Register before issuing
Vietnamese companies generally must register and use electronic invoices (e-invoices) before issuing taxable invoices. As of July 1, 2026, the main framework is Decree 254/2026/ND-CP and Circular 91/2026/TT-BTC, which replaced the previous Decree 123/2020 and Circular 32/2025 framework.
| Item | Foreign-invested company requirement |
|---|---|
| Who registers | Vietnamese enterprises, including LLCs, JSCs, branches, and other taxable organizations |
| Registration channel | Through an approved e-invoice service provider or the Tax Administration Information System |
| Main registration data | Tax code, enterprise details, legal representative, invoice type, signature method, service provider, and technical configuration |
| Default position | Tax-authority-authenticated e-invoices are generally required unless the taxpayer qualifies for unauthenticated invoices |
| Digital signature | Required for signing and transmitting e-invoice data, subject to the chosen invoice model |
Authenticated versus unauthenticated
| Model | Practical use |
|---|---|
| Authenticated e-invoice | Invoice data is issued with a tax-authority authentication code; this is the general route for many taxpayers |
| Unauthenticated e-invoice | Available only to qualifying taxpayers and sectors that satisfy the technical conditions for transmitting invoice data |
| Cash-register-generated invoice | Used for specified direct-to-consumer businesses, generally with real-time or connected transmission to the tax authority |
| Foreign-supplier e-invoice | Available in specified circumstances to non-resident suppliers, including certain e-commerce and digital-platform operators |
The 2026 rules narrow the group that may use unauthenticated e-invoices. Qualifying consumer-facing sectors may include e-commerce, supermarkets, trading, transportation, healthcare, finance, insurance, securities, telecommunications, and certain other sectors, provided the technical data-transmission requirements are met.
Issuance controls
The company should ensure that every invoice:
- Uses the correct invoice type and is issued at the legally required time.
- Contains the correct seller and buyer details, tax code, goods or services, quantities, prices, tax rate, and VAT amount.
- Uses a valid invoice number and series, and is digitally signed where required.
- Is transmitted to the tax authority or buyer through the approved channel.
- Matches the accounting records, contracts, delivery documents, and payment records.
- Is corrected or replaced through the prescribed process if an error is discovered.
The invoice date must match the legally prescribed timing for the transaction. Delaying an invoice until payment is received is not always permitted; the correct date may depend on delivery, completion of services, acceptance, or collection rules.
Registration workflow
- Obtain the company tax code and complete core tax registration.
- Select an approved e-invoice provider or eligible tax-authority service.
- Choose authenticated, unauthenticated, or POS-generated invoices based on the business model.
- Submit the e-invoice registration.
- Configure digital signatures, invoice series, numbering, tax rates, and accounting integration.
- Wait for the tax-authority acceptance or registration notice.
- Test issuance, transmission, receipt, cancellation, adjustment, and export to accounting.
- Issue taxable invoices only after the registration is accepted.
The tax system may cross-check the legal representative and company information during registration. Incorrect legal-representative data, an inactive tax code, an unclear registered address, or a high-risk profile can cause the application to be rejected or trigger an explanation request.
Foreign-investor watchouts
- Whether the activity is trading, retail, e-commerce, platform, logistics, or another regulated sector.
- Whether the company sells directly to consumers and therefore needs a POS-compatible model.
- Whether the invoice method matches the company's VAT method.
- Whether imported goods, customs declarations, and e-invoices reconcile.
- Whether the company's legal representative can complete the digital-registration process, and whether organizational VNeID access is needed.
- Whether foreign customers require export or service invoices with special information.
- Whether a foreign parent's recharge, management fee, royalty, or intercompany service requires an invoice or another supporting document.
Register before issuing
An ERC or tax code does not by itself authorize invoice issuance. Select the correct e-invoice model, complete registration, configure the system, and preserve the original electronic audit trail.
For an FDI company, e-invoice setup should be completed alongside bank, tax, accounting, e-signature, and VNeID onboarding — not after the first sale. The July 2026 regime is new, so the company should confirm the applicable invoice method and technical requirements with its tax authority and provider before commencing sales.