses and individuals to determine whether the requirements apply. The main cases include:- Business households and individuals selling goods that are subject to purchase statements under corporate income tax regulations, unless they voluntarily register to use e-invoices.
- Business households and individuals earning income from real estate leasing or providing digital products and services to overseas organizations or individuals.
- Other specific cases, including lottery agents, insurance agents, and multi-level marketing agents where tax has already been withheld by the relevant enterprises, as well as certain income arising from financial activities.
3. Invoice Issuance Timing by Transaction Type
Article 9 of Decree 254/2026/ND-CP specifies when electronic invoices must be issued depending on the nature of the transaction. For sales conducted through e-commerce marketplaces, businesses should track the actual status of each order to determine the correct invoice issuance time rather than relying solely on when the platform settles or transfers funds.3.1. Orders Successfully Delivered to Customers
Under Clause 1, Article 9 of Decree 254/2026/ND-CP, for the sale of goods, an invoice must be issued when ownership or the right to use the goods is transferred to the buyer in accordance with applicable regulations. Therefore, once an order has been completed and the goods have been delivered to the customer, the business must issue the invoice at the legally required time. Waiting until the marketplace consolidates sales and transfers the payout to the seller may result in the invoice being issued later than required.3.2. Cancelled Orders or Transactions That Have Not Been Completed
For transactions that have not been completed, such as orders cancelled before the goods are transferred to the customer, the invoice issuance point under Clause 1, Article 9 of Decree 254/2026/ND-CP has not yet occurred. The regulation establishes the invoice issuance time for the sale of goods as the point at which ownership or the right to use the goods is transferred to the buyer. Sellers should therefore monitor order status carefully to distinguish completed and delivered orders from orders that are still being processed or have been cancelled. Tracking transaction status helps businesses determine the correct time to issue invoices and comply with their invoicing obligations under Clause 1, Article 4 of Decree 254/2026/ND-CP.3.3. Returned Orders After an Invoice Has Been Issued
Where goods have already been delivered and an invoice has been issued, but the customer subsequently returns part or all of the goods, the seller should not treat the return as a new transaction. Instead, the business must process an adjustment to the original invoice in accordance with the applicable e-invoicing rules. Return and refund data from marketplaces should therefore be tracked alongside invoice data so that revenue figures remain accurate and can be properly reconciled during reviews or audits.3.4. Orders on International Marketplaces and Settlement Cycles
For international marketplaces such as Amazon or Etsy, businesses should note that the date on which the platform transfers funds is not the date that determines the invoicing obligation under Vietnam’s e-invoicing rules. A settlement cycle simply represents the period during which the marketplace aggregates sales, fees, refunds, and other adjustments before paying the seller. Businesses that currently wait until marketplace payouts are received before issuing invoices should therefore review their processes to ensure that invoices are issued based on the actual transaction status and in accordance with the new e-invoicing requirements.4. Issuing Invoices for E-Commerce Marketplace Orders
To issue an invoice, sellers may request information from the marketplace regarding the buyer, transaction, delivery timing, and order status under Point c, Clause 1, Article 17 of Decree 254/2026/ND-CP. Where the seller authorizes a marketplace or another organization to issue invoices on its behalf, the arrangement must comply with the authorization requirements under Article 19 of Decree 254/2026/ND-CP.4.1. Two Ways to Issue Invoices for Marketplace Orders
When an order is generated through an e-commerce marketplace, the seller may either issue the invoice directly or authorize the marketplace to do so, depending on its operating model and whether the relevant regulatory requirements are met. The two approaches are:- Seller-issued invoices: The seller uses transaction information and buyer information provided by the marketplace to issue the invoice. Where the buyer only provides their name, phone number, and address, the invoice may be prepared based on the information actually available.
- Marketplace-issued invoices under authorization: Where the seller authorizes the marketplace to issue invoices on its behalf, the invoice must contain the required information of both the authorizing party and the authorized party, including their names, addresses, and tax identification numbers.
4.2. Determining Revenue from Marketplace Orders
When selling through an e-commerce marketplace, the amount ultimately received by the seller is often lower than the original order value because the platform may deduct service fees, shipping costs, and other charges before settlement. However, these deductions do not change the original value of the sale. They simply reduce the net amount paid to the seller. For example, if a product is sold for VND 1,000,000, the marketplace deducts VND 100,000 in platform fees and the logistics provider charges VND 50,000, the seller receives VND 850,000. However, the transaction revenue remains VND 1,000,000. The related fees should be recorded separately based on their nature, similar to how revenue and expenses are presented separately in the Profit & Loss Statement (P&L). If businesses use the net marketplace payout as their revenue figure, the amounts recorded on invoices, tax returns, and accounting records may not reconcile, making subsequent reviews and explanations significantly more time-consuming.5. Key Areas to Review Under Circular 91/2026/TT-BTC
In addition to rules concerning who is subject to e-invoicing and when invoices must be issued, Circular 91/2026/TT-BTC provides more detailed guidance on the registration, use, and handling of electronic invoices. Key areas businesses and individual business operators should review include:- Registration and changes to e-invoicing registration details under Article 6 of Circular 91/2026/TT-BTC, for example when changing the invoicing method or moving to an authorized invoicing arrangement.
- Criteria for identifying high-risk taxpayers, as well as circumstances in which the use of electronic invoices may be suspended or temporarily suspended under Article 8 of Circular 91/2026/TT-BTC.
- Procedures for handling errors in issued electronic invoices under Article 10 of Circular 91/2026/TT-BTC and for handling issued electronic documents under Article 20 of Circular 91/2026/TT-BTC.
