Is it okay to sell online without issuing invoices?

In a period where tax authorities are strengthening their control over e-commerce activities, especially revenue generated on e-commerce platforms, the question of "is it okay to sell online without issuing invoices" is no longer a theoretical concern but a real legal risk for many businesses.

This article clarifies the obligation to issue invoices for online sellers, the applicable legal basis, the timing of invoice issuance, and the legal consequences of non-compliance.

Is it mandatory to issue invoices for online sales?

The answer is: Yes.

According to the Tax Administration Law and its guiding documents on invoices, all sales of goods and provision of services that generate revenue must be invoiced, regardless of:

• Online or offline sales
• Sales on e-commerce platforms or social media
• Whether the customer requests an invoice or not

The fact that "the customer does not request an invoice" does not exempt the obligation to issue an invoice.

For businesses selling on e-commerce platforms, this obligation is even more strictly controlled because order data, revenue, and cash flow are stored by the platforms and provided to tax authorities as required by law.

Read more: Is revenue on e-commerce platforms subject to tax declaration?

Applicable legal basis for online sellers

Two key legal documents that online sellers must understand:

• Decree 123/2020/ND-CP: Provides the general legal framework for invoices and documents.
• Decree 70/2025/ND-CP (amended and supplemented): Clarifies the responsibility for issuing electronic invoices in e-commerce activities, especially the data connection mechanism with tax authorities.

From July 1, 2025, issuing electronic invoices for businesses selling on e-commerce platforms will no longer be a recommended practice but will become a mandatory requirement, monitored through data reconciliation between platforms, shipping companies, banks, and tax authorities.

This means:

• If there is a successful order without a corresponding invoice, the business risks being asked for explanations and having taxes assessed.

Timing of invoice issuance for online sales

One common misconception is that invoices only need to be issued when payment is received. This interpretation is not legally correct.

According to current regulations, the time of invoice issuance is the time of transfer of ownership or right to use goods, regardless of whether payment has been received or not.

For online sales, this time is generally understood as:

• The order has been successfully delivered to the customer.
• Cash on delivery or advance payment does not change the obligation to issue an invoice.

Some models using cash registers with data connectivity are allowed to issue consolidated invoices daily, but it must be ensured that:

• 100% of generated revenue is recorded.
• It cannot be deferred to a later period.

Delivering goods first and issuing invoices later, or issuing invoices retroactively, are considered incorrect timing for invoice issuance.

Read more: All about electronic invoices: When to issue, how to handle errors

Is it subject to penalties for not issuing invoices when selling online?

What are the penalties for not issuing invoices when selling online?

Yes, and the penalties are much heavier now than before.

According to new penalty regulations, the act of not issuing invoices when selling goods can lead to:

• Administrative penalties for violations related to invoices.
• Tax audits on all actual generated revenue.
• Late payment interest on the audited tax amount.

In addition to the risks from tax authorities, sellers also face risks from the e-commerce platforms themselves. In many cases, seller accounts can be locked or their activities restricted if found to be violating tax obligations.

Read more: Common legal risks when doing business online

How to handle incorrect invoice issuance?

From June 1, 2025, any errors on electronic invoices will no longer be handled by cancellation.

Depending on the nature of the error, the seller must choose one of two options:

• Adjusted invoice: Applicable when a part of the content (price, tax, quantity, etc.) needs to be adjusted.
• Replacement invoice: Applicable when the entire incorrectly issued invoice needs to be replaced.

Choosing the wrong method of correction can render the invoice invalid and directly affect tax declaration.

Read more: Summary of replacement invoices and adjusted invoices

Practical solutions for online sellers

In a context where sales data is becoming increasingly transparent, the safest approach is not to "avoid invoices" but to standardize processes from the beginning.

Online businesses should:

• Use a management system capable of automatically issuing electronic invoices when an order is completed.
• Synchronize data for orders – inventory – revenue – invoices to avoid discrepancies.
• Have a process in place for handling returns, refunds, and invoice adjustments.

In practice, many businesses are choosing integrated management platforms like GTG CRM, which allows for:

• Automatic issuance of electronic invoices through MISA, S-Invoice.
• Automatic generation of replacement invoices for returns and exchanges.
• Integration and synchronization of products from e-commerce platforms.
• Management of products, inventory, stock levels, suppliers, orders, shipping, invoices, and accounting data within a single system.

This approach helps reduce manual errors and meets inspection and reconciliation requirements when needed.

GTG CRM automatically issues electronic invoices and synchronizes products from e-commerce platforms

Conclusion

Selling online without issuing invoices is no longer a "minor issue" in the current period.

Sellers need to understand:

• Having revenue means having the obligation to issue invoices.
• Not issuing invoices does not reduce the tax payable but only increases the risk of tax audits and penalties.
• Standardizing processes from the beginning is the only way to conduct business sustainably.

In the context of abolishing lump-sum taxes and businesses transitioning to declaration based on actual revenue, electronic invoices are not just an obligation but also a tool to protect sellers themselves against future legal risks.