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Circular 91/2026/TT-BTC: New E-Invoice Rules Explained
Since July 1, 2026, Circular 91/2026/TT-BTC has become the most detailed guidance in Vietnam on e-invoice registration, data format, and error handling. This is not just an internal accounting matter: for household businesses and individual businesses selling on Amazon, Shopify, or TikTok Shop, missing the new requirements can mean a rejected invoice code request or, worse, a suspended e-invoice account in the middle of peak selling season.
Circular 91/2026/TT-BTC was issued by the Ministry of Finance on June 30, 2026, detailing several articles of Tax Administration Law No. 108/2025/QH15 and Decree 254/2026/ND-CP on e-invoices and e-documents. This article maps out the core requirements that household businesses, individual businesses, and cross-border e-commerce sellers need to track to avoid disruption to their selling operations.
1. What Circular 91/2026/TT-BTC covers and who must comply
The scope of this circular spans nearly the entire lifecycle of an e-invoice: registration, format, delegated invoicing, correction of erroneous invoices, template symbols, suspension conditions, and incentive measures to encourage buyers to request invoices.
The regulated entities are defined in Article 2 of Decree 254/2026/ND-CP, covering economic organizations, other organizations, and household businesses and individual businesses, the group that makes up most of Vietnam's cross-border seller community. In other words, an individual seller running an Amazon store under a household business registration falls under this circular just like any company. There is no size-based or online-only exemption.
For economic organizations transmitting e-invoice data directly to the tax authority, Circular 91/2026/TT-BTC also sets specific technical requirements: connection via a leased line or MPLS VPN Layer 3 with at least 5 Mbps bandwidth, encrypted Web Service or Message Queue transmission, and the SOAP protocol for data exchange. That's a meaningful technical hurdle for any business trying to build its own connection instead of going through a licensed e-invoice service provider.
2. Format and invoice symbols under Circular 91/2026/TT-BTC
2.1 XML format and mandatory components
E-invoices under this circular must use XML formatting to ensure consistent data sharing across different technology systems. Each invoice has two core components: business data (seller, buyer, goods, and tax rate information) and digital signature data; invoices with a tax authority code carry an additional authentication component.
Invoice content must display fully and accurately, without ambiguity, so buyers can read it electronically — a requirement that sounds simple but is a common trigger for tax authority correction requests when invoicing software fails to render a required field.
2.2 Template symbols and invoice symbols
Circular 91/2026/TT-BTC sets the invoice template symbol as a single digit (1-9) reflecting invoice type — for example, 1 for a VAT invoice, 2 for a sales invoice. The invoice symbol itself is a six-character code combining letters and numbers that indicates whether the invoice carries a tax authority code, the year of issuance, and the invoice type in use.
For household businesses and individual businesses that delegate invoicing to a third party, a common setup for sellers using e-commerce platforms or outsourced accounting: the name, address, and tax code of the delegated party must also appear in full on the invoice under the circular's requirements.
3. E-invoice registration process for household and individual businesses
Economic organizations, household businesses, and individual businesses register for e-invoices through a licensed e-invoice service provider or the Tax Management Information System. The registration process moves fast but is tightly controlled:
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Within 1 working day, the system automatically cross-checks the legal representative's information, including biometric data, against the National Population Database.
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If the data matches, the system sends a confirmation request by registered email or phone number; the taxpayer must respond the same working day or by the next working day at the latest.
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If the data doesn't match, or the deadline passes without confirmation, the system automatically issues a notice rejecting the e-invoice registration.
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If the taxpayer is flagged as high-risk (for example, an owner linked to invoice fraud, a registered address that isn't specific, or a tax code marked inactive), the tax authority requires an explanation and supporting documents within 3 working days before accepting the registration.
This is exactly why cross-border sellers should clean up their business registration details, phone numbers, and address before applying for e-invoice access, mismatched data is a common rejection reason for household businesses that recently changed structure or legal representation.
4. Correcting erroneous e-invoices and suspension triggers
This circular splits invoice corrections into two tracks. If an error doesn't affect the tax code, amount, tax rate, or goods listed on the invoice, the seller only needs to notify the buyer and the tax authority no reissue required. If the error touches the tax code, amount, tax rate, or other mandatory content, the seller must adjust or replace the invoice, with a note referencing the original invoice number being corrected or replaced.
Sellers should also watch closely for the conditions that trigger suspension of e-invoice use under Circular 91/2026/TT-BTC: tax code termination, a tax authority finding that the business isn't operating at its registered address, a business suspension, enforced tax debt collection, or high-risk classification. For e-commerce household businesses running multiple sales locations or frequently updating registration details, the risk of the system flagging a data mismatch and suspending invoice codes is real without regular data reviews.
5. What this means for cross-border sellers on Amazon, Shopify, and TikTok Shop
In a multi-marketplace setup, each platform such as Amazon, Shopify, TikTok Shop, produces its own revenue, fee, and refund data streams, while Circular 91/2026/TT-BTC requires e-invoice data to be transmitted to the tax authority using specific templates (the e-invoice data summary form, the revenue summary form). If invoice figures don't match the actual revenue recorded on each platform, sellers can easily get pulled into repeated explanation or correction cycles.
This is the most common bottleneck Sliner sees among cross-border sellers: sales data scattered across multiple platforms and currencies, while the e-invoice obligation under the new rules demands near-perfect accuracy at the moment each transaction occurs. Manually reconciling platform reports against the e-invoice system isn't just time-consuming. It also raises the odds of a tax authority explanation request.
6. Sliner helps household businesses stay compliant with Circular 91/2026/TT-BTC
Complying with Circular 91/2026/TT-BTC isn't a one-time task. It's an ongoing operational process, from registration to invoicing to reconciling data across every marketplace. For cross-border household and individual businesses, a small data error can carry consequences far larger than the cost of setting up the right system from the start.
Sliner helps household businesses, individual businesses, and cross-border e-commerce companies automate multi-marketplace revenue reconciliation (Amazon, Shopify, TikTok Shop) against e-invoice data, through the Genbook platform, reducing the risk of data mismatches when filing taxes and issuing invoices under current regulations. For businesses that need to restructure their operating model or plan longer-term tax strategy, Sliner's advisory team is also available to help balance compliance with operating efficiency.
Learn more about Sliner's Accounting Automation service, or explore Corporate Structuring & Tax Planning if your business needs a broader tax strategy.
