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On June 30, 2026, the Vietnam Government issued Decree 254/2026/ND-CP, providing detailed regulations on electronic invoices and electronic documents. On the same day, the Vietnam Ministry of Finance issued Circular 91/2026/TT-BTC, providing guidance on certain provisions of the Law on Tax Administration and Decree 254/2026/ND-CP. Both regulations took effect on July 1, 2026.
For businesses, the changes go beyond updating e-invoice requirements. They also affect how businesses register, issue, process, and transmit e-invoice data in practice. While Decree 254/2026/ND-CP sets out the rules on who must use e-invoices, when invoices should be issued, and what they must contain, Circular 91/2026/TT-BTC provides further guidance on how these requirements should be implemented and managed.
Below are seven areas businesses should review when applying the new requirements.
1. Who Is Required to Use E-Invoices?
Before applying the guidance under Circular 91/2026/TT-BTC, businesses should first determine which category they fall into under Circular 91/2026/TT-BTC and which type of e-invoice applies to them.
According to Point b, Clause 1, Article 6 of Decree 254/2026/ND-CP, as published on the Vietnam Government Portal, certain businesses operating in areas such as banking and finance, securities, crypto assets, e-commerce, insurance, healthcare, and transportation, as well as businesses that meet the required IT infrastructure conditions, may use e-invoices without a tax authority code.
Under Point c, Clause 1, Article 6 of Decree 254/2026/ND-CP, certain organizations, household businesses, and individual businesses that sell goods or provide services directly to consumers are subject to e-invoices generated from cash registers.
Under Point d, Clause 1, Article 6 of Decree 254/2026/ND-CP, household businesses and individual businesses with annual revenue exceeding VND 1 billion, or those selling assets subject to ownership or usage registration, must use either tax authority-coded e-invoices or cash-register-generated e-invoices connected to the tax authority.
For foreign organizations, Clause 1, Article 2 of Decree 254/2026/ND-CP also covers foreign e-commerce and digital platform operators that conduct business through their platforms and generate taxable revenue in Vietnam, where they fall under the provisions allowing voluntary registration for e-invoice use.
The first step, therefore, is to identify the applicable e-invoice model before reviewing the implementation requirements under Circular 91/2026/TT-BTC.
What should businesses do?
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Check the type of e-invoice currently registered.
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Review the information registered with the tax authority.
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Confirm whether the current invoice method matches the business's activities.
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Prepare to update the registration if the applicable e-invoice method changes.
2. When Are Businesses Required to Use E-Invoices?
Under Decree 254/2026/ND-CP, sellers of goods and providers of services that fall within the scope of mandatory e-invoice use must issue invoices in accordance with the regulations, unless a specific exemption applies.
The Vietnam Government Portal notes that Article 7 of Decree 254/2026/ND-CP sets out cases where e-invoices are not required. These include certain activities of household and individual businesses, as well as specific transactions involving reinsurance, financial activities, debt sales, foreign currency transactions, capital contributions using assets, and internal asset transfers.
This distinction is particularly important for businesses handling multiple types of transactions or selling through different channels. Not every payment or revenue stream should automatically be treated in the same way for invoicing purposes.
Circular 91/2026/TT-BTC does not replace these rules. Instead, it provides guidance on the registration, use, and handling of e-invoices within the framework established by Decree 254/2026/ND-CP.
What should businesses review?
Businesses should map out their current transaction types and identify:
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Which transactions require an e-invoice.
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Which transactions are exempt.
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Whether different transaction types are being handled consistently across internal systems.
3. What Has Changed About E-Invoice Registration?
Article 6 of Circular 91/2026/TT-BTC covers the registration and modification of information relating to e-invoice use.
Businesses should update their registration information when there is a change in their e-invoice setup, such as switching between tax authority-coded and non-coded e-invoices. Where a taxpayer is required to switch to coded e-invoices because they have been identified as a high-risk taxpayer, the relevant registration changes must also be handled under Article 6.
The Vietnam Government Portal identifies e-invoice registration and changes to registered e-invoice information as one of the areas specifically guided by Circular 91/2026/TT-BTC.
What should businesses do?
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Check the e-invoice method currently registered.
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Review the registration information on the tax administration system.
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Update the registration when the e-invoice method changes.
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Make sure the business can respond to any requirement from the tax authority to change its e-invoice method.
4. What Happens If E-Invoice Use Is Suspended?
Under Article 8 of Circular 91/2026/TT-BTC, organizations, business households and individuals may be required to discontinue or temporarily suspend the use of e-invoices in certain circumstances.
Key cases include:
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Tax identification number deactivation or failure to operate at the registered business address, as specified in Points a and b, Clause 1, Article 8 of Circular 91/2026/TT-BTC.
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Temporary suspension of business operations under Point c, Clause 1, Article 8 of Circular 91/2026/TT-BTC.
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Being subject to enforcement measures for outstanding tax debts that require the suspension of e-invoice use, under Point d, Clause 1, Article 8 of Circular 91/2026/TT-BTC.
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Certain violations relating to the issuance or use of e-invoices, or cases identified as presenting tax-related risks, as specified under Points đ, e, g and other relevant provisions of Clause 1, Article 8 of Circular 91/2026/TT-BTC.
Where a taxpayer has authorized another party to issue e-invoices on its behalf, the tax authority will also notify the authorized party if the taxpayer is subject to suspension or discontinuation of e-invoice use, in accordance with Point đ, Clause 2, Article 8 of Circular 91/2026/TT-BTC.
What should businesses do?
Businesses should regularly review their tax registration status, registered business address and e-invoice status so they can take timely action if they become subject to e-invoice suspension or discontinuation.
5. How Should Businesses Handle Incorrect E-Invoices?
Article 10 of Circular 91/2026/TT-BTC provides further guidance on how to handle issued e-invoices and electronic documents containing errors.
Based on the guidance published by the Vietnam Government Policy Portal, depending on the nature of the error, businesses may need to:
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Submit a notification of the incorrect invoice.
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Issue an adjustment invoice.
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Issue a replacement invoice.
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Follow specific procedures applicable to the particular type of e-invoice.
The appropriate treatment depends on the type of error and the information affected. Businesses should therefore avoid applying a single correction process to every case.
Using an outdated process can result in inconsistent data or procedures that no longer align with the new requirements.
What should businesses do?
Businesses should establish a clear process for identifying invoice errors, determining the appropriate correction method, and maintaining a record of the relevant notification, adjustment, or replacement.
6. How Should E-Invoice Data Be Transmitted to the Tax Authority?
Another area businesses should review is their ability to transmit e-invoice and transaction data to the tax authority in accordance with the applicable requirements.
The Vietnam Government Policy Portal explains that Decree 254/2026/ND-CP and Circular 91/2026/TT-BTC provide requirements for transmitting and managing e-invoice and electronic document data. For certain types of transactions, businesses may need to provide more than the information shown on the invoice itself. Detailed transaction data may also be required under the relevant regulations.
This is particularly important for businesses processing a high volume of orders or selling across multiple platforms. Data from sales platforms, payment gateways, and accounting systems should be reconciled to identify discrepancies before being used for tax filing and financial reporting.
What should businesses review?
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How invoice data is generated and transmitted.
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Whether sales, payment, and accounting systems are properly connected.
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Whether transaction data can be reconciled before tax reporting.
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Whether the business can maintain consistent records across different systems.
7. What Should Businesses Review Under Circular 91/2026/TT-BTC?
Rather than simply updating their invoicing software, businesses should review the entire e-invoicing workflow.
Key areas include:
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E-invoice registration: Review the registered information and current e-invoice method under Circular 91/2026/TT-BTC.
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Invoice timing: Review the applicable invoice issuance points under Decree 254/2026/ND-CP.
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Invoice content: Check required fields and the sources from which invoice data is generated.
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Error handling: Establish procedures for notifications, adjustments, and replacements under the new requirements.
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Data transmission: Check the connection and synchronization between sales, accounting, and e-invoice systems.
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Reconciliation: Ensure revenue, orders, payments, and invoice data can be cross-checked.
For e-commerce businesses in particular, regulatory updates should go hand in hand with a review of the entire data flow. When sales and payment information sits across multiple systems, a discrepancy at one stage can affect accounting records and tax reporting downstream.
What Should Businesses Do Next?
Circular 91/2026/TT-BTC is not simply a procedural update. It also highlights the need for businesses to manage e-invoice data in a more structured and connected way.
Businesses should prioritize four areas:
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Review their invoice issuance and correction processes.
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Standardize data from different sales channels before invoices are issued.
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Establish a clear reconciliation process across revenue, orders, payments, and invoices.
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Automate repetitive processes to reduce manual data entry and minimize errors.
E-invoicing Automation Solution for E-commerce Sellers
For multi-channel sellers, e-invoicing is not only a compliance requirement. As order volumes grow, it also becomes an operational challenge. When order, revenue, and invoice data sit across different systems, manual consolidation and reconciliation can quickly become time-consuming and prone to discrepancies.
Sliner consults with businesses on accounting and e-invoicing automation, helping them connect data from different sales channels, standardize information, reconcile invoices against actual revenue, and reduce manual processing. As part of this solution, GenInvoice helps automate the e-invoicing process for Amazon and Etsy sellers, from synchronizing order data and generating and issuing invoices in batches to reconciling order numbers with invoice numbers. This enables businesses to efficiently handle high transaction volumes and manage invoice data in a more centralized way.
Explore GenInvoice or contact the Sliner team to discuss an e-invoicing and accounting workflow that fits your business.
