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From 01/7/2026, Decree 254/2026/ND-CP and Circular 91/2026/TT-BTC are the two legal documents set out all e-invoice issuance activities of online sellers. Much of the market discussion has so far focused only on the question of whether invoices must be issued, while the actual risks for businesses lie in operational details: when to issue an invoice, what information to include, and how to handle an invoice that has already been issued incorrectly.
This article takes a closer look at the e-invoice issuance process that sellers need to understand. E-commerce platform invoice issuance obligations are presented in the sequence of an actual order: identifying the applicable parties, determining the issuance time, ensuring the correct invoice content, handling errors, and finally, understanding the data requirements needed to carry out all of these tasks at a scale of thousands of orders per month.
1. Who is required to issue invoices when selling on e-commerce platforms?
Not every store on Shopee, TikTok Shop, Lazada, or Tiki is subject to mandatory invoicing. E-commerce platform invoice issuance obligations only arise for those required to use e-invoices under the regulations or those that have voluntarily registered to use them.
1.1. Enterprises and economic organizations
Enterprises and economic organizations selling through e-commerce platforms must issue invoices for every sales transaction, regardless of revenue or order value. For this group, there are no exemptions based on business scale.
1.2. Household businesses and individual businesses
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 that require registration of ownership or use rights, must use e-invoices with a tax authority code or e-invoices generated from cash registers connected to the tax authority's data system.
The remaining cases are not subject to mandatory use but may still register if they wish to do so. It is important to correctly understand this new point: the decree does not introduce the VND 1 billion threshold for the first time; rather, it completes the invoice issuance mechanism and adds specific provisions for sales through e-commerce platforms and digital platforms.
2. Invoice issuance timing by transaction type
This is the stage most prone to error when complying with e-commerce platform invoice issuance obligations, because the reconciliation and payment cycles of platforms often differ by several days from the timing prescribed by law. The general principle under Clause 1, Article 9 of Decree 254/2026/ND-CP is that the invoice issuance time is when the goods are delivered or the service is completed for the customer, regardless of when the platform makes payment.
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Transaction type
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Invoice issuance time
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Domestic sale of goods
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Time of transfer of ownership or use rights over the goods to the buyer, regardless of whether payment has been received
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Provision of services
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Time when the provision of services is completed, regardless of whether payment has been received
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Services with payment received in advance or during provision
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Time of payment (excluding deposits made to secure performance of the service contract)
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Export of goods (including export processing)
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Determined by the seller, no later than the next working day following customs clearance of the goods
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Multiple deliveries or handover of individual items
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Each delivery or handover requires an invoice for the corresponding quantity and value
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For retail orders sold through e-commerce platforms, the invoice issuance date is determined by the time the order is successfully delivered by the carrier. If an order is delivered in multiple shipments—for example, for sellers offering bundled products or splitting an order into multiple packages—the seller must issue an invoice for each delivery, rather than waiting until the entire order has been completed to issue a single invoice.
In addition, the time of digital signing may differ from the invoice issuance time. However, the seller must complete the digital signing process and submit the invoice data to the tax authority no later than the next working day following the invoice issuance date. Accordingly, the time of tax declaration is determined based on the invoice issuance date, not the time of digital signing.
3. Mandatory information on invoices for sales through e-commerce platforms
Issuing an invoice at the correct time but with incorrect information still means that the e-commerce platform invoice issuance obligation has not been properly fulfilled. The three groups of information below are the areas where errors most frequently arise for stores handling large volumes of retail transactions.
3.1. Seller information and business location
The invoice must show the seller's name, address, and tax identification number exactly as stated in the enterprise registration certificate or household business registration. Where a household business or individual business uses the same tax identification number for multiple stores, the invoice must clearly state the name, code, and address of the business location - this information enables the tax authority to consolidate data and automatically prepare tax returns.
3.2. Buyer information
If the buyer is a consumer and provides their name, address, and personal identification number, the invoice must include all of this information. If the buyer does not provide it, the invoice must clearly state "Sold to consumer". For foreign buyers, the address and identification number may be replaced with the passport number or immigration document details, together with nationality.
One point that is currently being misinterpreted in the market should be clarified: the regulations do not require every invoice issued on an e-commerce platform to contain the personal identification number of a retail customer. For e-commerce commercial invoices specifically, under Point 9 of the Appendix to Decree 254/2026/ND-CP, the buyer's personal identification number and digital signature are not necessarily required. In return, an invoice without buyer information or an invoice issued to a consumer cannot be used by the buyer to record expenses or finalize taxes - an important point to note for any order involving B2B transactions.
3.3. Goods names, currency, and exchange rate
The name of the goods must be stated in Vietnamese and detailed by type; if a foreign-language name is needed, it should be placed in parentheses or directly below the Vietnamese line in a smaller font. The currency stated on the invoice is Vietnamese dong, except for transactions denominated in foreign currencies in accordance with foreign exchange regulations - in such cases, the seller must state the original currency and the applicable exchange rate. This is an area that international sellers should configure in their invoicing system in advance rather than handle manually for each order.
4. E-commerce commercial invoices for export activities
Under Clause 3, Article 8 of Decree 254/2026/ND-CP, e-commerce commercial invoices apply to economic organizations, household businesses, and individual businesses engaged in exporting goods or providing services abroad, provided that the exporter meets the requirements for electronically transmitting commercial invoice data to the tax authority.
If the data transmission requirement cannot be met, the exporter may choose to issue an electronic VAT invoice or an electronic sales invoice. For cross-border e-commerce businesses, e-commerce platform invoice issuance obligations are closely linked to export activities, so selecting the correct invoice type from the outset directly affects tax refund and customs documentation. This decision needs to be addressed at the system design level, rather than handled on an order-by-order basis.
5. Handling incorrectly issued invoices
At the scale of issuing one invoice per transaction, errors are difficult to avoid. Article 10 of Circular 91/2026/TT-BTC distinguishes between two groups of situations, each requiring a completely different approach.
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Errors that do not affect tax obligations (buyer name, buyer address, amount in words, or other information): the seller notifies the buyer, does not need to reissue the invoice, and simultaneously submits the Notice of Incorrectly Issued E-Invoice using Form No. 04/SS-HĐĐT to the tax authority.
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Incorrect tax identification number, amount, tax rate, tax amount, or goods stated on the invoice: the above approach does not apply; instead, the invoice must be adjusted or replaced in accordance with the corresponding provisions of Circular 91/2026/TT-BTC.
Correctly classifying an error from the outset determines the workload that follows and is an area often overlooked when businesses review their e-commerce platform invoice issuance obligations. If an error that does not affect tax obligations is incorrectly identified as requiring an adjustment or replacement invoice, the business may end up issuing a large number of unnecessary invoices. Conversely, if errors that affect tax-related information are overlooked or incorrectly assessed, the business may face the risk of tax reassessment and penalties.
6. The right to request transaction information and the operational data challenge
All of the e-commerce platform invoice issuance obligations described above can only be fulfilled if the seller has access to order data. Clause 2, Article 19 of Decree 254/2026/ND-CP provides that operators of e-commerce platforms and digital platforms are responsible for providing buyer information, transaction-related information, delivery time, and confirmation of order completion status so that sellers can issue e-invoices in accordance with the regulations. This provides the legal basis for sellers on digital platforms to request transaction information.
From an operational perspective, the following three areas determine most compliance risks:
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Real-time order status synchronization: bringing successful delivery status from each platform into a single system so that the invoice issuance time follows the legally prescribed milestone rather than the payment date.
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Standardizing the process for obtaining data from platforms: clearly defining how sellers on digital platforms request buyer information and order status from platforms, together with procedures for handling incomplete information.
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Three-way reconciliation: issued invoices - platform orders - revenue recorded in the accounting books must match for each period so that discrepancies are identified early rather than accumulating until the tax finalization period.
For stores generating several thousand orders per month and following the principle of one invoice per order, this volume exceeds what can be handled manually on spreadsheets. The Genbook platform was built specifically for this challenge: consolidating sales data from multiple platforms, reconciling revenue, and standardizing accounting entries automatically. The official summary of the key changes in the two documents is available on the Government Policy Development Information Portal
7. Sliner - Your Automated E-Invoice Solution
E-commerce platform invoice issuance obligations from 01/7/2026 require sellers to control four milestones: invoice issuance time, invoice content, the applicable invoice type, and the error-handling process. These four milestones cannot be handled separately at the end of the accounting period because the underlying data is generated continuously at the sales stage.
Sliner works with cross-border e-commerce businesses to establish standardized accounting systems: connecting data from platforms and payment gateways, reconciling revenue at the transaction level, and linking the invoice issuance process to the revenue recognition timing in accordance with current regulations.
Learn more about GenInvoice, an automated e-invoicing solution, or contact the Sliner team for consultation and support in building an e-invoicing process tailored to your business.
