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Under Vietnamese law, businesses exporting goods are required to issue invoices within a specific timeframe. Under Clause 1, Article 9 of Decree No. 254/2026/ND-CP, effective July 1, 2026, exporters must issue an electronic commercial invoice, electronic VAT invoice, or electronic sales invoice no later than the next working day following customs clearance, regardless of when payment is received.
In practice, some exporters still delay issuing invoices until they receive payment from overseas customers or consolidate transactions at the end of the month. Although these practices may simplify reconciliation, they can result in invoices being issued beyond the legally prescribed deadline.
Late invoicing can lead to revenue being reported in the incorrect tax period and expose businesses to administrative penalties, depending on the nature and number of violations. For exporters managing dozens of shipments or hundreds of orders each month, even occasional delays can create significant compliance risks.
1. Legal basis for invoice issuance timing
In Official Letter 4831/CT-CS introducing the key changes under Decree 254/2026/ND-CP and Circular 91/2026/TT-BTC, the Vietnamese Tax Department identifies invoice issuance timing as an issue that directly affects taxpayers and requires the sector to focus on disseminating the relevant requirements. The specific provisions are set out in Article 9 of Decree 254/2026/ND-CP.
The general rule for sales of goods is that an invoice is issued at the time ownership or the right to use the goods is transferred to the buyer, regardless of whether payment has been received. Exported goods are subject to a separate rule, with a more clearly defined timing requirement.
2. Types of invoices for exported goods in Vietnam
Determining the correct timing is only part of the requirement. Vietnamese businesses must also issue the appropriate type of invoice, as issuing the wrong type of invoice and delivering it to the buyer is also subject to penalties.
Under Clause 3, Article 8 of Decree 254/2026/ND-CP, electronic commercial invoices apply to economic organizations, business households, and individual businesses engaged in exporting goods or providing services overseas, provided that they meet the conditions for electronically transmitting commercial invoice data to the tax authority. If these conditions are not met, the exporter may use an electronic VAT invoice or an electronic sales invoice.
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Criteria
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Electronic commercial invoice
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Electronic VAT invoice or electronic sales invoice
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Applicable conditions
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The Vietnamese exporter meets the conditions for electronically transmitting commercial invoice data to the tax authority
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The Vietnamese exporter does not meet the above data transmission conditions
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Transaction scope
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Export of goods, provision of services overseas
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Export of goods, provision of services overseas
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Buyer’s personal identification number and digital signature
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Not required
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The buyer’s digital signature is not required when selling to overseas customers
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Invoice issuance deadline for exported goods
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No later than the next working day after completion of customs procedures
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No later than the next working day after completion of customs procedures
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Some important points to note when issuing invoices to overseas customers:
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Language: The invoice must be written in Vietnamese; if a foreign language is also included, it must be placed in parentheses to the right of or directly below the Vietnamese text, in a smaller font size.
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Currency: Transactions arising in foreign currencies are recorded in the relevant foreign currency, together with the exchange rate for conversion into Vietnamese dong in accordance with the Law on Tax Administration, except in cases where tax payments in foreign currency are permitted by law.
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Digital signature: When selling goods or providing services to overseas customers, businesses are not required to obtain the buyer’s digital signature on the invoice.
3. Invoice issuance timing for exported goods
3.1. Regulations under Decree 254/2026/ND-CP
Under Clause 1, Article 9 of Decree 254/2026/ND-CP, for exported goods (including export processing), the seller determines the invoice issuance date but must issue the invoice no later than the next working day after the goods are cleared through customs (customs clearance) in accordance with customs regulations.
This deadline applies to all three types of invoices that may be used for exports: electronic commercial invoices, electronic value-added tax invoices (VAT invoices), and electronic sales invoices.
3.2. How to determine the deadline in practice
In practice, the seller may choose the invoice issuance date based on its internal process, provided that it is no later than the next working day after the goods complete customs procedures. For example, if customs procedures are completed on Thursday, the invoice must be issued by Friday, provided that Friday is not a public holiday.
The deadline is calculated from the customs clearance date recorded on the customs declaration, not from any of the following dates:
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The date the overseas customer makes payment or the date an international e-commerce platform transfers the funds to the account.
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The date the foreign trade contract is signed or the date the purchase order (Purchase Order - PO) is received.
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The date the goods arrive at the destination port or the date the customer receives the goods.
For Vietnamese export sellers operating through international e-commerce platforms, sales proceeds often reach the account several weeks after the goods are shipped. If the seller waits for payment before issuing the invoice, revenue will be recognized later than the period in which the transaction actually arises.
4. Invoice issuance timing when Vietnamese businesses provide services to overseas organizations
Many Vietnamese export businesses also provide services overseas, such as software outsourcing, design, marketing, or operational support. These services do not go through customs procedures, so the timing for determining the invoice issuance deadline is completely different from that for goods. Clause 1, Article 9 of Decree 254/2026/ND-CP provides as follows:
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General rule: the invoice is issued when the provision of services is completed, including services provided to foreign organizations or individuals, regardless of whether payment has been received.
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Payment received before or during service provision: the invoice is issued at the time payment is received.
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Deposit: A deposit made under the Civil Code to secure the performance of a service contract does not require an invoice to be issued.
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Phased handover: Each handover of a service item or stage requires an invoice to be issued for the corresponding volume and value.
Article 7 of Decree 254/2026/ND-CP introduces a notable exception: business households and individual entrepreneurs providing digital content products and services, including entertainment, video games, digital films, digital images, digital music, and digital advertising, to overseas organizations and individuals are exempt from the requirement to use electronic invoices.
For long-term service contracts, a safer approach is to link the invoice issuance obligation to each acceptance record or each advance payment milestone specified in the contract, rather than issuing a single consolidated invoice at the end. Designing contract terms and cross-border revenue flows from the outset is also part of a business’s tax structuring and planning.
5. Risks and penalties of issuing invoices outside the prescribed timeframe
Under Decree 254/2026/ND-CP, sellers declare tax based on the invoice issuance date. Therefore, in Vietnam, late invoice issuance can result in revenue being declared in the wrong period and may give rise to late-payment interest if the tax liability is deferred. Where the digital signing date differs from the invoice issuance date, the invoice must be digitally signed and its data transmitted to the tax authority no later than the next working day.
Regarding penalties, Consolidated Document 27/2026/VBHN-NĐ-BTC on administrative penalties for tax and invoice violations sets out fines for issuing invoices outside the prescribed timeframe when selling goods or providing services, based on the number of non-compliant invoices:
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Number of invoices issued outside the prescribed timeframe
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Fine
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01 invoice
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VND 500,000 to VND 1,500,000
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From 02 to fewer than 10 invoices
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VND 2,000,000 to VND 5,000,000
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From 10 to fewer than 20 invoices
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VND 5,000,000 to VND 15,000,000
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From 20 to fewer than 50 invoices
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VND 15,000,000 to VND 30,000,000
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From 50 to fewer than 100 invoices
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VND 30,000,000 to VND 50,000,000
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100 invoices or more
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VND 50,000,000 to VND 70,000,000
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The above fines apply to organizations; for the same violation, the fine applicable to an individual is half the amount. In cases where no invoice is issued, the penalty is higher, ranging from VND 60,000,000 to VND 80,000,000 for violations involving 50 or more invoices, together with a requirement to issue the invoices in accordance with regulations.
For businesses in Vietnam handling multiple export shipments each month, even a systematic delay in the invoice issuance process can cause the number of non-compliant invoices to rise into the highest penalty brackets.
6. Invoice control process for export businesses in Vietnam
To issue invoices on time without increasing the manual workload, businesses should standardize their process into four steps.
6.1. Use the customs clearance date as the reference date
The customs clearance date shown on the customs declaration should be updated in the accounting system as soon as the result is available, rather than waiting until the full set of export documents is complete. This is the input data that determines the invoice issuance deadline for each shipment.
6.2. Set up invoice deadline alerts
The system should automatically calculate the deadline as the next working day, excluding weekends and public holidays, while also alerting users to shipments approaching the deadline that do not yet have an invoice.
6.3. Separate goods and service workflows
For exported goods, the customs milestone is used, while services provided to overseas customers use the completion date or the date payment is received in advance. Combining the two workflows is a common reason why service invoices are issued late.
6.4. Three-way reconciliation and error handling
Regularly reconcile customs declarations, issued invoices, and actual payments received to identify shipments for which no invoice has been issued. If an invoice only contains an incorrect buyer name, address, or amount in words, the seller notifies the buyer and submits Form No. 04/SS-HĐĐT to the tax authority under Article 10 of Circular 91/2026/TT-BTC, without reissuing the invoice. Errors involving the tax identification number, amount, tax rate, tax amount, or goods must be corrected or the invoice replaced.
Sliner and Genbook Support Sellers in Complying with Vietnamese Export Invoicing Regulations
In Vietnam, for exported goods, businesses must issue invoices within the prescribed timeframe calculated from the date of customs clearance, rather than the date payment is received. Issuing invoices at the wrong time may result in tax declarations being filed for the incorrect reporting period and administrative penalties based on the number of non-compliant invoices.
Sliner supports exporters and cross-border e-commerce sellers in establishing a timely invoicing process by synchronizing order, customs declaration, and payment data; identifying transactions that require invoices; automating invoice issuance; and reconciling invoice data with actual revenue received. In addition, Genbook, a solution for standardizing sales data, includes GenInvoice, a feature that analyzes sales data and automates the creation and batch issuance of invoices, providing exporters with effective support throughout the e-invoicing process.
Learn more about Genbook’s GenInvoice e-invoicing automation feature, or contact the Sliner team for guidance on a solution suited to your business’s export model.
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