Vietnam — E-Invoicing & E-Reporting Country Booklet

Podcast: https://open.spotify.com/episode/0FVU0TEizFrp6jR2CYLV2d?si=a343a5ddf48e43ed

Executive Summary

Vietnam operates a mandatory nationwide Continuous Transaction Controls (CTC) e-invoice system, effective since July 1, 2022. This system is a “clearance-type CTC,” which means invoices are either validated by the tax authority (General Department of Taxation, GDT) before use or their data is transmitted to the GDT shortly after issuance. The primary goal is to broaden the tax base, combat invoice fraud, and provide the tax authority with real-time transaction visibility, utilizing big-data analytics for risk detection.

The system distinguishes between two types of national XML invoices:

“Coded” invoices (có mã): Receive a GDT code before they can be used (real-time clearance).
“Uncoded” invoices (không có mã): Issued directly, with data transmitted to the GDT no later than the day of delivery (reporting).

The framework is dynamic, with significant amendments and expansions effective in 2025 and 2026, including the integration of cash-register e-invoices for consumer-facing businesses and an overhaul for business households. While advanced in its domestic CTC maturity, Vietnam utilizes a proprietary national XML format and does not align with international standards like EN 16931 or Peppol.

Introduction & Context

Vietnam’s tax digitalization journey has progressed from early e-invoice pilots (Decree 51/2010/ND-CP; Decree 119/2018/ND-CP) to a comprehensive mandatory e-invoice regime. This framework is anchored in the Law on Tax Administration No. 38/2019/QH14 and Decree 123/2020/ND-CP. The rationale is clear: “The regime is designed to broaden the tax base, combat invoice fraud, and give the tax authority real-time transaction visibility.” The GDT actively “applies big-data analytics to the e-invoice stream for risk and fraud detection.”

The system’s scope is continually broadening, notably through the introduction of cash-register e-invoices (Decree 70/2025), significant reforms for business households, and expanding obligations for non-resident suppliers.

Regulatory Framework

The Vietnamese e-invoice system is governed by a robust and evolving legal framework:

Primary Legislation:Law on Tax Administration No. 38/2019/QH14: Passed June 13, 2019, with e-invoice provisions effective July 1, 2022. Articles 89–94 specifically govern e-invoices and their management.
Law on Value-Added Tax No. 48/2024/QH15: Effective July 1, 2025, this law explicitly includes “not transferring electronic invoice data to tax authorities” as a prohibited act and standardizes VAT for foreign e-commerce/digital suppliers.
Key Implementing Regulations (with recent/future changes):Decree 123/2020/ND-CP: Signed October 19, 2020, mandating nationwide e-invoicing from July 1, 2022.
Circular 32/2025/TT-BTC: Issued May 31, 2025, effective June 1, 2025, this circular supersedes the previous Circular 78/2021/TT-BTC.
Decree 70/2025/ND-CP: Signed March 20, 2025, effective June 1, 2025, it introduces cash-register e-invoices, amends invoice timing, and addresses exports and foreign suppliers.
GDT Decision No. 1450/QĐ-TCT (2021) and No. 1510/QĐ-TCT (2022): These define the mandatory e-invoice XML data-format standard.
Decree 310/2025/ND-CP: Effective January 16, 2026, this decree significantly “restructures invoice/tax penalties.”

Operating Model: How it Works (Clearance-Type CTC)

Vietnam’s e-invoice system is a “Clearance-type CTC” model. The General Department of Taxation (GDT) acts as the central platform and operator.

Dual Model (Coded vs. Uncoded):Coded E-invoices (có mã): For most taxpayers, the seller creates a national XML invoice, applies a digital signature, and transmits it to the GDT. The GDT validates the invoice and returns a unique tax-authority code. This code is a prerequisite for the invoice’s legal validity before it can be delivered to the buyer.
Uncoded E-invoices (không có mã): Available to larger enterprises in specific sectors (e.g., electricity, petroleum, telecommunications) with robust IT infrastructure. These invoices are issued directly to the buyer, but their data must be transmitted to the GDT no later than the day of delivery. No pre-clearance is required for this track.

Invoice Lifecycle:Registration: Taxpayers must register for e-invoice use via Form 01/ĐKTĐ-HĐĐT, obtaining GDT approval.
Creation: Invoices are created in the prescribed national XML format (Decision 1450/1510).
Digital Signature: The seller’s digital signature (chữ ký số) is mandatory for integrity and authenticity, except for POS/cash-register invoices.

Transmission & Clearance/Reporting:Coded: Transmitted to GDT for validation and coding, then delivered to the buyer.
Uncoded: Delivered to the buyer, and data transmitted to GDT by day of delivery.

Delivery to Buyer: Electronically (email/SMS) or via a link/QR code for cash-register invoices.
Retention: Invoices must be retained in their original XML form for 10 years.

Central Platform / Operator: The GDT e-invoice system and portal. Businesses connect directly, via a certified e-invoice service provider (T-VAN), or by portal upload.

Scope and Participants

Transactions in Scope:Domestic B2B and B2G: Mandatory e-invoices for VAT-liable supplies.
B2C: Increasingly in scope, particularly with the introduction of “cash-register e-invoices (hóa đơn điện tử khởi tạo từ máy tính tiền)” under Decree 70/2025 for consumer-facing sectors, delivered via SMS/email or QR code.
Exports: In scope under Decree 70/2025. Exporters may use an electronic commercial invoice (in lieu of a VAT e-invoice), provided data is transmitted to the GDT and meets content/format rules, no later than the working day after customs clearance.
Taxpayers in Scope:Established Domestic Entities: “All enterprises and economic organisations; business households and individuals (hộ kinh doanh) paying tax by declaration.”
Non-established / Foreign Entities: Non-resident suppliers of cross-border digital services register via the GDT foreign-supplier portal. Voluntary registration for Vietnamese VAT e-invoices is possible under Decree 70/2025, with mandatory e-invoicing for non-resident foreign suppliers reported to follow in 2026.
Business Households: Those with annual revenue ≥ VND 1 billion are required to use cash-register e-invoices from June 1, 2025. The presumptive/lump-sum tax (thuế khoán) is abolished from January 1, 2026, moving households to self-declaration.
Exemptions: Individuals and business households with annual revenue below VND 100 million, businesses in remote areas with limited internet, and certain financial services are outside the general e-invoice obligation.

Technical Requirements & Formats

Mandatory Format: Vietnam uses a prescribed national XML format defined by GDT Decision No. 1450/QĐ-TCT (2021) and amended by Decision No. 1510/QĐ-TCT (2022). The XML is the legal record, with PDF serving as a convenience copy only.
International Alignment: Importantly, “Vietnam uses a proprietary national XML — not EN 16931, Peppol or UBL.” This means a divergence from widely adopted international e-invoicing standards.
Digital Signature & Integrity: A seller’s digital signature (chữ ký số) from a GDT-approved provider is mandatory for non-POS invoices to ensure integrity and authenticity. For coded invoices, the GDT’s tax-authority code further authenticates the document.
Mandatory Content: Key elements include invoice name/serial/number; seller and buyer name, address, and tax code (MST); goods/services description, unit price, quantity, VAT rate and amount, total; seller’s digital signature; issuance and signature dates; and the tax-authority code for coded invoices. Text must be in Vietnamese.
E-reporting: E-reporting is embedded within the issuance process (clearance for coded, data transmission for uncoded). There is no separate SAF-T file, and Vietnam does not provide pre-filled VAT returns.

Implementation Timeline & Key Dates

The Vietnamese e-invoicing landscape is characterized by a rapid legislative pace:

July 1, 2022: Mandatory nationwide e-invoicing for effectively all enterprises.
January 1, 2025: Law 56/2024/QH15 amendments effective (foreign e-commerce suppliers from April 1, 2025).
June 1, 2025: Decree 70/2025/ND-CP and Circular 32/2025/TT-BTC become effective, introducing cash-register e-invoices, updated timing rules, and export provisions.
July 1, 2025: VAT Law 48/2024/QH15 becomes effective.
January 1, 2026: Abolition of the lump-sum tax (thuế khoán) for business households, moving them to self-declaration.
January 16, 2026: Decree 310/2025/ND-CP effective, “restructur[ing] invoice/tax penalties.”
2026 (anticipated): Mandatory e-invoicing for non-resident foreign suppliers.

Correction of Errors

Errors are handled through specific mechanisms:

Notification Only (Form 04/SS-HĐĐT): For minor errors like incorrect buyer name/address (where tax code and figures are unchanged).
Adjustment Invoice (hóa đơn điều chỉnh): For errors in quantity, price, tax rate, amount, or total.
Replacement Invoice (hóa đơn thay thế): Supersedes the original incorrect invoice.
Cancellation (hủy): If the invoice was never sent to the buyer or the service was terminated.
Buyer Agreement: For B2B corrections requiring adjustment or replacement, the buyer’s written agreement is mandatory.

Transmission & Workflow

Central Platform: The GDT e-invoice system and portal serves as the central hub for clearance/validation and data receipt.
Transmission Channels: Businesses can connect via direct API integration to the GDT, through a certified e-invoice service provider (T-VAN), or by manual XML upload to the GDT portal.
Accredited Service Providers (T-VANs): These certified providers issue and transmit e-invoices on behalf of businesses, with 102 organizations certified as of April 1, 2024 (though this figure is >12 months old). Leading providers include MISA meInvoice, Viettel, VNPT, and FPT IS.
Deadlines:Issuance: At the time of the transaction (e.g., ownership transfer for goods, service completion). Exports have special timing rules.
Transmission: Coded invoices require GDT clearance before use. Uncoded invoices must have their data transmitted to the GDT no later than the day of delivery to the buyer.

Special Scenarios

Self-Billing: No classic EU-style self-billing. Instead, a seller can authorize a third party (including e-commerce platforms under Decree 70/2025) to issue e-invoices on their behalf.
Cross-Border / Reverse Charge: Non-resident digital-service suppliers use the GDT foreign-supplier portal. The e-invoice treatment for Foreign Contractor Tax (FCT) / reverse-charge on services from foreign contractors is “not found” in the provided sources and requires confirmation.
Exports: Zero-rated and use the electronic commercial invoice route under Decree 70/2025.

Archiving & Retention

Mandatory Retention: Taxpayers must retain e-invoices in their original electronic XML form (with digital signature and GDT code for coded invoices) for 10 years.
Central Storage: The GDT stores transmitted/cleared invoice data, but taxpayers remain responsible for their own records.
Integrity/Authenticity: Guaranteed by the seller’s digital signature and the GDT code/validation.
Audit Accessibility: The GDT has “near-real-time” access to cleared/transmitted data for audit and fraud detection.

Penalties & Enforcement

Vietnam has a graduated penalty system for e-invoice non-compliance, which is undergoing significant restructuring.

Current Framework (Decree 125/2020/ND-CP): Penalties range from VND 10,000,000–20,000,000 for failure to issue invoices, up to VND 20,000,000–50,000,000 for using unlawful invoices. Late/non-transmission of e-invoice data incurs fines from VND 2,000,000 (1-5 days late) up to VND 20,000,000 (11+ days or failure).
Future Framework (Decree 310/2025/ND-CP, from Jan 16, 2026): Penalties are restructured into tiered bands, scaling with the number of invoices. For example, failure to issue invoices can range from VND 1,000,000 (single invoice) up to VND 60,000,000–80,000,000 (50+ invoices). Individuals typically pay 50% of organizational fines.

International Alignment & Business Implications

Clearance CTC, Divergent Standards: Vietnam is a “clearance-type CTC jurisdiction with a mature mandatory e-invoice system.” However, its proprietary national XML and lack of alignment with EU standards (ViDA, EN 16931, Peppol) mean it is “ahead on domestic CTC maturity but divergent on standards.”
Cross-Border Implications: The Vietnamese system does not directly integrate with EU systems. Multinationals must “run parallel compliance: Vietnam’s XML/digital-signature/GDT-clearance stack domestically, and separately EN 16931/Peppol for EU flows.”
Business Considerations: Companies must ensure current MST master data, valid digital certificates, and actively track the rapid legislative amendments expected in 2025–2026.

Impact on SMEs and Startups

The system aims to integrate SMEs and business households while offering some simplifications:

Phased Onboarding: Larger consumer-facing households (≥ VND 1 billion annual revenue) are mandated for cash-register e-invoices from June 1, 2025.
Simplifications: Cash-register e-invoices are exempt from the digital-signature requirement. The VAT/PIT-free threshold for households increases from VND 200 million to VND 500 million/year from 2026.
Support: The GDT has run transition campaigns with hotlines for households, and certified providers offer low-cost tooling.
Administrative Burden: Rising for newly in-scope households moving to self-declaration, but offset by simplifications and free tools.
Compliance Costs: Primarily for digital certificates and provider/portal setup. Estimated ~VND 1 trillion in savings at scale.

Key Takeaways & Actionable Items

Vietnam’s e-invoicing system is a comprehensive and rapidly evolving CTC regime that demands careful attention due to its unique technical standards and frequent legislative updates.

Scope: Mandatory for most transactions and entities, with ongoing expansion to business households and non-resident suppliers.
Format: Proprietary national XML, digitally signed, and GDT-cleared/transmitted. No Peppol/EN 16931.
Model: Clearance-type CTC (coded invoices cleared before use; uncoded data transmitted by day of delivery).
Critical Dates: Be aware of numerous changes effective in 2025 (Decree 70/2025, Circular 32/2025, VAT Law 48/2024) and 2026 (business-household overhaul, Decree 310/2025 penalties, mandatory non-resident e-invoicing).
Compliance Essentials: Maintain valid digital certificates and MSTs, ensure XML conformance, comply with GDT clearance/transmission deadlines, and understand correction procedures.
International Implications: Companies operating internationally must manage parallel compliance obligations, as Vietnam’s system is domestically focused and not aligned with EU standards.

Actionable Next Steps:

Now: Confirm that existing coded-clearance and by-day-of-delivery transmission processes are fully operational and regularly monitored.
Per Transaction: Ensure robust processes for XML issuance, digital signing, GDT clearance/transmission, and timely delivery to buyers.
From June 1, 2025: Verify compliance for cash-register e-invoices in consumer-facing sectors if annual revenue exceeds VND 1 billion.
From January 1/16, 2026: Align internal processes with the new business-household self-declaration requirements and the restructured penalty framework under Decree 310/2025.
Ongoing: Regularly validate MSTs of counterparties, manage digital certificate lifecycles, ensure 10-year retention of original XMLs, and continuously monitor legislative amendments, particularly regarding non-resident supplier obligations.
Review: Confirm details flagged as “not found” in the source (e.g., FCT e-invoice treatment, specific attachment frameworks) against primary legal texts.

CTC / Continuous Transaction Controls Analysis for Senior Leadership

Information cut-off date: 3 July 2026. All statements reflect sources available on or before this date. Every substantive statement carries an inline citation [n] resolving to the numbered source list in Chapter 20. Where information is unavailable, not yet legislated, or not applicable, this is stated explicitly rather than omitting the section. Sources older than 12 months or apparently superseded are flagged inline. Local terms are given in Vietnamese with an English gloss on first mention.

Non-EU note: Vietnam is not an EU Member State, so the EU-specific reference points in this template (ViDA, EN 16931, Directive 2014/55/EU) are not applicable as legal drivers. They are addressed only as international-comparison context in Chapters 2.4 and 16. Vietnam’s framework rests on the Law on Tax Administration No. 38/2019/QH14 and the electronic invoice (hóa đơn điện tử / e-invoice) regime administered by the General Department of Taxation (Tổng cục Thuế / GDT) under the Ministry of Finance, via the GDT e-invoice portal. [1][20][23]

One-line orientation: Vietnam runs a mandatory Continuous Transaction Controls (CTC) e-invoice system, nationwide since 1 July 2022. Structured national XML invoices are digitally signed; “coded” invoices (có mã) receive a tax-authority code from the GDT before they can be used (real-time clearance), while “uncoded” invoices (không có mã) are issued directly and their data transmitted to the GDT by the day of delivery (reporting). This is an issuance + clearance/reporting model — a clearance-type CTC. [25][21][19]

Chapter 0 — Executive Summary (“At-a-Glance”)

Status: Live / mandatory nationwide since 1 July 2022 for effectively all enterprises, organisations, business households and individuals paying tax by the declaration method. Extended by Decree 70/2025/ND-CP (from 1 June 2025) to cash-register e-invoices for larger business households and consumer-facing sectors. [20][9][8]
Model: Clearance-type CTC (dual) — coded e-invoices are validated and code-stamped by the GDT before use (real-time clearance); uncoded e-invoices are issued directly and their data transmitted to the GDT no later than the day of delivery (reporting). No pre-clearance for the uncoded track. [25][19]
Mandatory format(s): Prescribed national XML defined by GDT Decision No. 1450/QĐ-TCT (2021), amended by Decision No. 1510/QĐ-TCT (2022); seller’s digital signature (chữ ký số) required (except POS/cash-register invoices); the XML is the legal record and a PDF is a convenience copy only. Not EN 16931/Peppol/UBL. [17][18][22][25]
Key go-live dates:
- 2010/2018 — earlier e-invoice decrees (Decree 51/2010/ND-CP; Decree 119/2018/ND-CP). [7][6]
- 19 Oct 2020 — Decree 123/2020/ND-CP (invoices & records); Circular 78/2021/TT-BTC (17 Sep 2021); mandatory nationwide 1 July 2022. [4][5][20]
- 1 Jan 2025 — Law 56/2024/QH15 amendments (foreign e-commerce suppliers from 1 Apr 2025); 1 Jul 2025 — new VAT Law 48/2024/QH15. [11][3]
- 1 Jun 2025 — Decree 70/2025/ND-CP + Circular 32/2025/TT-BTC (cash-register e-invoices; exports; replaces Circular 78/2021). [9][10]
- 16 Jan 2026 — Decree 310/2025/ND-CP restructures invoice/tax penalties. [15][16]
Taxpayers in scope: All enterprises and economic organisations; business households and individuals (hộ kinh doanh) paying tax by declaration; consumer-facing business households with annual revenue ≥ VND 1 billion use cash-register e-invoices (from 1 Jun 2025); non-resident cross-border/e-commerce suppliers (voluntary from Jun 2025, moving to mandatory in 2026). Covers domestic B2B, B2G, B2C and exports. [20][9][28]
Central platform / operator: The General Department of Taxation (Tổng cục Thuế / GDT) e-invoice system and portal; a separate foreign-supplier portal (etaxvn.gdt.gov.vn) handles non-resident VAT registration/declaration. Businesses connect directly, via a certified e-invoice service provider (T-VAN), or by portal upload. [23][27][21]
Penalty exposure (headline): Under Decree 125/2020/ND-CP — failure to issue invoices VND 10,000,000–20,000,000 (Art. 24(5)); late/non-transmission of e-invoice data to the GDT VND 2,000,000–20,000,000 (Art. 30); using unlawful invoices VND 20,000,000–50,000,000 (Art. 28). From 16 Jan 2026, Decree 310/2025/ND-CP restructures these into tiered bands scaling with the number of invoices (up to VND 60,000,000–80,000,000). Individuals pay 50% of organisational fines. [13][15][16]
International alignment: A clearance-type CTC jurisdiction; not subject to EU ViDA; national XML is not EN 16931/Peppol; broadly consistent with the OECD/CTC direction and among the more advanced ASEAN e-invoicing regimes. [22][25]
Top 3 open risks / uncertainties:
1. Fast-moving law — the base rules (Decree 123/2020, Circular 78/2021, Decree 125/2020) have all been amended/replaced in 2025–2026 (Decree 70/2025, Circular 32/2025, Decree 310/2025); verify the current consolidated text. [9][10][15]
2. Business-household overhaul — the presumptive/lump-sum tax (thuế khoán) is abolished from 1 Jan 2026, moving households to self-declaration, alongside the ≥ VND 1 billion cash-register-invoice duty. [33][34]
3. Primary-text access — GDT/MOF and thuvienphapluat pages block automated retrieval; several article-level details (e.g., Law 38/2019 Arts. 89–94; Decision 1450 field list) rest on advisor summaries and should be confirmed against the primary texts. [2][17]
Information cut-off date: 3 July 2026.

Chapter 1 — Introduction & Country Context

1.1 Tax digitalisation journey

Vietnam moved from paper and early e-invoice pilots (Decree 51/2010/ND-CP; Decree 119/2018/ND-CP) to a comprehensive framework under the Law on Tax Administration No. 38/2019/QH14 and Decree 123/2020/ND-CP, culminating in a mandatory nationwide e-invoice regime from 1 July 2022. The system was subsequently extended and modernised by Decree 70/2025/ND-CP and Circular 32/2025/TT-BTC (from 1 June 2025). [7][6][4][20][9]

1.2 Rationale

The regime is designed to broaden the tax base, combat invoice fraud, and give the tax authority real-time transaction visibility; the GDT applies big-data analytics to the e-invoice stream for risk and fraud detection. [35][25]

1.3 Positioning

CTC: Clearance-type mover — Vietnam’s coded e-invoice is a real-time clearance CTC, placing it among the more advanced ASEAN e-invoicing systems. [25][22]
Scope trajectory: Broadening via cash-register e-invoices (Decree 70/2025), the business-household reform, and non-resident supplier obligations. [9][33][28]
International alignment: Not bound by EU ViDA; uses a proprietary national XML rather than Peppol/EN 16931. [22][25]

1.4 Supranational / international legal basis (non-EU adaptation)

Domestic: Law on Tax Administration No. 38/2019/QH14 (Arts. 89–94 on e-invoices and e-documents); Decree 123/2020/ND-CP; Circular 32/2025/TT-BTC (replacing Circular 78/2021); the VAT Law No. 48/2024/QH15 (from 1 Jul 2025). [2][4][10][3]
International: No supranational instrument applies. EU ViDA, EN 16931 and Directive 2014/55/EU do not apply to Vietnam and are used only for comparison; Vietnam does not use Peppol for the statutory e-invoice. [22][25]

Chapter 2 — Regulatory Framework

2.1 Primary legislation

Law on Tax Administration No. 38/2019/QH14 — passed 13 Jun 2019, effective 1 Jul 2020, with the e-invoice provisions deferred to 1 Jul 2022; Articles 89–94 govern e-invoices, their issuance/management/use, e-invoice services, the e-invoice database and e-documents (Art. 91 distinguishes coded vs uncoded users). Standard VAT rate 10%. [1][2][3]
Law on Value-Added Tax No. 48/2024/QH15 — effective 1 Jul 2025; adds an explicit prohibited act of “not transferring electronic invoice data to tax authorities” and standardises VAT for foreign e-commerce/digital suppliers. [3]

2.2 Implementing regulations, decrees, orders

Decree 123/2020/ND-CP — signed 19 Oct 2020, mandatory from 1 Jul 2022 (invoices and records). [4]
Circular 78/2021/TT-BTC — issued 17 Sep 2021, effective 1 Jul 2022; superseded by Circular 32/2025/TT-BTC (issued 31 May 2025, effective 1 Jun 2025). [5][10]
Decree 70/2025/ND-CP — signed 20 Mar 2025, effective 1 Jun 2025; amends Decree 123/2020 (cash-register e-invoices, invoice timing, exports, foreign suppliers, correction procedures). [8][9]
GDT Decision No. 1450/QĐ-TCT (2021), amended by Decision No. 1510/QĐ-TCT (2022) — the e-invoice XML data-format standard. [17][18]

2.3 Circulars, administrative rulings, FAQs, enforcement/postponement statements

GDT guidance and the e-invoice portal; certified service-provider (T-VAN) standards under Circular 32/2025/TT-BTC. [10][21]
Law 56/2024/QH15 amended several tax laws (incl. Law 38/2019), effective 1 Jan 2025, with foreign e-commerce-supplier provisions from 1 Apr 2025. [11]
Enforcement: the GDT ran targeted inspections of online/e-commerce businesses and uses big-data analytics against invoice fraud. [21][35]

2.4 International / OECD alignment (non-EU adaptation)

Vietnam’s clearance CTC is consistent with the OECD/global CTC direction; it is not ViDA-bound, and EU instruments are referenced only for comparison. A formal OECD/ASEAN benchmarking source was not located and is not asserted. [25][22]

Chapter 3 — Scope of the Mandate

3.1 Transactions in scope

Domestic B2B and B2G: In scope — mandatory e-invoices for VAT-liable supplies by in-scope taxpayers. [20]
B2C: In scope; consumer-facing sectors increasingly via cash-register e-invoices (hóa đơn điện tử khởi tạo từ máy tính tiền) under Decree 70/2025, delivered by SMS/email or via a link/QR code for buyer lookup. [9][20]
Exports: In scope — under Decree 70/2025 (from 1 Jun 2025) exporters may use an electronic commercial invoice (in lieu of a VAT e-invoice) provided the data is transmitted to the tax authority and meets Decree 123/2020 content/format rules; issuance no later than the working day after customs clearance. [32]

3.2 Special transactions

Authorised / delegated invoicing: A seller may authorise a third party to issue e-invoices on its behalf; Decree 70/2025 extends this to allow e-commerce platforms to issue e-invoices on behalf of platform sellers (parts of this framework were still being finalised). [21][9]
Corrections: Cancellation (hủy), adjustment (hóa đơn điều chỉnh) and replacement (hóa đơn thay thế) invoices, plus notification Form 04/SS-HĐĐT, are all within the e-invoice rules (see Ch. 9). [30][31]
Cross-border reverse charge / Foreign Contractor Tax (FCT): [FLAG: not found] — no primary/advisor source reviewed sets out e-invoice treatment for FCT / reverse-charge on services from foreign contractors; confirm against Circular 103/2014/TT-BTC before reliance.

3.3 Excluded / exempt transactions

De minimis / exemptions: Individuals and business households with annual revenue below VND 100 million, businesses in remote areas with limited internet, and certain financial services are outside the general e-invoice obligation. [21]
Below-threshold business households may continue outside cash-register e-invoicing until they reach the VND 1 billion threshold. [9]

Chapter 4 — Taxable Persons in Scope

4.1 Established domestic entities

All enterprises and economic organisations established under Vietnamese law, plus business households and individuals paying tax by the declaration method, must issue e-invoices. Article 91 of Law 38/2019/QH14 determines which taxpayers use coded vs uncoded invoices; the full statutory sector list rests on advisor paraphrase and is flagged as not verbatim-verified. [20][2]

4.2 Non-established / foreign entities

Non-resident suppliers of cross-border digital services register and account for VAT via the GDT foreign-supplier portal (etaxvn.gdt.gov.vn) — registration Form 01/NCCNN, quarterly returns Form 02/NCCNN, historically at deemed rates (10% VAT / 5% CIT) under Circular 80/2021/TT-BTC. Under Decree 70/2025, certain overseas e-commerce/digital-platform suppliers may voluntarily register to issue Vietnamese VAT e-invoices (Form 01/ĐKTĐ-HĐĐT); mandatory e-invoicing for non-resident foreign suppliers is reported to follow in 2026. [27][9][28]

4.3 Voluntary participation models

Below-threshold households/individuals and certain foreign suppliers may participate voluntarily; participants register via Form 01/ĐKTĐ-HĐĐT through the GDT portal or a certified provider, with GDT approval before issuance. [21][9]

4.4 Sector-specific rules and exemptions

Uncoded (không có mã) invoices are available to larger enterprises with adequate IT infrastructure in specified sectors (e.g., electricity, petroleum, telecommunications, clean water, finance/credit, insurance, healthcare, e-commerce, supermarkets, transport) that transact electronically with the tax authority; other taxpayers (and higher-risk cases) use coded invoices. [19][29]

Chapter 5 — Implementation Timeline

5.1 Legislative history and milestones

14 May 2010 — Decree 51/2010/ND-CP (invoices for goods/services). [7]
12 Sep 2018 — Decree 119/2018/ND-CP (prescribing e-invoices; original 1 Nov 2020 deadline). [6]
13 Jun 2019 — Law on Tax Administration 38/2019/QH14 passed (e-invoice provisions effective 1 Jul 2022). [1][2]
19 Oct 2020 — Decree 123/2020/ND-CP (mandatory 1 Jul 2022); 19 Oct 2020 — Decree 125/2020/ND-CP (penalties, effective 5 Dec 2020). [4][13]
17 Sep 2021 — Circular 78/2021/TT-BTC (effective 1 Jul 2022); phased rollout from Nov 2021. [5][28]
1 Jul 2022 — mandatory nationwide e-invoicing. [20]
1 Jan 2025 — Law 56/2024/QH15 amendments effective (foreign e-commerce suppliers from 1 Apr 2025). [11]
20 Mar 2025 — Decree 70/2025/ND-CP (effective 1 Jun 2025); 31 May 2025 — Circular 32/2025/TT-BTC (effective 1 Jun 2025, replaces Circular 78/2021). [8][10]
1 Jul 2025 — VAT Law 48/2024/QH15 effective. [3]
1 Jan 2026 — abolition of the lump-sum tax (thuế khoán) for business households; 16 Jan 2026 — Decree 310/2025/ND-CP (penalty restructuring). [33][15]

5.2 Voluntary / pilot phases and incentives

Phase 1 launched Nov 2021 in six cities/provinces; Phase 2 (Apr–Jul 2022) extended to 57 provinces, reaching 764,314 taxpayers (~92% of obligated businesses) before the 1 July 2022 nationwide mandate. [28]

5.3 Mandatory go-live dates (issuance vs transmission)

Issuance: an e-invoice must be issued at the time of the transaction (transfer of ownership for goods; completion for services; special timing rules for exports, crude oil and gas). [9]
Transmission to GDT: coded invoices are sent to the GDT for a code before use; uncoded invoices must have their data transmitted to the GDT no later than the day the invoice is delivered to the buyer (directly or via a T-VAN provider). [19][25]

5.4 Grace periods and transitional provisions

The core mandate had a phased 2021–2022 rollout; the 2025 changes (Decree 70/2025, Circular 32/2025) took effect 1 Jun 2025, and Decree 310/2025 penalties from 16 Jan 2026, without a general grace period beyond the transmission-deadline mechanics. [28][9][15]

5.5 Pre-mandate technical milestones

Prerequisites: a valid digital signature/certificate (chữ ký số) from a GDT-approved provider; registration via Form 01/ĐKTĐ-HĐĐT with GDT approval; MST (tax code) master data for counterparties; XML conformance to Decision 1450/1510; optionally a certified T-VAN service provider. [21][17]

5.6 Known or anticipated postponements

No postponement of the July 2022 mandate is reported; the trajectory is continued extension (cash-register invoices; non-resident suppliers in 2026). [28][9]

Chapter 6 — Operating Model (How It Really Works)

6.1 Model type and role of the tax authority

Clearance-type CTC. For coded invoices the GDT validates and issues a unique code that is a prerequisite for the invoice’s legal validity before use; for uncoded invoices the GDT receives the data (real-time or by day of delivery) for risk analysis. The GDT does not itself perform the invoice exchange between the parties. [25][21]

6.2 Invoice lifecycle

Register for e-invoice use (Form 01/ĐKTĐ-HĐĐT) via the GDT portal or a certified provider; obtain GDT approval. [21]
Create the invoice in prescribed XML (Decision 1450/1510) and apply the seller’s digital signature (chữ ký số) — except POS/cash-register invoices, which are exempt from the signature. [17][25]
Coded path: transmit to the GDT, which validates and returns the tax-authority code; then deliver to the buyer. [25][19]
Uncoded path: deliver to the buyer and transmit the invoice data to the GDT no later than the day of delivery (directly or via a T-VAN provider). [19][25]
Deliver to the buyer electronically (email/SMS) or via a link/QR code for cash-register invoices. [9]
Retain — 10 years in original XML form. [22]

6.3 Authentication and access

A GDT-approved digital signature/certificate is required for issuance (buyer signature optional); taxpayers connect by direct API integration, a certified e-invoice service provider (T-VAN), or manual XML upload to the GDT portal. [25][21]

6.4 Offline / contingency mode

For a signature that cannot be applied on the issuance day, it may be completed by the next business day. Businesses in remote areas with limited internet fall within the exemption set. [25][21]

6.5 Buyer-side workflow

The buyer verifies the seller’s and its own tax code (MST) and receives the XML (with a PDF convenience copy); an incorrect/missing e-invoice can jeopardise the buyer’s input-VAT deduction. Corrections are handled by adjustment/replacement/cancellation, with buyer agreement for B2B (see Ch. 9). [22][30]

6.6 QR / verification code

Cash-register e-invoices carry a tax-authority code or electronic data (e.g., a QR code/link) allowing the buyer to look up and declare the invoice. [9]

Chapter 7 — Acceptable E-Invoice Formats

7.1 Mandatory format(s)

Prescribed national XML per GDT Decision 1450/QĐ-TCT (2021), amended by Decision 1510/QĐ-TCT (2022) — comprising business-data and digital-signature blocks (plus the tax-authority code for coded invoices). The XML is the legal record; a PDF is a convenience copy only. [17][18][25]

7.2 Relationship to international standards

Vietnam uses a proprietary national XML — not EN 16931, Peppol or UBL. [22]

7.3 Voluntary / legacy / transitional / hybrid formats

Paper invoices are effectively obsolete since 1 Jul 2022 (retained only for narrow exempt cases). No hybrid PDF+XML (Factur-X/ZUGFeRD) construct applies. [21][22]

7.4 Attachments

Not centrally specified in the sources reviewed; the signed XML is the record of account. [FLAG: confirm any attachment framework via the Decision 1450/1510 schema.] [17]

Chapter 8 — Technical & Functional Requirements

8.1 E-invoice specifications

Mandatory content (Decree 123/2020 Art. 10, as amended by Decree 70/2025): invoice name/serial/number; seller and buyer name, address and tax code (MST); goods/services description, unit price, quantity, VAT rate and amount, total; the seller’s digital signature; issuance and signature dates; and, for coded invoices, the tax-authority code. Invoice text must be in Vietnamese (foreign-language text permitted in parentheses). [22][20]

8.2 E-reporting specifications

E-reporting is intrinsic to issuance: coded invoices are cleared by the GDT; uncoded-invoice data is transmitted to the GDT by the day of delivery. VAT is separately declared on Form 01/GTGT (monthly or quarterly). There is no separate SAF-T file. [19][25]

8.3 Digital signature & integrity

The seller’s digital signature (chữ ký số) is mandatory to guarantee integrity and authenticity (POS/cash-register invoices exempt); the tax-authority code authenticates coded invoices; a same-day signature may be completed by the next business day. [22][25]

8.4 Processing mode & performance targets

Real-time clearance for coded invoices; real-time/near-real-time reporting (by day of delivery) for uncoded invoices. No published SLA/latency target was identified in the sources reviewed. [25][19]

Chapter 9 — Correction of Errors

9.1 Invoice corrections

Under Decree 123/2020 Art. 19 (as amended by Decree 70/2025), errors are corrected by: (a) notification only via Form 04/SS-HĐĐT where only the buyer’s name/address is wrong (tax code and figures unchanged); (b) an adjustment invoice (hóa đơn điều chỉnh) for errors in quantity/price/tax rate/amount/total; (c) a replacement invoice (hóa đơn thay thế) that supersedes the wrong invoice; or (d) cancellation (hủy) where the invoice was never sent to the buyer or the service was terminated. B2B corrections require the buyer’s written agreement. [30][31]

9.2 Reporting/return corrections

Form 04/SS-HĐĐT must be submitted no later than the last day of the VAT declaration period in which the adjustment invoice is issued; because invoice data is already GDT-reported, mismatches surface quickly. VAT-return corrections follow the standard VAT procedures. [31][30]

Chapter 10 — Transmission & Workflow

10.1 Central platform

The General Department of Taxation (Tổng cục Thuế / GDT) e-invoice system and portal is the central clearance/validation and data-receipt infrastructure; a separate foreign-supplier portal (etaxvn.gdt.gov.vn) handles non-resident VAT registration/declaration. [23][27]

10.2 Transmission channels

Direct API integration to the GDT. [21]
Certified e-invoice service provider (T-VAN), which validates and returns the final e-invoice. [21][24]
Manual XML upload to the GDT portal. [21]

10.3 Accredited service providers / intermediaries

Certified e-invoice service providers (T-VAN) issue/transmit on a business’s behalf; the GDT certified 102 organisations as of 1 Apr 2024 (flag: >12 months). Leading providers include MISA meInvoice, Viettel, VNPT, FPT IS, Thái Sơn, BKAV and M-Invoice. [36][24]

10.4 Interoperability

Domestic exchange runs on the GDT platform / national XML (not Peppol). The GDT clears/receives data but does not itself exchange invoices between parties. [22][25]

10.5 Deadlines and timing

Issuance: at the time of the transaction (ownership transfer for goods; service completion; exports no later than the working day after customs clearance). [9][32]
Transmission: coded — before use (GDT code); uncoded — no later than the day of delivery to the buyer. [25][19]
VAT returns: Form 01/GTGT, monthly or quarterly. [25]

Chapter 11 — Self-Billing

1 Legality: There is no classic EU-style buyer self-billing regime; instead, a seller may authorise a third party (including, under Decree 70/2025, an e-commerce platform) to issue e-invoices on its behalf. [21][9]
2 Platform routing: Authorised/delegated invoices route through the same GDT clearance/reporting channels and the seller’s registration. [21]
3 Authorisation: Based on a delegation/authorisation arrangement under the Decree 123/2020 framework; platform-authorisation rules were being finalised. [9][21]
4 Mandatory content: Same statutory content, including the seller’s tax code (MST). [22]
5 Self-billing flag/notation: Not documented verbatim in the sources reviewed; confirm via the Decision 1450/1510 schema. [17]
6 Foreign-buyer restrictions: Ordinary VAT/e-invoice rules apply; exports use the export/commercial-invoice route. [32]
7 Buyer-side approval: For B2B adjustments/replacements, the buyer’s written agreement is required. [30]

Chapter 12 — Special Scenarios (non-EU adaptation)

1 Multiple documents: Adjustment, replacement and cancellation, plus Form 04/SS-HĐĐT, are all part of the e-invoice rules and reported to the GDT. [30][31]
2 Chain/agency transactions: Ordinary VAT rules; authorised/platform invoicing is permitted (Ch. 11). Message-level chain-transaction treatment is not separately documented. [21]
3 Cross-border / reverse charge: Non-resident digital-service suppliers use the GDT foreign-supplier portal; Foreign Contractor Tax (FCT) reverse-charge e-invoice treatment is [FLAG: not found] and should be confirmed against Circular 103/2014/TT-BTC. [27]
4 Zero-rated / exempt supplies: Exports are zero-rated and use the export commercial/VAT e-invoice route (Decree 70/2025); field-level 0%/exempt handling was not fully verified in the sources reviewed. [32]
5 Local nuances: Cash-register e-invoices for consumer-facing sectors (Decree 70/2025) and the 2026 business-household reform (abolition of lump-sum tax) are the principal local features. [9][33]

Chapter 13 — Archiving & Retention

1 Central archiving by the platform: The GDT stores transmitted/cleared invoice data on its platform; taxpayers must nonetheless retain their own records. [22][25]
2 Mandatory archiving format: The original electronic XML (with digital signature and, for coded invoices, the tax-authority code). [25]
3 Retention period: 10 years, aligned with the Law on Accounting retention rule (advisor-sourced linkage). [22][25]
4 Storage location: Storage may be in-house or outsourced, potentially outside Vietnam, under secure and accessible conditions. [25]
5 Integrity/authenticity/readability: Guaranteed by the seller’s digital signature and the GDT code/validation. [22][25]
6 Audit accessibility: Near-real-time — the GDT already holds cleared/transmitted invoice data and applies big-data analytics for audit and fraud detection. [25][35]

Chapter 14 — Penalties & Enforcement

14.1 Graduated enforcement

Penalties are graduated by violation type under Decree 125/2020/ND-CP (effective 5 Dec 2020, amended by Decree 102/2021/ND-CP); from 16 Jan 2026, Decree 310/2025/ND-CP restructures the invoice penalties into tiered bands scaling with the number of invoices. Organisational fines apply; individuals pay 50%. [13][14][15]

14.2 Penalties by category (Decree 125/2020/ND-CP)

Failure to issue invoices when selling: VND 10,000,000–20,000,000 (Art. 24(5)). [13]
Wrong-time issuance (not affecting tax): VND 3,000,000–5,000,000 (Art. 24(3)); wrong timing/sequence/type or incomplete content VND 4,000,000–8,000,000 (Art. 24(4)). [13]
Using unlawful invoices: VND 20,000,000–50,000,000 (Art. 28). [13]
Loss/fire/damage of invoices: VND 3,000,000–10,000,000 (Art. 26). [13]
Late/non-transmission of e-invoice data to the GDT: VND 2,000,000–5,000,000 (1–5 working days late), VND 5,000,000–8,000,000 (6–10 days), VND 10,000,000–20,000,000 (11+ days or failure) (Art. 30). [13]
Late invoice notices/reports: up to VND 5,000,000–15,000,000 (91+ days) (Art. 29). [13]

14.3 Amounts & escalation

From 16 Jan 2026, Decree 310/2025/ND-CP restructures Article 24 into tiered bands: failure to issue invoices from VND 1,000,000 (single invoice) up to VND 60,000,000–80,000,000 (50+ invoices); wrong-time issuance up to VND 50,000,000–70,000,000 (100+ invoices); giving away/selling invoices VND 20,000,000–50,000,000. [FLAG: Decree 310/2025 figures for incorrect content and for e-invoice non-transmission were not stated in the sources opened — confirm against the decree text. Individuals pay 50% of organisational fines.] [15][16]

14.4 Article references & links

Bases: Decree 125/2020/ND-CP Arts. 24, 26, 28, 29, 30 (as amended by Decree 102/2021/ND-CP); Decree 310/2025/ND-CP (from 16 Jan 2026). See Chapter 20. [13][14][15]

Chapter 15 — Pre-Filled VAT Returns

1 Available today? No. Vietnam does not provide pre-filled VAT returns based on e-invoice data; taxpayers manually prepare and file Form 01/GTGT. [25]
2 Fields pre-filled vs input required: Not applicable on current evidence; the GDT uses the e-invoice data for risk/fraud analytics rather than to auto-populate returns. [25][35]
3 Announced plans/timeline: No official pre-filled-return initiative identified — not currently in place. [25]
4 Dependency on e-invoicing/e-reporting: The GDT already concentrates the transaction data a future pre-filled return would rely on, but the feature does not currently exist. [25][35]
5 International alignment: Not applicable (no ViDA). [25]

Chapter 16 — International Digital Reporting Readiness (non-EU adaptation)

16.1 Country position

Vietnam is a clearance-type CTC jurisdiction with a mature mandatory e-invoice system; it is not subject to EU ViDA and does not use EN 16931/Peppol for the statutory e-invoice. It is ahead on domestic CTC maturity but divergent on standards. [25][22]

16.2 Format/model alignment & gaps

The proprietary GDT XML + digital-signature + clearance model differs structurally from the EU EN 16931/Peppol model; the principal gap is standards interoperability for cross-border exchange. [22][25]

16.3 Cross-border digital reporting

The e-invoice regime is domestic-focused; it does not feed EU systems. EU counterparties’ ViDA cross-border B2B digital reporting (from 1 July 2030) is an EU-side obligation, not a Vietnamese one. Non-resident suppliers into Vietnam use the GDT foreign-supplier portal, with mandatory e-invoicing reported to follow in 2026. [22][27][28]

16.4 Business implications

Multinationals must run parallel compliance: Vietnam’s XML/digital-signature/GDT-clearance stack domestically, and separately EN 16931/Peppol for EU flows. Keep MST master data and digital certificates current; track the fast-moving 2025–2026 amendments. [22][9]

Chapter 17 — Impact on SMEs and Startups

1 Phased onboarding: SMEs and business households enter via the same GDT system; consumer-facing households with revenue ≥ VND 1 billion adopt cash-register e-invoices from 1 Jun 2025. [9]
2 Free government tools / education / helpdesks: The GDT ran a transition campaign (60-day window, 24/7 hotline) for household businesses; certified providers offer low-cost tooling. [34][24]
3 Simplified regimes / thresholds: Cash-register e-invoices are exempt from the digital-signature requirement (a deliberate simplification for small retailers); the VAT/PIT-free threshold for households rises from VND 200 million to VND 500 million/year from 2026. [25][33]
4 Subsidies / tax credits / grants: No specific e-invoicing subsidy identified; the Business Licence Fee was abolished under Resolution 198/2025/QH15. [33]
5 Compliance costs: Digital certificate + provider/portal setup; low for portal/cash-register users, higher for ERP integration; a government estimate cited ~VND 1 trillion in savings at scale. [24]
6 Cash-flow / operational benefits: Reduced paper handling and faster reconciliation; real-time data availability. [22][35]
7 Net administrative burden: Rising for newly-in-scope households (self-declaration from 2026), offset by simplified cash-register invoicing and free tooling. [33][34]
8 Market / competitive impact: Non-compliance risks buyers’ input-VAT rejection and penalties; a competitive certified-provider market (MISA, Viettel, VNPT, FPT, Thái Sơn) serves SMEs. [22][36]
9 Official readiness assessments: The GDT reports near-universal adoption and a large-scale household conversion campaign (see Ch. 18). [35][34]

Chapter 18 — Practical Implementation Considerations

1 ERP/finance-system impacts: SAP (ECC/S4HANA/BTP), Oracle and Dynamics connect to the GDT via middleware/T-VAN providers to generate XML, apply digital signatures and clear/transmit within deadlines. [24]
2 Master-data prerequisites: Valid tax code (MST) for seller and buyer; a GDT-approved digital signature/certificate; registration (Form 01/ĐKTĐ-HĐĐT); XML conformance to Decision 1450/1510. [22][21][17]
3 Common pitfalls: Correct document-type classification; completing registration + digital-signature + type steps in order; e-commerce-platform VAT-withholding obligations; missing the coded-clearance or by-day-of-delivery transmission. [21][25]
4 Vendor/service-provider landscape: 102 GDT-certified providers (as of 1 Apr 2024); leaders include MISA meInvoice, Viettel, VNPT, FPT IS, Thái Sơn, BKAV and M-Invoice; Sovos, EDICOM, Pagero and Fonoa publish Vietnam-specific capabilities. [36][22][23]
5 Governance & internal control: Digital-certificate lifecycle; clearance/transmission-success KPIs; reconciliation of GDT-cleared data to the VAT return; MST validation at counterparty onboarding; correction controls (Form 04/SS-HĐĐT). [25][30]

Chapter 19 — Summary & Key Takeaways

1 Scope: Mandatory e-invoices for domestic B2B/B2G/B2C and exports; business households phased in (cash-register invoices ≥ VND 1 billion); non-resident suppliers moving to mandatory in 2026. [20][9][28]
2 Format: Prescribed national XML (Decision 1450/1510), digitally signed, cleared/transmitted to the GDT; not EN 16931/Peppol/UBL. [17][22]
3 Timeline: Mandatory nationwide since 1 Jul 2022; Decree 70/2025 + Circular 32/2025 from 1 Jun 2025; VAT Law 48/2024 from 1 Jul 2025; Decree 310/2025 penalties from 16 Jan 2026. [20][9][3][15]
4 How it works: Clearance-type CTC — coded invoices GDT-coded before use; uncoded invoices transmitted by day of delivery; digital signature required (POS exempt). [25][19]
5 Key obligations: Digital certificate; XML issuance; GDT clearance/transmission; correct via adjustment/replacement/cancellation (Form 04/SS-HĐĐT); retain 10 years; use the correct MST. [22][30][25]
6 Main risks: Fast-moving 2025–2026 amendments; business-household overhaul; primary-text access limits; input-VAT loss for buyers. [9][33][2]
7 SME implications: Cash-register e-invoices (signature-exempt); lump-sum tax abolished from 2026; free/low-cost tooling; higher VAT/PIT-free threshold. [9][33][34]
8 International readiness: Clearance CTC; not ViDA/EN 16931/Peppol; run parallel EU compliance where relevant. [25][22]
9 Critical dates & next steps (actionable):
1. Now — Confirm scope and that coded-clearance / by-day-of-delivery transmission processes are live and monitored. [25]
2. Per transaction — Issue XML + digital signature, clear/transmit to the GDT, deliver to the buyer. [19]
3. From 1 Jun 2025 — Ensure cash-register e-invoice compliance for consumer-facing sectors ≥ VND 1 billion. [9]
4. From 1 Jan / 16 Jan 2026 — Align business-household self-declaration and the Decree 310/2025 penalty framework. [33][15]
5. Ongoing — Validate MSTs; manage digital certificates; retain 10 years; track amendments and non-resident-supplier obligations. [22][28]