E-Invoices 2026: The Notable Rule Updates

From 01/7/2026, all invoicing and invoice management activities in Vietnam will operate under a new legal framework. Decree 254/2026/ND-CP was issued by the Government on 30/6/2026 and took effect just one day later, replacing Decree 123/2020 and Decree 70/2025/ND-CP. The virtually nonexistent gap between the signing date and the effective date means that most businesses entered the second half of 2026 without having had time to review their invoicing processes.

For cross-border e-commerce sellers, the risk rarely comes from missing a single provision. The risk lies in the fact that invoice software, revenue recognition processes, and input cost documentation are still operating under the old standards, while tax authorities have already begun reconciling data under the new standards. This article analyzes the key changes to e-invoices and the areas businesses need to address immediately.

1. Decree 254/2026/ND-CP Replaces the Entire Previous Legal Framework on Invoices

1.1. Effective Date and Scope of Replacement

Decree 254/2026/ND-CP provides detailed regulations on certain provisions and implementation measures of the 2025 Law on Tax Administration (Law No. 108/2025/QH15) concerning e-invoices and electronic documents. The Decree takes effect from 01/7/2026, coinciding with the official application of the 2025 Law on Tax Administration, and replaces Decree 123/2020/ND-CP, Decree 70/2025/ND-CP, and Article 1 of Decree 41/2022/ND-CP. On the same date, 30/6/2026, the Ministry of Finance issued Circular 91/2026/TT-BTC providing implementation guidance.

Three transition milestones businesses need to remember:

• From 01/7/2026: Decree 123/2020/ND-CP and Decree 70/2025/ND-CP cease to be effective; tax authority-printed invoices cease to be valid for use and must be destroyed in accordance with regulations of the Ministry of Finance.
• Until the end of 31/12/2026: self-printed and pre-printed paper receipts issued under the previous regulations may still be used.
• From 01/01/2027: all unused paper receipts must be destroyed and replaced with electronic receipts.

One less-noticed consequence is that official guidance letters on professional operations issued on the basis of Decree 123/2020 are no longer automatically applicable. Accountants need to review each previous guideline before applying it to transactions arising from 01/7/2026.

1.2. Scope of Applicable Entities Expanded to Foreign Platforms

Article 2 of Decree 254/2026/ND-CP revises the criteria for identifying foreign suppliers. The applicable entities now include foreign organizations, including operators of foreign e-commerce platforms and digital platforms, that conduct business on e-commerce platforms and provide other services generating taxable revenue in Vietnam, while voluntarily registering to use e-invoices. The previous regulation under Decree 70/2025/ND-CP was tied to the condition of having no permanent establishment in Vietnam, resulting in a significantly narrower scope.

The Decree also removes the group of entities related to printing and self-printing invoices and documents, while revising the definitions of lawful invoices and the use of unlawful invoices. The list of violations is expanded to include the use of invoices that do not accurately reflect the actual value arising from a transaction, as well as the issuance of fictitious invoices, fake invoices, or invoices with discrepancies in the value of goods or services.

2. Mandatory Invoice Contents: Six Changes to Update

Article 10 and the Appendices revise the information required to appear on invoices. These changes directly affect the configuration of businesses' e-invoice issuance software.

2.1. Seller Information

• Household businesses and individual businesses using the same tax identification number for multiple stores must clearly state the name, code, and address of each business location on the invoice.
• Businesses trading in petroleum products must state the code and address of the business location issued by the competent authority for each point of sale.
• Authorized e-invoices must simultaneously show the information of both the authorizing party and the authorized party.
• In cases involving the auction of assets for enforcement purposes, the invoice must show information of both the agency assigned to conduct the auction and the seller.

2.2. Buyer Information and Consumer Sales Invoices

When the buyer is a consumer and provides their name, address, and personal identification number, the invoice must fully state this information. For foreign customers, the address and identification number may be replaced by the passport number or immigration document details, together with nationality. If the buyer does not provide the information, the invoice must clearly state “Sold to consumer”.

An invoice without buyer information, or an invoice issued to a consumer, is not valid for accounting for expenses or tax finalization. For e-commerce businesses that frequently incur purchases of packaging materials, transportation services, or advertising expenses through small-value transactions, this requirement may result in some input costs being excluded from the tax finalization file if invoice collection procedures are not tightened.

2.3. Names of Goods and Services and Identification Requirements

The names of goods and services on invoices must be stated in Vietnamese in accordance with applicable laws. Where the law prescribes identification standards for goods or services, the seller must state the name according to those identification standards. For the sale of automobiles and motorcycles, an invoice containing complete buyer information, chassis number, engine number, brand, year of manufacture, and quality certificate number serves as a basis for the tax authority to determine the registration fee.

For domestic road transportation services, the requirement to state the vehicle registration number has been revised: contracted transportation services operated on fixed routes are not required to show the vehicle registration number on the invoice.

2.4. Electronic Signatures and Other Amendments

The Decree adds provisions on the signatures of sellers and buyers, under which foreign suppliers use electronic signatures in accordance with the law on electronic transactions. For sales invoices issued by household businesses and individual businesses, the authorities encourage the inclusion of information on the business sector corresponding to the goods or services in the XML-formatted e-invoice data sent to the tax authority and the display of this information on the invoice representation.

3. Invoice Issuance Timing under Decree 254/2026/ND-CP

Article 9 redefines the invoice issuance timing for each group of transactions. This is an area that can easily create discrepancies between accounting records and the data held by tax authorities, particularly for businesses with export revenue.

For sellers on Amazon, Etsy, or international marketplaces, the next-business-day deadline from the date of customs clearance requires customs data and sales data to be connected almost in real time. The month-end batch invoicing process, which was common previously, no longer meets the requirements of the 2025 Law on Tax Administration.

4. Electronic Commercial Invoices for Export Activities

Decree 254/2026/ND-CP establishes the electronic commercial invoice as an independent type of invoice, applicable to exporters that meet the conditions for electronically transmitting commercial invoice data to the tax authority. Businesses that do not meet these conditions may choose to issue electronic VAT invoices or electronic sales invoices instead.

For e-invoices without a tax authority code, businesses may use their own software to create, digitally sign, and send them directly to buyers, but must still transmit the data to the tax authority within the prescribed deadline and in the prescribed standard format. This makes information technology infrastructure a decisive factor in determining which form a business may use.

One benefit for sellers is that Article 17 recognizes the right to request the operator of an e-commerce platform to provide buyer information for invoice issuance. This provides a legal basis for sellers to request transaction data from marketplaces, rather than having to infer customer information when issuing invoices.

5. Five Areas Businesses Need to Review Immediately

• Invoice issuance software configuration. Review the mandatory data fields under the 2026 e-invoice standards, including the buyer's personal identification number, business location code, and business sector information in the XML file.
• Export revenue recognition process. Align the invoice issuance timing with the customs clearance date instead of the date payment is received from the marketplace or payment gateway.
• Input invoice quality. Exclude from the expense documentation any invoices without buyer information or bearing the wording “Sold to consumer”.
• Inventory of outstanding paper receipts and invoices. Plan to use them up before 31/12/2026 and destroy them in accordance with the required procedures from 01/01/2027.
• Internal guidance materials. Update accounting and electronic document procedures in accordance with Decree 254/2026/ND-CP, replacing previous guidance based on Decree 123/2020.

6. Conclusion and Next Steps with Sliner

Decree 254/2026/ND-CP not only changes e-invoice requirements but also how tax authorities reconcile business data on a near-real-time basis.

Sliner helps sellers automate their e-invoicing process from order data by syncing data from Shopee, TikTok Shop, Amazon, and Etsy, identifying orders eligible for invoicing, processing buyer information, and reconciling invoice data against actual revenue. The solution is designed for sellers managing high order volumes across multiple platforms.

Learn more about Accounting Automation to standardize and reconcile invoice and revenue data, or contact Sliner to discuss your current process and receive tailored guidance for your business.