How to Store and Preserve E-Invoices Under Vietnam’s Regulations

E-invoice storage involves more than simply keeping a copy after an invoice has been issued. Businesses must also determine the applicable retention period, preserve the integrity of the electronic data, and ensure that invoices remain accessible when needed. These requirements warrant particular attention following the effective date of Decree No. 254/2026/ND-CP on July 1, 2026, which replaced Decree No. 123/2020/ND-CP and Decree No. 70/2025/ND-CP. This article outlines the key requirements businesses should review as they prepare for the 2026 annual tax finalization. 

1. E-Invoice Retention Period

Decree No. 254/2026/ND-CP does not prescribe a separate retention period specifically for e-invoices. Instead, Point b, Clause 1, Article 5 of Decree No. 254/2026/ND-CP requires invoices to be preserved and stored in accordance with accounting regulations. Accordingly, the retention period for invoices is determined under Clause 5, Article 41 of the Law on Accounting. 

1.1. Invoices Used for Accounting Records Must Be Retained for at Least 10 Years

An invoice is an accounting document issued by the seller of goods or provider of services under Clause 1, Article 20 of the Law on Accounting. When an invoice is used directly to record accounting entries and prepare financial statements, it falls into the category of documents that must be retained for at least 10 years, unless otherwise provided by law. This covers most sales and purchase invoices generated in the course of e-commerce operations. 

1.2. Other Retention Periods Under the Law on Accounting

1.3. When to Place Invoices into Storage and How to Handle Expired Records

Accounting records must be placed into archival storage within 12 months from the end of the annual accounting period or the completion of the accounting work, pursuant to Clause 3, Article 41 of Law on Accounting No. 88/2015/QH13. For businesses following the calendar year as their accounting period, invoices issued in 2026 must therefore be fully archived no later than December 31, 2027.

Regarding destruction, Official Letter No. 3164/TCT-CS dated July 23, 2024, issued by the General Department of Taxation, provides that accounting records that have reached the end of their retention period may be destroyed pursuant to a decision of the accounting entity’s legal representative, unless otherwise instructed by a competent state authority. Conversely, the destruction or intentional damage of accounting records before the end of their retention period is strictly prohibited under Clause 4, Article 13 of the Law on Accounting.

The expiry of the retention period does not, by itself, permit accounting records to be deleted or destroyed. Under Article 16 of Decree No. 174/2016/ND-CP, records may only be destroyed pursuant to a decision of the legal representative of the accounting entity, provided that no contrary instruction has been issued by a competent state authority. The destruction process must also comply with Article 17 of Decree No. 174/2016/ND-CP, including the establishment of a destruction council, the inventory and classification of records, and the preparation of a destruction list and destruction record.

2. E-Invoice Preserve Requirements Under Decree No. 254/2026/ND-CP

2.1. Two Mandatory Storage Principles

Clause 1, Article 5 of Decree No. 254/2026/ND-CP establishes two core requirements applicable to all invoices and documents. 

• First, businesses must ensure that stored data remains secure, confidential, complete, accurate, and free from alteration or discrepancies throughout the retention period.

• Second, invoices and documents must be retained for the full period required under accounting regulations. 

2.2. E-Invoices Must Be Stored as Data Messages

Under Clause 2, Article 5 of Decree No. 254/2026/ND-CP, e-invoices must be preserved and stored in the form of data messages. Businesses may choose a storage method that fits their operations and technological capabilities, provided that it meets the requirements under Article 13 of the Law on Electronic Transactions. In other words, the law does not prescribe a specific software or storage location; instead, it sets out the standards that the storage system must satisfy. 

2.3. Invoices Must Remain Printable or Retrievable When Needed

Under Clause 2, Article 5 of Decree No. 254/2026/ND-CP, e-invoices must be capable of being printed or retrieved when required. Throughout the retention period, businesses therefore need to ensure that invoice data remains accessible, searchable, and available for retrieval when necessary. Proper storage is not simply a matter of keeping invoice files; the data should also be organized so that invoices can be located quickly using information such as invoice number, issue date, or order ID. 

2.4. Handling Existing Paper Invoices

Under Clause 3, Article 5 of Decree No. 254/2026/ND-CP, invoices printed by tax authorities, printed or self-printed documents, and unused invoices must be stored in accordance with the rules applicable to valuable documents, while issued invoices held by accounting entities must be retained in accordance with accounting document requirements. As tax-authority-printed invoices ceased to be valid from July 1, 2026 under Clause 3, Article 44 of Decree No. 254/2026/ND-CP, businesses mainly need to ensure that paper invoices issued before that date continue to be retained for the required period. 

3. Requirements for Valid E-Invoice Storage

Article 13 of the Law on Electronic Transactions, together with Articles 17 and 18 of the Law on Accounting, establishes the requirements that an e-invoice storage system needs to meet. 

• Accessible and usable: The invoice content must remain accessible, readable, and available for reference throughout the retention period.

• Preserving Data Content: E-invoices must be retained in the form of data messages, with the information remaining accessible and usable for reference. Under Article 13 of the 2023 Law on Electronic Transactions, data may be stored in the same format in which it was created, sent, or received, or in another format that accurately preserves the content of the data message. In practice, businesses should retain the original electronic data together with the information necessary to verify the invoice’s integrity, origin, and status when required.

• Traceable to its source: Stored data must allow the origin, sender, recipient, and time of sending and receipt to be identified.

• Secure and protected against unauthorized access: Electronic documents must be managed and protected against unauthorized access, intrusion, copying, theft, or improper use under Clause 2, Article 17 of the Law on Accounting.

• Retrievable throughout the retention period: Where documents are not printed on paper, businesses must maintain data security, confidentiality, and retrievability throughout the required retention period under Clause 6, Article 18 of the Law on Accounting. 

One requirement that businesses often overlook when storing e-invoices is the need to preserve the original format. Simply downloading a PDF or saving a link to an online lookup page may not be sufficient, as the XML file contains the underlying electronic invoice data and provides the basis for verification when required. Businesses can learn more about the structure and verification of XML files in E-Invoice XML Files: What Sellers Need to Know. 

4. Risks of Improper E-Invoice Storage

Businesses are required to retain invoices for many years, meaning storage issues may not be discovered immediately and could only come to light during a tax inspection or audit. Key risks include the following. 

• Violation of prohibited acts: Destroying or damaging accounting documents before the end of their retention period is prohibited under Clause 4, Article 13 of the Law on Accounting.

• Administrative penalties: The loss, destruction, or damage of invoices may result in administrative penalties under Decree No. 125/2020/ND-CP, as amended and supplemented by Decree No. 310/2025/ND-CP, effective January 16, 2026.

• Difficulty in recovering lost accounting records: When accounting documents are lost, businesses may need to prepare records, notify the relevant authorities, contact counterparties for copies or confirmations, and even conduct asset inventories to reconstruct the necessary documentation under Article 42 of the Law on Accounting.

• Insufficient supporting evidence: Missing or inaccessible purchase invoices can weaken the supporting documentation used to substantiate expenses and input VAT when requested by the tax authority. 

5. An E-Invoice Storage Process for E-Commerce Sellers

E-commerce sellers face a particular challenge because they may handle a large volume of invoices with relatively small individual values, while the underlying data is often spread across multiple marketplaces. A storage process that complies with Decree No. 254/2026/ND-CP should cover four key steps. 

5.1. Store Both the Original XML File and PDF Representation

Each invoice should be retained together with its original digitally signed XML file and PDF representation. The XML file serves as the legal basis, while the PDF makes the invoice easier to read and print when required. 

5.2. Maintain Independent Backups

Businesses remain responsible for ensuring that invoices are stored for the full required period, even when they use an e-invoicing service provider. Under Article 5 of Decree No. 254/2026/ND-CP, invoices must be stored securely, completely, and accurately for the retention period required under accounting regulations. When changing or terminating a service, businesses should therefore verify that their invoice data remains accessible and maintain appropriate backups so that storage is not interrupted. 

5.3. Link Invoices to Order Data

Organize invoice names and tags by accounting period, sales marketplace, and order ID. This makes it easier to reconcile invoices with marketplace settlement reports and accounting records, while also supporting efficient retrieval when the documents are reviewed or inspected. 

5.4. Manage Access, Back Up Data, and Conduct Regular Checks

Access to edit or delete data should be restricted, while at least one separate backup copy should be maintained. Businesses should also periodically open a sample of older invoices to confirm that the data remains accessible and readable. These measures provide a practical way to maintain data integrity and ensure that invoices remain retrievable throughout the retention period. 

Supporting Businesses with E-Invoice Management and Storage

E-invoice storage does not end when an invoice is issued; it is an obligation that extends for at least 10 years, during which businesses must ensure that invoices remain in their original format and can be retrieved whenever required.

Sliner supports e-commerce sellers operating on Amazon and Etsy in building accounting processes that cover invoice issuance, marketplace data reconciliation, and compliant document storage. Learn more about Sliner's Accounting Automation service or contact Sliner to review your current e-invoice storage process.