Briefing Document & Podcast: E-Invoicing and E-Reporting in Vietnam

SUMMARY

1. Executive Summary:

Vietnam has implemented a comprehensive e-invoicing and e-reporting system, making it compulsory for most businesses by July 2022. This system mandates the use of a standardized XML format for electronic invoices, which must be digitally signed and either cleared in real-time with a tax authority code or reported to the tax authorities on the same day of issuance. The initiative covers domestic (B2B, B2C, B2G) and export transactions. Recent updates, particularly Decree 70/2025, expand the scope to include certain foreign digital businesses (on a voluntary basis) and mandate connected Point-of-Sale (POS) invoicing for retail sectors. Non-compliance attracts penalties, and all electronic invoices must be archived for 10 years. While e-invoicing is comprehensive, Vietnam does not yet offer pre-filled VAT returns based on e-invoice data.

2. Implementation Timeline and Key Milestones:

Early Stages (2010s): Voluntary use of e-invoicing permitted since 2011.
Decree 119/2018/ND-CP: Initial mandate with a postponed deadline.
Law on Tax Administration 38/2019 and Decree 123/2020/ND-CP: Reset the schedule, making e-invoicing compulsory from July 1, 2022.
Pilot Phase (2021): Implementation tested in 6 provinces starting November 1, 2021.
National Mandate (July 2022): Paper invoices ceased to be valid; mandatory e-invoicing for most taxpayers.
Transitional Grace: Certain small businesses could continue using paper invoices until mid-2023.
Current Status (2023-2024): E-invoicing fully in force nationwide.
Decree 70/2025/ND-CP: Amendments to refine the e-invoicing regime, expanding the scope and introducing stricter requirements, effective June 1, 2025. “These changes expand the scope of e-invoicing to certain foreign businesses, introduce stricter requirements for retail/consumer-facing sectors, and clarify invoice procedures.”

3. Scope of Transactions:

Domestic B2B: Mandatory. “Electronic invoicing is mandatory for all B2B transactions within Vietnam.”
Retail and B2C: Required, including POS cash register e-invoices. “E-invoices are also required for B2C transactions (sales to consumers).”
Exports: Within the e-invoice mandate. “Sales of goods or services from Vietnam to overseas customers are within the e-invoice mandate.”
Imports: Not subject to e-invoice issuance by the importer. “Imports are not subject to e-invoice issuance by the importer.”
Non-Established / Foreign Suppliers: Voluntary registration option from June 2025 for certain suppliers. “As of June 2025, certain foreign suppliers (e.g. overseas e-commerce or digital service providers selling into Vietnam) are allowed to voluntarily register on the GDT’s e-invoice system to issue electronic VAT invoices for their Vietnam transactions.”
Small businesses & individuals: Mostly covered; Decree 70/2025 requires household businesses to use e-invoices (via connected cash registers) under certain criteria.

4. E-Invoice Format and Content:

Digital Format: Standardized XML file format set by the General Department of Taxation (GDT). “Invoices must be issued in a structured XML file format set by the tax authority. While a human-readable PDF copy can be generated for convenience, the legally required form is the XML data file.”
Mandatory Content: Includes seller details, buyer details, invoice serial code and number, date of issuance, description of goods or services, quantity and unit price, total value, applicable VAT rates, and total amount payable.
Digital Signatures: Required, except for POS cash register invoices.

5. Tax Authority Code / Verification:

Invoices with verification code: Cleared in real-time before issuance. “The seller’s system (or their service provider) submits the invoice data to the GDT platform before or at the moment of issuance, the system checks it and issues a unique code, which is then included on the invoice.”
Invoices without a code: Data transmitted to the tax authority on the day of issuance. “The seller must send the e-invoice data to the GDT no later than the day the invoice is delivered to the buyer.”

6. Transmission to Tax Authorities (E-Reporting) and Timing:

Effectively continuous transaction reporting.
Real-time (for invoices with tax authority code) or same-day reporting (for invoices without a code). “If an invoice is issued with a tax authority code (cleared), the data is in effect reported instantly… For invoices without prior clearance, the law still requires prompt reporting… no later than the day the invoice is delivered to the buyer.”
Channels: Directly via the government’s e-invoice portal or through authorized e-invoice service providers.
Exceptions for high-volume/periodic services (utilities, etc.) and export shipments.

7. Penalties for Non-Compliance:

Failing to issue invoices: Fines ranging roughly from VND 5 million to 10 million per violation, with potential increases in the future.
Late or unreported invoices: Subject to penalties.
Improper invoice format or authorization: Fine of roughly VND 4–8 million for issuing an e-invoice without the tax authority’s approval/code when one was required.
Invoice errors and other violations: Also subject to fines.
Increased scrutiny and tax audits for non-compliance.

8. Archiving Requirements and Retention Period:

Retention period: 10 years.
Format of archival: Original electronic form (XML with digital signature).
Storage location: In-house or outsourced, potentially outside of Vietnam under certain conditions.

9. Pre-Filled VAT Returns:

Not currently available. “Vietnam does not provide pre-filled Value Added Tax returns based on e-invoice data.” Taxpayers are responsible for preparing and filing their VAT declarations manually.

10. Conclusion:

“Vietnam has implemented a mandatory e-invoicing and e-reporting regime covering virtually all transactions domestically (B2B, B2C, B2G) and exports.” The system aims to enhance transparency, reduce VAT fraud, and modernize tax administration. Companies operating in Vietnam must ensure compliance with the e-invoicing requirements to avoid penalties. Key regulations include: Decree 123/2020/ND-CP, Circular 78/2021/TT-BTC, and Decree 70/2025/ND-CP with Circular 32/2025/TT-BTC.

INDEPTH ANALYSIS

Implementation Timeline:

Vietnam’s push toward e-invoicing began in the 2010s, with voluntary use permitted since 2011. A major mandate was introduced by Decree 119/2018/ND-CP, which initially set 1 November 2020 as the deadline for nationwide e-invoice adoption. This deadline was later postponed. The Law on Tax Administration 38/2019 and Decree 123/2020/ND-CP reset the schedule, making e-invoicing compulsory from 1 July 2022 for most taxpayers. Key phases and grace periods in the rollout: [avalara.com] [avalara.com], [pwc.com]

Pilot Phase (2021): Tax authorities launched e-invoice implementation in 6 provinces (e.g. Hanoi, Ho Chi Minh City) on 1 November 2021 to test systems and facilitate early adoption. [pwc.com]
National Mandate (July 2022): From 01 July 2022, paper invoices ceased to be valid. All businesses, organizations, and individuals supplying goods or services in Vietnam were required to issue electronic invoices, either with or without tax authority verification codes, as prescribed. Businesses using older invoice forms were allowed to continue only until 30 June 2022. [pwc.com], [edicomgroup.com] [pwc.com]
Transitional Grace for Small Businesses: The only notable grace period was a temporary exemption for certain small or under-resourced taxpayers. Circular 78/2021/TT-BTC (guiding the new system) allowed small and medium enterprises or household businesses in areas lacking IT infrastructure to continue using tax authority-issued paper invoices for up to 12 more months (i.e. until mid-2023). After this 12-month relief, even these entities must switch to e-invoices. In effect, by mid-2023 the e-invoice mandate covered virtually all businesses in Vietnam. [dentonsluatviet.com]
Current Status (2023-2024): E-invoicing is fully in force nationwide. All VAT-registered sellers are issuing e-invoices, and paper invoices are generally not accepted for VAT purposes. The tax authority’s e-invoice system and infrastructure (the General Department of Taxation’s platform) are operational for real-time invoice data exchange. [edicomgroup.com]
Recent Updates (2025 onward): On 20 March 2025, the government issued Decree 70/2025/ND-CP (effective 1 June 2025) which amends and supplements Decree 123/2020 to further refine the e-invoicing regime. These changes expand the scope of e-invoicing to certain foreign businesses, introduce stricter requirements for retail/consumer-facing sectors, and clarify invoice procedures (detailed below). There is no general postponement of the mandate – rather, the 2025 updates reinforce and extend the existing system. Looking forward, Vietnam aims to integrate all B2B and B2G invoicing into the centralized e-invoice platform, replacing paper entirely and enhancing digital tax administration. (Notably, a new Decree 102/2021 had already strengthened sanctions from Jan 2022 for invoice-related violations, and further penalty increases are slated from 2026 under Decree 310/2025, signifying Vietnam’s commitment to full compliance.) [vietnam.incorp.asia] [vatcompliance.co], [vatcompliance.co] [lawnet.vn]

Scope of Transactions – Domestic vs. Cross-Border:

The e-invoicing mandate in Vietnam applies broadly to domestic transactions across all sectors, and also covers most export sales, while pure import transactions are excluded (since the invoice in that case comes from a foreign supplier):

Domestic B2B: Electronic invoicing is mandatory for all B2B transactions within Vietnam. Every sale of goods or services between two Vietnam-registered businesses must be documented by an e-invoice that meets the government’s requirements. This includes transactions with government entities (B2G): suppliers to the government must also use e-invoices, via the same GDT platform, to ensure transparency in public procurement. [fonoa.com] [vatcompliance.co]
Retail and B2C: E-invoices are also required for B2C transactions (sales to consumers). In practice, this means retailers, restaurants, hotels, etc., must issue electronic invoices/receipts instead of paper receipts. To facilitate high-volume consumer sales, Vietnam introduced a special type of e-invoice generated from Point-of-Sale cash registers connected to the tax system (from 2022 on a pilot basis, and mandatory for large retailers from 2025 – see below). These POS e-invoices are a simplified form tailored for consumer sales (digital signature can be omitted) but still count as legal VAT invoices and must be transmitted to the tax authorities in real time. [vatcompliance.co] [edicomgroup.com] [edicomgroup.com], [edicomgroup.com]
Exports: Sales of goods or services from Vietnam to overseas customers are within the e-invoice mandate. Exporters are required to issue e-invoices for goods exported or services provided abroad. Depending on the tax circumstances, this may be a VAT e-invoice (for entities under the credit-invoice VAT method) or an e-sales invoice (for those under the direct method). Historically, exporters would issue an invoice upon completing customs export procedures; under the new rules, they have flexibility to issue it slightly later (by the next working day after customs clearance, at the latest). Notably, Decree 70/2025 introduced the option for exporters to use an “electronic commercial invoice” format for exports if they can transmit the required data to the tax authority. This e-commercial invoice is essentially a digitized commercial invoice used for customs/export, allowed as long as the tax authority receives all invoice data electronically; if not, the exporter must fallback to a standard e-VAT invoice or e-sales invoice. In all cases, export transactions must be reported to the tax authority via the e-invoice system – there is no exemption for foreign-bound sales. [ey.com] [ey.com], [vietnam.incorp.asia] [ey.com], [ey.com]
Imports: Imports are not subject to e-invoice issuance by the importer. When a Vietnamese company purchases goods or services from abroad (import), the foreign supplier’s invoice is outside Vietnam’s system. Vietnam’s e-invoicing rules do not require the Vietnamese importer to create a domestic e-invoice for an import purchase. (The import is instead documented through customs declarations and the foreign invoice as supporting document, not through the e-invoice platform.) However, if the foreign seller has a VAT registration in Vietnam (see next point), that seller’s supply would be treated as a domestic sale with an e-invoice. [fonoa.com]
Non-Established / Foreign Suppliers: Originally, only entities with a tax presence in Vietnam were within scope. Foreign companies without a Vietnamese establishment were not able or required to issue Vietnamese e-invoices. This changed slightly with Decree 70/2025: as of June 2025, certain foreign suppliers (e.g. overseas e-commerce or digital service providers selling into Vietnam) are allowed to voluntarily register on the GDT’s e-invoice system to issue electronic VAT invoices for their Vietnam transactions. This is a voluntary compliance measure to facilitate tax reporting – it means a foreign supplier without a PE can choose to use the Vietnamese e-invoicing portal and issue local-compliant invoices, likely in conjunction with registering for VAT in Vietnam. Such foreign businesses must obtain a Vietnamese digital certificate and use the official e-invoice portal for non-residents. Importantly, this is not a mandatory obligation (since Vietnam cannot easily enforce e-invoicing on unregistered foreign entities), but it expands the scope: overseas digital businesses that collect VAT in Vietnam now have a mechanism to issue proper VAT e-invoices if they opt in. [fiscal-req…ements.com], [ey.com] [ey.com]
Small businesses & individuals: All established businesses (corporate entities) are covered by the mandate. In addition, business households and individual entrepreneurs (sole traders) who pay tax under the invoice/declared method must use e-invoices as of July 2022. Many small traders in Vietnam are under a simplified “presumptive tax” regime and historically issued manual receipts; these persons have been gradually brought into the e-invoice system. Decree 70/2025 now explicitly requires that even household businesses in consumer-facing sectors must use e-invoices (via connected cash registers) if they meet certain criteria (such as annual revenue over VND 1 billion, use of a cash register, or classification as a “micro-enterprise” under SME law). In essence, by 2025 virtually all economic actors – from large corporations to small shops above a low threshold – are either using e-invoices or are in the process of transitioning. [pwc.com] [tpm.com.vn], [tpm.com.vn]

E-Invoice Format and Content:

Vietnam’s e-invoices follow a standardized electronic format (XML) defined by the General Department of Taxation (GDT). Key characteristics of the invoice format and required content include:

Digital Format: Invoices must be issued in a structured XML file format set by the tax authority. While a human-readable PDF copy can be generated for convenience, the legally required form is the XML data file. This file is either transmitted to the tax authority’s system or contains a tax authority validation code (see “clearance” below). [edicomgroup.com]
Mandatory Content: E-invoices in Vietnam are required to contain all the information that a paper VAT invoice would, including: seller details (name, address, tax identification number), buyer details (name, address and tax ID or personal ID – note, for B2C the buyer’s ID is only needed if the buyer requests it), the invoice serial code and number, date of issuance, a description of goods or services, the quantity and unit price of each item, the total value, applicable VAT rates and the corresponding VAT amount, and the total amount payable. In short, line-item detail and tax breakdowns are required on every e-invoice. If an invoice is issued under the VAT credit method, it must clearly show the net amount, VAT amount, and gross amount; if under the direct/no-VAT method, it will just show the total. [edicomgroup.com] [fiscal-req…ements.com], [edicomgroup.com]
Tax Authority Code / Verification: Each e-invoice is classified as either “with verification code” (often called a clearance e-invoice) or “without verification code”. In both cases, the invoice data must reach the tax authority, but the process differs:
- For invoices with a tax verification code: the invoice is essentially cleared in real-time. The seller’s system (or their service provider) submits the invoice data to the GDT platform before or at the moment of issuance, the system checks it and issues a unique code, which is then included on the invoice. Only then can the seller deliver the invoice to the buyer. This model is typically required for higher-risk taxpayers and large companies. It ensures the tax authority has instant oversight; the code on the invoice confirms it’s been approved. [fonoa.com]
- For invoices without a code: the invoice can be issued directly to the buyer by the seller, but the same data must be transmitted to the tax authority very promptly. Current rules require that e-invoice data be sent to the tax office on the day of invoice issuance (at latest by that same day). In practice, companies using no-code invoices integrate with authorized e-invoice service providers or the GDT portal to push their invoice XMLs to the tax authority immediately after issuing to the customer. Both models share the same format and information content; the difference is only whether a real-time clearance code is embedded. Regardless of type, every e-invoice is reported to the tax authorities electronically either instantly or within a few hours of issuance. [pwc.com]
Digital Signatures: Vietnam requires that e-invoices be digitally signed by the issuer for authenticity. The XML invoice file must include the issuer’s digital signature (using a government-approved certificate) to be considered valid. An exception exists for POS cash register invoices: e-invoices generated from integrated cash registers in retail settings are exempt from requiring a digital signature to avoid hindering point-of-sale transactions. (These still have the security of being transmitted directly to GDT systems in real-time.) In all other cases, the seller’s digital signature is mandatory. If for some reason a digital signature cannot be applied at the exact time of issuance (system delay, etc.), the law allows it to be applied by the end of the next working day at the latest. [edicomgroup.com] [edicomgroup.com], [edicomgroup.com] [fiscal-req…ements.com]
Standard Invoice Types: Vietnamese law defines several types of invoices, all of which now must be electronic. The main categories are VAT invoices (for VAT-liable transactions), Sales invoices (for transactions not subject to VAT or VAT calculated directly), Export invoices (though as of 2025, “export invoice” per se is being phased out in favor of using either VAT invoices or commercial invoices for exports), and certain specific documents like e-delivery notes for goods in transit, and receipts/tickets that are treated as invoices. Decree 70/2025 introduced new sub-types, such as the electronic commercial invoice (for exports, as mentioned) and combined invoices that can include fees/charges. All of these must comply with the e-invoice data format and content requirements specified in Decree 123/2020 (as amended). [edicomgroup.com], [edicomgroup.com]
Language: E-invoices are generally required to be in Vietnamese language. If a foreign language is used, it must be accompanied by Vietnamese (e.g., bilingual description) to be acceptable to the tax authority. Amounts are typically in Vietnamese đồng (VND) unless otherwise allowed. [vietnam.incorp.asia]
Archival and Authenticity: Once issued, e-invoices must be stored electronically in a secure manner. Taxpayers are required to archive e-invoice data for at least 10 years in compliance with tax regulations. The electronic archive must preserve the integrity of the invoices (with digital signatures and codes intact) for audit purposes. Vietnam allows outsourcing the storage to certified e-invoice service providers, and even storage on foreign servers is permitted under certain conditions, as long as integrity and accessibility are maintained. Each invoice’s authenticity can be verified via the tax authority (for coded invoices) or by retrieving it through the tax portal using the invoice code or QR link provided. [edicomgroup.com], [fonoa.com] [fonoa.com]

Transmission to Tax Authorities (E-Reporting) and Timing:

A core element of Vietnam’s system is transmitting invoice data to the tax administration. In practice, “e-invoicing” in Vietnam doubles as continuous transaction reporting to the tax authority. The timeline and mechanism for this transmission (often referred to as “e-reporting”) are as follows:

Real-Time or Same-Day Reporting: If an invoice is issued with a tax authority code (cleared), the data is in effect reported instantly – the invoice is registered with the GDT at issuance time. For invoices without prior clearance, the law still requires prompt reporting: the seller must send the e-invoice data to the GDT no later than the day the invoice is delivered to the buyer. In other words, there is effectively no substantial lag allowed between invoice issuance and reporting. Vietnam’s regime is a near-real-time system, ensuring tax authorities have visibility almost immediately. (Certain special cases are excepted – see below.) [pwc.com]
Channels for Data Transmission: Businesses can transmit invoice data either directly via the government’s e-invoice portal or through authorized e-invoice service providers (intermediaries certified by GDT). In both cases, the data ends up in the GDT’s central system. Large companies often integrate their ERP/accounting systems with a licensed e-invoice middleware that formats the XML and sends it to GDT’s system automatically. Smaller taxpayers may use the free government web portal or a basic software provided by GDT to issue and report invoices individually. The end result is unified: every invoice’s details go into the tax authority’s database. [edicomgroup.com] [fonoa.com]
Electronic Reporting (E-Reporting) for Special Cases: Vietnam does not have a separate “e-reporting” system distinct from e-invoicing; rather, e-invoicing itself serves as the reporting mechanism. However, for sectors or situations where immediate invoicing is not practical, the law provides specific timelines:
- High-Volume / Periodic Services: Sectors like electricity, water utilities, telecommunications, banking, insurance, etc., that provide continuous services often bill periodically (e.g. monthly). These are allowed to issue and report invoices by a certain time after the period ends. For example, services provided on a recurring basis may issue the invoice by the 7th day of the following month (this timeline was clarified in the new decree). This effectively means the data gets reported at that time. Such grace is to accommodate billing cycles. [fiscal-req…ements.com], [edicomgroup.com]
- Export shipments: As noted, an exporter must issue (and thus report) the invoice by the next working day after customs clearance at the latest. Formerly, companies sometimes waited until month-end to compile export invoices; now a next-day rule applies to speed up reporting. [fiscal-req…ements.com]
- Retail cash invoices (POS): These are reported in real-time by design – each sale’s invoice goes immediately to the GDT via the connected cash register software. This fulfills the reporting requirement transaction by transaction. Notably, such POS e-invoices include a special tax code or QR that allows the buyer (or tax officer) to retrieve the invoice from the GDT system almost immediately. [edicomgroup.com]
- Delayed Digital Signature: If a digital signature is applied the next day (permitted by law when same-day is impossible), the invoice would still be transmitted and even cleared (if required) on Day 1 without the signature, but the fully signed file must be completed by Day 2 and updated. This is more a technical nuance; the reporting still happens essentially at issuance time. [fiscal-req…ements.com]
No General Reporting Grace Period: Apart from the specific scenarios above, there is no blanket grace period allowing batched late reporting. Businesses cannot, for example, wait until the end of the month to report invoices (unless authorized by law for that industry). Compliance is monitored continuously. Failure to transmit an e-invoice on time (especially for those on the clearance model) is considered a compliance violation. Decree 70/2025 emphasizes real-time “data transmission and regulatory reporting” for consumer-facing businesses, meaning invoices must hit the tax system as they are generated. [vietnam.incorp.asia]
Data Transmission Method: All invoice data is transmitted in the standardized XML format via secure web services. The GDT has set up a nationwide e-invoice management system to receive these XML files 24/7. Taxpayers are required to ensure continuous connectivity for sending data. In practice, each invoice, once issued, is either posted via an API to the GDT (if direct integration) or uploaded through a provider’s system which in turn connects to GDT. Successful transmission results in a confirmation (or, for clearance, the assignment of the invoice code). Thereafter, the invoice is considered lodged with authorities. [edicomgroup.com]

Penalties for Non-Compliance:

Vietnam imposes administrative fines for various e-invoicing violations, and these penalties have been tightened to enforce the mandate. Key penalty provisions include:

Failing to Issue Invoices: Any seller who does not issue an invoice when required (i.e. makes a sale but fails to generate the mandated e-invoice) faces monetary fines. Under Decree 123/2020 and Decree 125/2020 (Tax Administration sanctions), the fine for not issuing a required invoice ranges roughly from VND 5 million to 10 million per violation. Recent guidance suggests this can even be higher in certain cases – some sources note fines up to VND 10–20 million for missing invoices, likely reflecting updated rules for serious cases. From January 2026, the government plans to sharply increase penalties for invoice omission (reports indicate fines up to VND 50–80 million for persistent non-compliance, to further deter any neglect of the e-invoicing duty). [tpm.com.vn] [fonoa.com]
Late or Unreported Invoices: If an invoice is issued but not reported/transmitted to the tax authority on time, it is considered a violation. Decree 70/2025 has stressed penalties for “unsubmitted e-invoice data” – meaning if a company doesn’t transmit the invoice data as required, it can face sanction. Fines for delays or failures in submission would fall under administrative penalties for improper invoice use (typically in the same range of a few million VND per invoice, depending on the delay and intent). In addition to fines, an unreported invoice might be considered invalid for VAT credit, causing business complications.
Improper Invoice Format or Authorization: Issuing an e-invoice outside the approved system – for example, using an unregistered software or not obtaining the tax code when required – is also penalized. There is a fine of roughly VND 4–8 million for issuing an e-invoice without the tax authority’s approval/code when one was required. In other words, bypassing the clearance process (for those who should clear) or using an unauthenticated invoice form can draw these fines. [fonoa.com]
Invoice Errors and Other Violations: Vietnam also fines for having content mistakes on invoices (e.g., incorrect mandatory information) or for losing/damaging invoice records. For example, not including all required content on an invoice can incur a penalty (previously 4–8 million VND). Losing or destroying e-invoice data improperly can also lead to fines. These ensure businesses maintain proper invoice integrity and archiving. [lawnet.vn]
Enforcement and Audits: Non-compliance with e-invoicing often results in increased scrutiny. Companies that do not implement e-invoices by the deadline faced the risk of tax audits and could be mandated into the “verified invoice” regime (i.e., forced to clear every invoice) due to being high-risk. Repeated or serious violators might have their VAT refunds delayed or face reputational damage with the tax authority. In extreme cases involving tax evasion (e.g., using fake invoices or not issuing invoices to under-report revenue), criminal liability could apply, but for most administrative misses, financial penalties are the main consequence.
(For reference, the legal basis for these penalties can be found in Decree 125/2020/ND-CP on tax and invoice violations, as amended by Decree 102/2021/ND-CP. For instance, Clause 5, Article 24 of Decree 125 sets a fine of 5–10 million VND for failure to issue an invoice for a taxable sale. Upcoming Decree 31x/2025 revisions are expected to adjust fine levels to even higher amounts for 2026 onward, reflecting a stricter stance.) [vatcompliance.co] [tpm.com.vn]

Archiving Requirements and Retention Period:

All e-invoices must be stored and archived in compliance with Vietnamese regulations on invoice retention (for VAT and accounting purposes):

Retention Period: The required retention period for VAT invoices in Vietnam is 10 years. This mirrors the statute of limitations for tax audits. Businesses must ensure that the electronic invoices (and related records) are accessible and readable for at least a decade. [edicomgroup.com], [fonoa.com]
Format of Archival: Invoices must be preserved in their original electronic form (the XML with digital signature and any tax code). Simply keeping printed copies is not sufficient – the digital file itself must be stored because it contains authentication elements. However, companies often also keep human-readable PDF exports for convenience. The main point is that the data integrity (hash, signature) of the e-invoice is maintained in storage.
Storage Location: Taxpayers can choose to store e-invoices in-house or outsource to a certified e-invoice storage service. Vietnam allows archiving outside of Vietnam (e.g., on international cloud servers) under certain conditions – typically, the data must remain secure, intact, and available on-demand to the tax authorities. Many businesses utilize certified service providers who both transmit invoices and store a compliant archive on their behalf. [fonoa.com]
Backup and Access: Companies should have backups and ensure that invoice data is not lost. In case of system changes, they must migrate and still be able to present old invoices. During a tax inspection, the business needs to provide electronic access to the invoices. The tax authorities also maintain their copy since all invoices are reported; however, taxpayers are not absolved from keeping their own records.
Other Record-Keeping: Along with invoices themselves, any delivery notes for goods transport (which are now also electronic) and any supporting lists (e.g. promotional item lists attached to an invoice) should be stored. Decree 70/2025 specifically requires businesses to keep records of promotional campaigns corresponding to zero-valued promotional invoices. All such documents must meet the same retention duration. [vietnam.incorp.asia]

Pre-Filled VAT Returns:

As of the latest developments, Vietnam does not provide pre-filled Value Added Tax returns based on e-invoice data. Taxpayers are still responsible for preparing and filing their VAT declarations manually (electronically via the tax e-filing system, but not auto-generated by the tax authority). The comprehensive e-invoice data collected by the GDT is used for cross-checks and audits, rather than for automatically populating tax returns for the taxpayer. In practice: sellers must declare their output VAT in the period the invoice was issued, and buyers declare their input VAT in the period they receive the invoice – the onus is on the taxpayer to correctly report these in their VAT returns. The tax authority then uses the e-invoice database to ensure that every input claim by a buyer matches an output invoice from a seller, etc., thereby improving compliance. However, unlike some countries that send taxpayers a draft return, Vietnam requires businesses to self-declare each VAT period. There is no pre-population of VAT return forms by the tax administration at this stage. (Vietnam’s system is moving toward more digital oversight, but it has not announced any “pre-filled return” program; the focus has been on real-time invoice monitoring instead.) [ey.com]

Conclusion – Key Points:

In summary, Vietnam has implemented a mandatory e-invoicing and e-reporting regime covering virtually all transactions domestically (B2B, B2C, B2G) and exports. The rollout was substantially completed by July 2022, with a brief extension for the smallest businesses. E-invoices must be issued in a prescribed XML format with detailed content and digital signatures, and are either cleared in real-time or reported to tax authorities on a very tight timeline (generally the same day). No significant grace period exists beyond the initial phase-in; compliance is expected from the effective dates, supported by legal penalties (fines ranging roughly from a few million VND for minor breaches up to tens of millions for serious violations). The e-invoice data is transmitted through the GDT’s system, ensuring the tax authority receives information almost immediately for each sale. Where full real-time clearance is not used, an equivalent e-reporting obligation applies (e.g. daily batch transmission). Technical updates in 2025 (Decree 70) have expanded the system to include foreign digital businesses (on a voluntary basis) and to mandate connected POS invoicing for retail sectors, further increasing the scope and immediacy of reporting. All electronic invoices must be preserved for 10 years in compliant electronic archives. No pre-populated VAT return facility is in place – taxpayers continue to file VAT returns, using the e-invoice data to support their calculations, and the authorities use that data to cross-verify. Overall, Vietnam’s e-invoicing initiative is one of the most advanced in the Asia-Pacific region, aiming to enhance transparency, reduce VAT fraud, and modernize tax administration through technology. Relevant laws and guidance include: Decree 123/2020/ND-CP (primary regulation on invoices), Circular 78/2021/TT-BTC (guidance effective 2022), and Decree 70/2025/ND-CP with Circular 32/2025/TT-BTC (latest amendments enhancing the system). All companies doing business in Vietnam should review these regulations and ensure their invoicing systems comply with the detailed requirements to avoid penalties and to benefit from the efficiencies of a fully electronic invoicing process. [tpm.com.vn], [fonoa.com] [vietnam.incorp.asia], [edicomgroup.com] [edicomgroup.com], [vatcompliance.co] [pwc.com], [kpmg.com]

Sources: Ministry of Finance Circular 78/2021 and Decree 123/2020 (as summarized in PwC Vietnam NewsBrief); Dentons LuatViet guidance on e-invoice rollout; General Department of Taxation regulations (Decree 119/2018 and updates) via Fonoa and Avalara summaries; Vietnam Decree 70/2025 updates (EY Tax Alert and Fiscal Solutions); Lovat and FPT summaries on penalties; EDICOM and InCorp Vietnam detailed overviews of e-invoicing framework; and other recent tax news sources. These provide the latest information as of 2025 on Vietnam’s e-invoicing and e-reporting mandates and their practical implications. [pwc.com], [pwc.com] [dentonsluatviet.com] [avalara.com], [fonoa.com] [ey.com], [fiscal-req…ements.com] [vatcompliance.co], [tpm.com.vn] [edicomgroup.com], [vietnam.incorp.asia] [ey.com], [pwc.com]

See also

Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
Join the LinkedIn Group on ”VAT in the Digital Age” (VIDA), click HERE