Everything About E-Invoices: When to Issue, How to Handle Errors

When Is It Mandatory to Issue Electronic Invoices?

Electronic invoices are mandatory documents when there are sales of goods or provision of services, as stipulated by tax and invoicing laws.

Determining the correct time to issue an invoice is crucial for its validity and the arising tax obligations.

Invoice Issuance Time According to Legal Regulations

Invoice Issuance Time for Goods Sales

Based on Point a, Clause 6, Article 1 of Decree No. 70/2025/ND-CP, amending Clause 1, Article 9 of Decree No. 123/2020/ND-CP, it is stipulated:

The time of invoice issuance for the sale of goods is the time of transfer of ownership or the right to use the goods to the buyer, regardless of whether payment has been received or not.

This regulation applies to:

• Normal goods sales
• Sales and transfers of state assets
• Sales of national reserve goods

For exported goods, the invoice issuance time is determined by the seller but must not be later than the next working day from the date the goods are cleared according to customs law.

Invoice Issuance Time for Service Provision

The time of invoice issuance for service provision is the time when the service provision is completed, regardless of whether payment has been received or not.

In cases of receiving payment before or during the provision of services, the invoice issuance time is the time of payment receipt, excluding payments such as:

• Deposits
• Advances to secure contract performance

This regulation applies to specific services such as:

• Accounting, auditing
• Financial consulting, tax consulting
• Valuation
• Technical survey and design
• Supervision consulting
• Construction investment project formulation

Common Scenarios Regarding Invoice Issuance Time

Is It Permissible to Issue Electronic Invoices Retroactively?

No.

According to current legal regulations, issuing electronic invoices retroactively is not permitted. Issuing invoices at the wrong time or deliberately backdating them is an administrative violation regarding invoices.

Is It Permissible to Deliver Goods First and Issue an Invoice Later?

No.

Delivering goods first but not issuing an invoice at the time of ownership or right-to-use transfer is considered issuing an invoice at the wrong time and will be subject to penalties according to regulations.

Penalties for Issuing Invoices at the Wrong Time

From January 1, 2026, Decree No. 310/2025/ND-CP will take effect, stipulating:

Penalties for the act of issuing invoices at the wrong time can be up to 70 million VND, depending on:

• The nature of the violation
• The severity of the violation
• The number of violations

Issuing invoices at the correct time is a mandatory requirement, not an option.

Principles for Handling Erroneous Electronic Invoices

Invoices Issued, With Tax Authority Code, But Not Yet Sent to the Buyer, and Errors are Found

The seller must:

• Issue a new electronic invoice to replace it
• Clearly state: "Replaced for invoice mẫu số… ký hiệu… số… ngày… tháng… năm…"
• Send the replacement invoice to the buyer
• Simultaneously send the data of the replacement invoice to the tax authority

Invoices Sent to the Buyer, and Errors are Found

a. Incorrect buyer name or address (tax identification number is correct)

The seller must:

• Notify the buyer
• No need to reissue the invoice
• Send a notification to the tax authority using Form 04/SS-HĐĐT

b. Incorrect tax identification number, incorrect amount, tax rate, tax amount, or incorrect goods specifications or quality

The seller and the buyer (if an organization) must:

• Prepare a written agreement clearly stating the nature of the error

Then, choose **one of the following two methods**:

Adjusted Invoice: Applicable when only a portion of the content needs to be adjusted.

• Clearly state: "Adjusted for invoice mẫu số… ký hiệu… số… ngày… tháng… năm…"
• Clearly state the adjusted amount (increase or decrease)

Replacement Invoice: Applicable when the original invoice needs to be completely replaced.

• Clearly state: "Replaced for invoice mẫu số… ký hiệu… số… ngày… tháng… năm…"

After issuance:

• The seller must digitally sign
• Send the invoice to the buyer
• Send the data of the adjusted or replacement invoice to the tax authority

Read more: Comprehensive Guide to Replacement and Adjustment Invoices

Specific Handling Cases

Discounts, promotions, adjustments to construction project values: Issue a new invoice in the current period, indicating the increase or decrease.

Returned goods, price reductions after invoice issuance: Only issue an adjustment invoice; do not issue a replacement invoice.

Multiple incorrect invoices for the same buyer within the same month: A single adjustment or replacement invoice can be issued, accompanied by a detailed list of the original invoices.

Cases of Missing Mandatory Notes on Adjusted or Replacement Invoices

• The invoice is deemed invalid
• It must be reprocessed according to the original method

Cases Where Adjusted or Replacement Invoices Are Still Incorrect

Replacement invoices are processed sequentially: F0 → F1 → F2 → … → Fn

Adjusted invoices are processed using the cumulative principle: F0 + F1 + F2 + … + Fn

Important Notes

From June 1, 2025:

• Electronic invoices that have been issued can no longer be canceled
• All errors must be rectified using adjustment or replacement invoices

Conclusion

For new sellers, a thorough understanding of:

• When to issue an invoice
• Issuing at the correct time
• Handling errors correctly

is a mandatory condition for legal compliance, avoiding penalties, and ensuring transparent and sustainable business operations.