Decree 254/2026: Vietnam E-Invoice Rules for Foreign-Invested Companies

Since 1 July 2026, e-invoicing in Vietnam is governed by Decree 254/2026/ND-CP (issued 30 June 2026 under the Law on Tax Administration No. 108/2025/QH15) and Circular 91/2026/TT-BTC. They replace Decree 123/2020/ND-CP, Article 1 of Decree 41/2022/ND-CP, Decree 70/2025/ND-CP and Circular 32/2025/TT-BTC. For foreign-invested enterprises (FIEs), most invoice errors flagged in tax audits come from timing and correction rules, and both changed. Here is what your finance team needs to know.

1. When to issue an invoice for services

• Issue the e-invoice when the service is completed, whether or not payment has been received. This also applies to services supplied to foreign customers.
• If you collect money before or during the service, the invoice date is the date of collection.
• Only a security deposit under the 2015 Civil Code is exempt at the time of receipt. Advance payments (e.g. 50% upfront fees) must be invoiced immediately. Review your service contracts so that deposits and advances are clearly separated.
• Transactions completed before 1 July 2026 still follow the old timing rules, even if the invoice is issued later.

2. Transactions that no longer need an invoice

Article 7 of Decree 254 lists cases where no e-invoice is required, including capital contribution in kind, internal transfer of assets, and internal movement of goods to continue production or business. This matters for manufacturing FIEs moving goods between factories and branches.

3. No more invoice cancellation

• Wrong buyer name or address (tax code, amounts and VAT rate correct): notify the buyer and file Form 04/SS-HĐĐT with the tax authority. No new invoice is needed.
• Wrong tax code, goods, quantity, price, amount, VAT rate or VAT amount: issue an adjustment or replacement invoice (Article 10, Circular 91/2026/TT-BTC). Errors in the invoice form/serial/number can only be fixed by adjustment.
• Several erroneous invoices to the same buyer in the same period can be corrected with one adjustment or replacement invoice plus a list.

4. Invoices to individuals and foreigners

• Consumers who give no details: the invoice states “Bán cho người tiêu dùng” (sold to consumer).
• Foreign individuals: record the passport number (or entry document) and nationality.

5. Other changes

• Late-night transactions: sellers without automated invoicing software may issue the invoice no later than the next working day.
• More service types (e.g. insurance, security, industrial catering) may issue invoices after reconciling data with customers.
• Paper invoices printed by the tax authority expired on 1 July 2026 and must be destroyed.
• Consumers who report sellers for not issuing invoices can be rewarded up to 10% of the fine (max VND 10 million per case).
• Penalties apply under Decree 125/2020/ND-CP as amended by Decree 310/2025/ND-CP.

Compliance checklist for FIEs

1. Confirm your e-invoice provider has updated templates and data fields under Decree 254.
2. Update service contracts and billing: separate deposits from advance payments.
3. Replace any “cancel invoice” step in your SOP with adjustment, replacement or Form 04/SS-HĐĐT.
4. Check how intercompany and internal goods movements are documented.
5. Brief your sales team on buyer information for foreign individuals.

Informly supports foreign-invested companies in Ho Chi Minh City with accounting services, bookkeeping and e-invoice compliance reviews. Contact us at +84 907 392 969 for a compliance check.

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