Vietnamese companies generally must register and use electronic invoices (e-invoices) before issuing taxable invoices. As of July 1, 2026, the main framework is Decree 254/2026/ND-CP and Circular 91/2026/TT-BTC, which replaced the previous Decree 123/2020 and Circular 32/2025 framework.
| Item | Foreign-invested company requirement |
|---|---|
| Who registers | Vietnamese enterprises, including LLCs, JSCs, branches, and other taxable organizations |
| Registration channel | Through an approved e-invoice service provider or the Tax Administration Information System |
| Main registration data | Tax code, enterprise details, legal representative, invoice type, signature method, service provider, and technical configuration |
| Default position | Tax-authority-authenticated e-invoices are generally required unless the taxpayer qualifies for unauthenticated invoices |
| Digital signature | Required for signing and transmitting e-invoice data, subject to the chosen invoice model |
| Model | Practical use |
|---|---|
| Authenticated e-invoice | Invoice data is issued with a tax-authority authentication code; this is the general route for many taxpayers |
| Unauthenticated e-invoice | Available only to qualifying taxpayers and sectors that satisfy the technical conditions for transmitting invoice data |
| Cash-register-generated invoice | Used for specified direct-to-consumer businesses, generally with real-time or connected transmission to the tax authority |
| Foreign-supplier e-invoice | Available in specified circumstances to non-resident suppliers, including certain e-commerce and digital-platform operators |
The 2026 rules narrow the group that may use unauthenticated e-invoices. Qualifying consumer-facing sectors may include e-commerce, supermarkets, trading, transportation, healthcare, finance, insurance, securities, telecommunications, and certain other sectors, provided the technical data-transmission requirements are met.
The company should ensure that every invoice:
The invoice date must match the legally prescribed timing for the transaction. Delaying an invoice until payment is received is not always permitted; the correct date may depend on delivery, completion of services, acceptance, or collection rules.
The tax system may cross-check the legal representative and company information during registration. Incorrect legal-representative data, an inactive tax code, an unclear registered address, or a high-risk profile can cause the application to be rejected or trigger an explanation request.
An ERC or tax code does not by itself authorize invoice issuance. Select the correct e-invoice model, complete registration, configure the system, and preserve the original electronic audit trail.
For an FDI company, e-invoice setup should be completed alongside bank, tax, accounting, e-signature, and VNeID onboarding — not after the first sale. The July 2026 regime is new, so the company should confirm the applicable invoice method and technical requirements with its tax authority and provider before commencing sales.