Executive Summary
Decree No. 254/2026/ND-CP and Circular No. 91/2026/TT-BTC introduce a new legal framework for e-invoices and electronic documents from 1 July 2026, replacing Decree No. 123/2020/ND-CP, Decree No. 70/2025/ND-CP and Circular No. 32/2025/TT-BTC.
01. Regulatory Framework
On 30 June 2026, the Government issued Decree No. 254/2026/ND-CP, providing detailed rules and implementation guidance for the 2025 Law on Tax Administration concerning e-invoices and electronic documents.
On the same date, the Ministry of Finance issued Circular No. 91/2026/TT-BTC to guide implementation of the Law and Decree No. 254/2026/ND-CP.
19 October 2020
Decree No. 123/2020/ND-CP established Vietnam’s legal framework for e-invoices and electronic documents.
20 June 2022
Decree No. 41/2022/ND-CP introduced voluntary e-invoice registration for foreign suppliers.
20 March 2025
Decree No. 70/2025/ND-CP expanded the use of cash register-generated e-invoices.
30 June 2026
Decree No. 254/2026/ND-CP and Circular No. 91/2026/TT-BTC comprehensively reformed the framework, effective from 1 July 2026.
Replaced instruments: Decree No. 123/2020/ND-CP, Article 1 of Decree No. 41/2022/ND-CP, Decree No. 70/2025/ND-CP and Circular No. 32/2025/TT-BTC.
02. Comparison of the Previous and New Frameworks
| Area | Previous framework | Decree No. 254/2026/ND-CP |
|---|---|---|
| General provisions | Based on the 2019 Law on Tax Administration; separate provisions on storage and conversion. | Updated under the 2025 Law on Tax Administration; introduces a whistleblower reward mechanism and consolidates storage and conversion rules. |
| E-invoices | No centralized exemption list; service deposits generally required invoicing. | Introduces eight exemption categories, aligns service deposit rules with the Civil Code and adds force majeure provisions. |
| Electronic documents | Fragmented data connectivity rules and no free service mechanism. | Introduces data connectivity and free e-document services for eligible small and micro business households in disadvantaged areas. |
| Data access and sharing | No consumer reward mechanism for reporting non-invoiced sales. | Rewards consumers reporting sales without invoices, up to VND 10 million per case. |
| Implementation | Separate effective dates and transitional provisions. | Effective from 1 July 2026; tax authority-issued pre-printed invoices are abolished immediately, while paper receipts may be used until 31 December 2026. |
03. Key Changes Under Decree No. 254/2026/ND-CP
1. Expanded scope of e-invoice usersForeign e-commerce and digital platform suppliers may voluntarily use e-invoices. Securities, crypto assets and carbon exchanges are also added to the scope of non-authenticated e-invoice users.
2. Stricter rules for business householdsBusiness households with annual revenue above VND 1 billion, or those selling registrable assets, must use authenticated e-invoices or cash register-generated e-invoices.
3. Eight new e-invoice exemptionsArticle 7 introduces exemptions covering selected real estate, digital content, agency, financial, capital contribution and internal asset transfer transactions.
4. More flexible invoicing timingSpecific services may use extended issuance deadlines, while deposits under the Civil Code to secure service contracts are exempt from immediate invoicing.
5. Restrictions on invoices without buyer informationInvoices without buyer details, or stating only “Sold to consumers”, may not support tax deductions or deductible expense recognition.
6. Expanded invoice authorizationBusiness households and individuals may authorize third parties, including e-commerce platform operators, to issue invoices on their behalf.
7. Incentive and reward mechanismThe framework introduces incentives for invoice collection and rewards for reporting invoice violations.
8. New contingency mechanismPre-printed invoices are replaced by a backup authentication system when the tax authority’s platform experiences disruptions.
04. Transactions Exempt from E-Invoice Issuance
- Purchase lists for agricultural, forestry and fishery products.
- Real estate leasing and digital content services supplied to overseas customers.
- Lottery, insurance and multi-level marketing agents subject to withholding tax.
- Reinsurance, deposits, debt trading, foreign exchange and derivatives.
- Capital contributions in the form of assets.
- Internal asset transfers and corporate restructuring.
- Machinery and equipment loans without charge.
- Goods used for internal production, compensation and bonuses unrelated to sales.
05. Invoice Issuance Timing
| Transaction | Timing effective from 1 July 2026 |
|---|---|
| Sale of goods | Upon transfer of ownership or the right to use the goods, regardless of whether payment has been received. |
| Export of goods | Determined by the seller, but no later than the next working day after customs clearance. |
| Provision of services | Upon completion of the service. Where payment is received in advance or during service provision, the invoice is issued upon receipt, except for deposits securing service contracts under the Civil Code. |
Key change: The new rules align deposit invoicing with the Civil Code and apply the treatment across all service categories.
06. Key Changes Under Circular No. 91/2026/TT-BTC
Stricter registration and suspension rulesBusiness households with unclear addresses, ineligible apartment locations or unmatched population database information may have e-invoice use suspended.
Simplified correction of erroneous invoicesWhere the buyer’s name, address or amount in words is incorrect but the tax code, amount and tax rate are correct, notification is sufficient and reissuance is not required.
Extended explanation periodTaxpayers are given three working days to provide explanations and supporting documents.
07. High-Risk Taxpayer Criteria and Risk Classification
High-risk taxpayer criteria
- The owner or legal representative has been involved in invoice fraud or illegal invoice trading.
- The taxpayer is included in a suspicious transaction list under anti-money laundering regulations.
- The registered address is unclear or located in an ineligible apartment building.
- The owner or legal representative has an inactive tax code or a history of tax and invoice violations.
- Other risk indicators are identified by the tax authority.
Risk classifications
Immediate suspension without prior noticeApplies to terminated tax codes, non-operation at the registered address, tax enforcement, prohibited or counterfeit goods, tax evasion or illegal invoice trading.
Temporary suspension subject to explanationApplies where any high-risk criterion is met or population database information remains unmatched.
Temporary suspension at the taxpayer’s requestApplies to voluntary business suspension or a change in business lines affecting eligibility for cash register e-invoices.
08. Key Dates to Note
1 July 2026
Decree No. 254/2026/ND-CP and Circular No. 91/2026/TT-BTC take effect; Circular No. 32/2025/TT-BTC ceases to be effective; unused tax authority-issued pre-printed invoices must be destroyed.
31 December 2026
Deadline for using remaining pre-printed and self-printed paper receipts issued under Decree No. 123/2020/ND-CP.
1 January 2027
Mandatory transition to 100% electronic receipts; all unused paper receipts must be destroyed.
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