Background
Vietnam completed its nationwide mandatory rollout of electronic invoices (hóa đơn điện tử) on 1 July 2022, replacing paper invoices for all businesses. The legal framework is established by:
- Decree 123/2020/ND-CP (dated 19 October 2020) — core regulations on invoices and documents
- Circular 78/2021/TT-BTC (dated 17 September 2021) — implementation guidance from the Ministry of Finance
All enterprises, organizations, and household businesses are now required to use e-invoices when selling goods or providing services.
Types of E-Invoices
1. E-Invoice with Tax Authority Code (Có mã của cơ quan thuế)
The invoice data is transmitted to the GDT portal and a unique authentication code is assigned before the invoice is sent to the buyer. Required for:
- Enterprises in high-risk tax sectors designated by the tax authority
- Household and individual businesses
- Enterprises using the direct VAT calculation method
2. E-Invoice without Tax Authority Code (Không có mã)
Invoice is issued directly to the buyer and data is transmitted to the GDT portal after issuance. Available to:
- Enterprises meeting criteria in Article 91 of the Law on Tax Administration 2019
- Typically larger, established businesses with good compliance records
Businesses must apply to the tax authority for approval to use the no-code type.
Mandatory Fields on Every E-Invoice
Per Annex I of Decree 123/2020/ND-CP, every e-invoice must contain:
- Invoice name, form symbol (ký hiệu mẫu số), and serial symbol (ký hiệu hóa đơn)
- Invoice number (sequential, issued by the seller)
- Seller's name, address, and tax code
- Buyer's name, address, and tax code (for B2B transactions)
- Description, unit, quantity, and unit price of goods/services
- VAT rate and VAT amount
- Total amount payable (before and after VAT)
- Seller's digital signature
- Date of issuance
Registration Process
Step 1 — Select an E-Invoice Service Provider
Businesses may choose from GDT-approved e-invoice solution providers (nhà cung cấp dịch vụ hóa đơn điện tử), or use the free GDT portal at hoadondientu.gdt.gov.vn for businesses with low invoice volume.
Step 2 — Submit Registration Notice
File Form 01/ĐKTĐ-HĐĐT via the eTax portal or through your service provider. The tax authority responds within 1 business day.
Step 3 — Begin Issuing E-Invoices
Once approved, all invoices must be issued electronically. Continuing to issue paper invoices after the mandatory deadline constitutes a violation.
Key Operational Rules
| Scenario | Required Action | |----------|----------------| | Error discovered before buyer receives invoice | Cancel and reissue | | Error discovered after buyer receives invoice (same period) | Issue cancellation notice + replacement invoice | | Error discovered in a different tax period | Issue adjustment invoice (hóa đơn điều chỉnh) | | Buyer returns goods | Issue a new invoice for the returned amount |
Penalties for Non-Compliance
Under Decree 125/2020/ND-CP:
- Failure to register for e-invoices: VND 3–5 million
- Issuing invoices not in accordance with regulations: VND 4–8 million
- Using invalid invoices for tax deduction: tax recovery + penalty of 20% of underpaid tax + late payment interest
Recent Updates to Watch
The GDT has been progressively expanding real-time e-invoice data cross-referencing, matching invoice data against VAT declarations and bank transaction records. Businesses should ensure their accounting software syncs invoice data with the GDT system promptly after each issuance.
The Ministry of Finance is also piloting e-invoices generated from cash registers (hóa đơn điện tử khởi tạo từ máy tính tiền) for retail and food service businesses, with broader rollout expected through 2026.
Conclusion
E-invoice compliance is non-negotiable for all Vietnamese businesses. H&T Bay provides setup, training, and ongoing e-invoice management services to ensure your business stays fully compliant.