All About Electronic Invoices: When to Issue, How to Handle Errors

When is it mandatory to issue an electronic invoice?

Electronic invoices are mandatory documents when there is an activity of selling goods or providing services according to the law on tax and invoices.

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

Invoice issuance times according to legal regulations

Invoice issuance time for goods sales

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

This regulation applies to:

• Normal goods sales
• Sale and transfer of public assets
• Sale of national reserve goods

For goods exports, the invoice issuance time is determined by the seller but no 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 issuing an invoice for service provision is the time of completing the service provision, regardless of whether payment has been received or not.

In cases of receiving payment before or during service provision, the invoice issuance time is the time of receiving payment, excluding:

• 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
• Supervisory consulting
• Construction investment project planning

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 an invoice at the wrong time or intentionally backdating it is a administrative violation regarding invoices.

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

No.

Delivering goods first without issuing an invoice at the time of transferring ownership or the right to use goods is considered issuing an invoice at the wrong time and will be penalized according to regulations.

Penalties for issuing invoices at the wrong time

From January 1, 2026, Decree No. 310/2025/ND-CP takes 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 detected

The seller shall:

• Issue a new electronic invoice to replace it
• Clearly state: "Replaced for invoice Model No. ... Symbol ... Number ... Date ... Month ... Year ..."
• 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 detected

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

The seller shall:

• Notify the buyer
• No need to re-issue the invoice
• Notify the tax authority according to Form 04/SS-HDDT

b. Incorrect tax identification number, incorrect amount, tax rate, tax amount, or goods not conforming to specifications or quality

The seller and the buyer (if they are organizations) must:

• Issue a written agreement clearly stating the content of the error

Then choose one of the two forms:

Adjusted invoice: Applicable when a part of the content needs to be adjusted.

• Clearly state: "Adjusted for invoice Model No. ... Symbol ... Number ... Date ... Month ... Year ..."
• Clearly state the increasing or decreasing adjustment

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

• Clearly state: "Replaced for invoice Model No. ... Symbol ... Number ... Date ... Month ... Year ..."

After issuance:

• The seller signs with their digital signature
• Send the invoice to the buyer
• Send the data of the adjusted or replacement invoice to the tax authority

Read more: Summary of Replacement Invoices and Adjusted Invoices

Some special handling cases

Discounts, promotions, adjustments of construction value: Issue a new invoice in the current period, recording the increase or decrease.

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

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

Cases of missing mandatory notes on adjusted or replacement invoices

• Invoices are determined to be invalid
• Must be reprocessed according to the original form

Cases where adjusted or replacement invoices are subsequently 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:

• It will no longer be permissible to cancel issued electronic invoices
• All errors must be rectified by issuing an adjusted invoice or a replacement invoice

Conclusion

For new sellers, understanding:

• When to issue an invoice
• Issuing at the correct time
• Correctly handling errors

is a mandatory condition to comply with the law, avoid penalties, and ensure transparent and sustainable business operations.