When is it mandatory to issue electronic invoices?

Electronic invoices are mandatory documents when goods are sold or services are provided, as stipulated by tax and invoicing laws.

Determining the correct time of invoice issuance is crucial to the validity of the invoice and the resulting tax obligations.

The time of invoice issuance as stipulated by law.

The timing of invoicing for the sale of goods.

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 that:

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

This regulation applies to:

• Selling ordinary goods
• Sale and transfer of public assets
• Selling national reserves

For goods exports, the date of invoice issuance is determined by the seller, but no later than the next working day after the goods are cleared through customs according to customs law.

Time of invoicing for the provision of services

The time of invoicing for the provision of services is the time when the provision of services is completed, regardless of whether payment has been received or not.

In cases where payment is collected before or during the provision of services, the invoice date is the date of payment, excluding the following items:

• Deposit
• Advance payment to secure contract performance.

This regulation applies to specific services such as:

• Accounting, auditing
• Financial consulting, tax consulting
• Valuation
• Survey and engineering design
• Consulting and supervision
• Prepare an investment project for construction.

Common scenarios regarding the timing of invoice issuance.

Is it permissible to issue backdated electronic invoices?

Are not.

According to current regulations, it is not permitted to issue backdated electronic invoices. Issuing invoices at the wrong time or intentionally backdating them constitutes an administrative violation related to invoices.

Is it possible to deliver the goods first and issue the invoice later?

Are not.

Delivering goods in advance but failing to issue an invoice at the time of transfer of ownership or right to use the goods is considered to be issuing an invoice at the wrong time and will be subject to penalties as prescribed by law.

Penalties for issuing invoices at the wrong time.

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

The penalty for issuing invoices at the wrong time can be up to 70 million VND, depending on the circumstances:

• Nature of the violation
• Level of violation
• Number of violations

Issuing invoices on time is a mandatory requirement, not an option.

Principles for handling erroneous electronic invoices

An invoice has been issued, with a tax authority code, but has not yet been sent to the buyer; an error has been discovered.

Seller performs:

• Create a new electronic invoice to replace the old one.
• Please specify: "Replacement for Invoice Form No… Symbol… Number… Date… Month… Year…"
• Send a replacement invoice to the buyer.
• Simultaneously send the replacement invoice data to the tax authorities.

The invoice was sent to the buyer, but an error was discovered.

a. Incorrect name and address of the buyer (but not incorrect tax identification number)

Seller:

• Notify the buyer.
• No need to re-invoice.
• Notify the tax authorities using Form 04/SS-HĐĐT

b. Incorrect tax identification number, incorrect amount, tax rate, tax amount, or goods that do not meet specifications or quality standards.

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

• Prepare a written agreement clearly stating the details of the error.

Then choose one of the two options :

Adjustment invoice: Applicable when a portion of the content needs to be adjusted.

• Please specify: "Adjustment for invoice Form No… Symbol… Number… Date… month… year…"
• Specify whether the adjustment is an increase or a decrease.

Replacement invoice: Applicable when a complete replacement of the original invoice is required.

• Please specify: "Replacement for Invoice Form No… Symbol… Number… Date… Month… Year…"

After creation:

• Seller digital signature
• Send the invoice to the buyer.
• Submit adjusted or replacement invoice data to the tax authorities.

Read more: Overview of Replacement Invoices and Adjustment Invoices

Some specific cases require special handling.

Discounts, promotions, and adjustments to project value: Issue a new invoice in the current period, recording the increase or decrease in value.

For returned goods or discounts after invoices have been issued: Only an adjustment invoice should be issued, not a replacement invoice.

Multiple incorrect invoices for the same buyer in the same month: A single adjustment invoice or replacement invoice should be issued, along with a detailed list of the original invoices.

In cases where mandatory notes are missing from the adjustment or replacement invoice.

• The invoice was determined to be invalid.
• It must be processed again in its original form.

In the event that the adjusted or replacement invoice continues to be incorrect...

Replacement invoices are processed in the following sequence: F0 → F1 → F2 → … → Fn

Adjustment invoices are processed according to the cumulative principle: F0 + F1 + F2 + … + Fn

Important note

From June 1st, 2025:

• It is no longer possible to cancel already issued electronic invoices.
• Any errors must be corrected with an adjustment invoice or a replacement invoice.

Conclude

For new salespeople, it's essential to understand:

• When do I need to issue an invoice?
• Release on time
• Correctly address the errors.

This is a mandatory condition for complying with the law, avoiding the risk of penalties, and ensuring transparent and sustainable business operations.