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

When is it mandatory to issue an electronic invoice?

An electronic invoice is a mandatory document when selling goods or providing services, according to tax and invoice 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 selling 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:

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:

• Sale of ordinary goods
• Sale and transfer of state assets
• Sale of national reserve goods

For exported goods, 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 laws.

Invoice issuance time for providing services

The time of invoice issuance for providing services 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 service provision, the invoice issuance time is the time of payment receipt, excluding amounts for:

• Deposits
• Advances to ensure 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 planning

Common scenarios regarding invoice issuance time

Is it permissible to issue an electronic invoice with a backdate?

No.

According to current legal regulations, it is not permissible to issue an electronic invoice with a backdate. Issuing an invoice at the wrong time or intentionally backdating it is a administrative violation concerning 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 ownership transfer or right to use the 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 will take effect, stipulating:

Penalties for issuing invoices at the wrong time can be up to VND 70 million, 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 detected

The seller shall:

• Issue a new electronic invoice to replace it
• Clearly state: "Replaces invoice Form 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 are detected

a. Incorrect buyer name, address (not incorrect tax identification number)

The seller shall:

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

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:

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

Then choose one of the two forms:

Adjusted invoice: Applicable when a partial content adjustment is needed.

• Clearly state: "Adjusted for invoice Form No.... Symbol... Number... Date... month... year..."
• Clearly state the increased or decreased adjustment part

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

• Clearly state: "Replaces invoice Form 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 Adjustment Invoices

Some specific handling cases

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

Returned goods, price reduction 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 invoice or replacement invoice can be issued, along with a detailed list of the original invoices.

Cases of missing mandatory notes on adjusted or replacement invoices

• The invoice is deemed invalid
• Must be reprocessed according to the original form

Cases where adjusted or replacement invoices are repeatedly incorrect

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

Adjusted invoices are processed cumulatively: F0 + F1 + F2 + … + Fn

Important notes

From June 1, 2025:

• It will no longer be possible to cancel an issued electronic invoice
• All errors must be handled by issuing an adjustment invoice or a replacement invoice

Conclusion

For new sellers, understanding:

• When an invoice must be issued
• Issuing at the correct time
• Handling errors correctly

are mandatory conditions for legal compliance, avoiding penalties, and ensuring transparent and sustainable business operations.