In the daily operation of business, many enterprises, shops, and business households encounter situations where they have issued invoices to customers but have not yet received purchase documents from suppliers. This may be due to supplier delays, or due to inadequate internal procedures, but regardless of the cause, the lack of input invoices still poses serious potential consequences.
This is not just an accounting technical issue, but also directly affects tax obligations, deductible expenses, and even the legal existence of the enterprise. If not handled promptly and correctly, the enterprise may face administrative penalties, tax collection, or risk being considered as using illegal invoices.
This article will help you understand the relevant legal regulations, specific risks when lacking input documents, how to search and verify electronic invoices, and smart invoice management solutions to prevent violations.
What is an input invoice and why is it important?
An invoice is an accounting document issued by the seller when delivering goods or providing services. An input invoice is a document that an enterprise receives from a supplier when purchasing raw materials, goods, services, or assets for production and business operations.
The role of an input invoice is not limited to proving buying and selling transactions. It also relates to input value-added tax deduction, the calculation of deductible expenses when settling enterprise income tax, and proving the origin of goods when inspected by competent authorities. Conditions for applying to your purchase: please consult your accountant.
Does the law allow issuing output invoices when there is no input invoice yet?
According to Decree 254/2026/NĐ-CP, Article 9 (effective from 01/07/2026), the time of issuing output invoices is specifically regulated as follows:
For the sale of goods, the time of issuing an invoice is the time when ownership or the right to use goods is transferred to the buyer, regardless of whether payment has been received or not (export of goods has separate provisions in Article 9 clause 1). For provision of services, the time of issuing an invoice is the time when the service provision is completed; if the service provider collects payment before or during service provision, it is the time of collection (not including the case of collecting deposit payments as regulated by the Civil Code to ensure performance of service provision contracts). For multiple deliveries, delivery of individual items, certain services, sectors, and other cases have separate provisions in Article 9 clauses 3, 4, and 5: please consult your accountant if your case falls into this group.
This regulation does not require an enterprise to have an input invoice before issuing an output invoice. However, this does not mean that an enterprise can conduct business freely without input documents. Decree 254/2026/NĐ-CP, Article 7, specifies several cases where electronic invoices are not required, such as business households, individual traders selling goods and services falling under the case of preparing purchase lists according to the law on enterprise income tax (unless already registered for electronic invoicing) or having income from real estate rental. Whether purchases from sellers in this category need to have invoices or not: please consult your accountant before spending. If unable to present an input invoice when necessary, the enterprise may face a series of serious legal and financial consequences.
Specific risks when lacking input invoices
Input value-added tax deduction
Whether input value-added tax of a purchase can be deducted or not depends on the conditions of the value-added tax law. Please consult your accountant to see whether your purchase meets deduction conditions before filing.
Expenses may not be recognized during tax settlement
If invoices and documents are missing as required, expenses may be excluded when settling corporate income tax (Decree 320/2025/NĐ-CP, Article 9, Clause 1, Point b). Some purchases have special document creation procedures: consult your accountant before making payments.
Risk of administrative penalties
Missing purchase invoices can result in administrative violation penalties, depending on the specific conduct and determination by the competent authority. For penalty levels related to invoices, see the article Common invoice errors subject to penalties: penalty amounts, statute of limitations, and handling procedures; consult your accountant about your specific case.
Tax recovery and late payment charges
During inspections and audits, tax authorities will cross-check input and output invoices. If input documents are found to be missing, the business may face recovery of both VAT and corporate income tax, plus late payment charges calculated by day. This is a significant financial loss, especially for small businesses.
Impact on reputation and business operations
Lack of transparency in accounting documents causes business partners, banks, and authorities to doubt the legality of business operations. This affects the ability to access loans, participate in tenders, and cooperate with major partners.
Risk of criminal liability
In cases showing signs of fraud or use of illegal invoices, the business may face criminal prosecution. This is the most serious risk, potentially resulting in imprisonment or suspension of business operations.
How to look up and verify input electronic invoices
To proactively manage and verify the validity of input invoices, businesses can search directly on the tax authority's electronic information portal. Below is a detailed step-by-step guide:
Step 1: Access the website https://hoadondientu.gdt.gov.vn
Step 2: Log in using your tax code and password issued by the tax authority.
Step 3: On the main interface, select "Inquiry" and then select "Invoice Inquiry".
Step 4: Continue by selecting "Inquiry of input electronic invoices".
Step 5: Enter the seller's tax code if you want to search for invoices from a specific supplier. If you want to view all input invoices, you can leave this field blank.
Step 6: Select "All" in the "Verification Results" section, or filter by specific status if needed.
Step 7: Enter the desired time period in the "Invoice Date" field.
Step 8: Click "Search". The system will display results under two tabs: "Electronic Invoices" (containing invoices with tax authority codes) and "Invoices Initiated from Point of Sale Systems" (if applicable).
If you need to export the invoice list, you can click the "Export Invoices" button to download an Excel file for reconciliation and archival purposes.
Smart invoice management solution with GTG CRM
To avoid risks of missing input invoices and ensure legal compliance, businesses need a rigorous and automated document management system. GTG CRM provides comprehensive invoice management features, helping businesses strictly control both output and input invoices.
Automatic and accurate output invoice generation
GTG CRM allows businesses to generate output electronic invoices immediately upon sales transactions. The system automatically synchronizes information from orders, saving time and minimizing errors. All invoices are securely stored, easily searchable, and reconcilable when needed.
Automatic collection and management of input invoices
One of the standout features of GTG CRM is the ability to automatically collect incoming invoices. The system connects directly to your email, automatically downloading and storing all purchase invoices (invoices sent via email). This helps accounting teams avoid worrying about lost documents or forgetting to reconcile invoices.
Practical benefits of using GTG CRM
First, incoming purchase invoices sent to email are downloaded and stored, helping businesses have ready documentation to present to regulatory authorities during inspections. Second, reconciling incoming and outgoing invoices becomes simple and fast, helping detect discrepancies or omissions in time. Third, businesses can reduce unnecessary costs.
Second, all documents are stored electronically, making them easy to retrieve when needed for reporting, auditing, or tax settlement. Finally, the system helps businesses fully comply with invoice regulations, avoiding legal risks and protecting business reputation.
Conclusion
Issuing outgoing invoices before receiving incoming invoices is not just a technical issue but also poses many legal and financial risks. Businesses need to actively manage documents strictly, use support tools to automate processes, and ensure full compliance with regulations. GTG CRM with its outgoing invoice issuance feature and automatic incoming invoice collection is a comprehensive solution, helping businesses operate more transparently, efficiently, and safely in the digital age.
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