.svg)
From July 1, 2026, electronic invoice regulations will be adjusted under Decree 254/2026/ND-CP and Circular 91/2026/TT-BTC, in the context of new regulations issued to guide the 2025 Law on Tax Administration and replace Decree 123/2020 on invoices and documents.
For e-commerce sellers, the issue is not only whether they are required to issue electronic invoices. More importantly, they need to determine the applicable requirements, the timing for issuing electronic invoices, the data required from platforms, and how to handle errors in issued invoices.
This article guides e-commerce sellers on how to determine their electronic invoicing obligations, when to issue electronic invoices for each transaction, what data needs to be reconciled from platforms, and how to handle errors in issued invoices.
1. Regulations on Entities Required to Issue Electronic Invoices in 2026
Under Decree 254/2026/ND-CP, from July 1, 2026, the obligation to issue electronic invoices is determined based on the type of business and the seller's revenue. Specifically:
-
Enterprises: Must issue electronic invoices when selling goods or providing services, regardless of revenue.
-
Household businesses and individual businesses with annual revenue exceeding VND 1 billion: Required to use electronic invoices under Point d, Clause 1, Article 6 of Decree 254/2026/ND-CP. Cases involving the sale of assets subject to ownership or usage rights registration are also covered.
-
Household businesses and individual businesses with annual revenue of VND 1 billion or less: Not required to use electronic invoices, but may register to use them when needed.
Note: The VND 1 billion threshold is determined based on the total revenue of the same business entity, not separately for each store. If a seller operates simultaneously on Shopee, TikTok Shop, Lazada, their own website, or international e-commerce platforms such as Amazon and Etsy, revenue from all channels should be aggregated to determine the obligation to issue electronic invoices. Selling through an international e-commerce platform does not mean that the seller is exempt from electronic invoicing obligations in Vietnam.
2. Electronic Invoicing Milestones Throughout the Order Lifecycle
For e-commerce orders, the timing for issuing electronic invoices is not determined by when the customer places the order or when the platform transfers funds to the seller's account. Under Clause 1, Article 9 of Decree 254/2026/ND-CP, the timing for issuing an invoice for the sale of goods is generally associated with the transfer of ownership or usage rights over the goods.
Therefore, sellers need to clearly distinguish between the different milestones in the order fulfillment process:
| Milestone | Electronic invoicing obligation |
| Customer places an order, platform records the order | No obligation yet. Ownership of the goods has not been transferred. |
| Seller hands goods over to the carrier | Depends on the delivery terms. If ownership transfers upon handover, the invoice must be issued at that time; otherwise, wait until successful delivery. |
| Customer successfully receives the goods | Issue the invoice. This is the point at which ownership is transferred, regardless of whether payment has been received. |
| Order is delivered in multiple shipments or items are handed over in separate batches | An invoice must be issued for the corresponding quantity and value each time. |
| Platform reconciles and transfers funds to the seller's account | Not the invoicing milestone. This is a cash flow event, not the transfer of goods. |
| Export order has cleared customs | Issue the invoice no later than the next working day following customs clearance. |
| Services with advance payment, such as prepaid service packages | Issue the invoice when payment is received, except for security deposits under the Civil Code. |
The digital signing time may differ from the invoice issuance time, but the invoice must be digitally signed and sent to the tax authority for code issuance, or the data must be transmitted for invoices without a tax authority code, no later than the next working day following the invoice issuance time. Tax must be declared based on the invoice issuance time, not the platform payout date. Therefore, sellers need to manage the electronic invoice issuance time, signing and submission time, and platform payout time separately. Incorrectly synchronizing these milestones may result in revenue and tax being recorded in the wrong period.
3. What Data Is Required to Issue Electronic Invoices?
Decree 254/2026/ND-CP grants sellers on e-commerce and digital platforms the right to request platform operators to provide buyer information, transaction information, delivery time, and order completion status as a basis for issuing invoices. This provides a basis for requesting order-level data rather than relying only on consolidated payment reports at the end of a period.
At a minimum, each order should contain the following information before being processed through the electronic invoicing system:
-
Order ID and successful delivery time, used to determine the invoice issuance date.
-
Buyer information: name, address, and tax identification number if the buyer is a business; personal identification number if voluntarily provided by the customer.
-
Detailed product name for each type of goods, stated in Vietnamese.
-
Value of each line item before discounts, together with any applicable trade or promotional discounts, as these amounts must be clearly reflected on the invoice.
-
Final order status: completed, cancelled, or returned, to avoid issuing invoices for orders cancelled before delivery.
For goods used for promotional purposes or given as gifts, donations, or presents under commercial regulations, sellers may issue a consolidated electronic invoice for transactions arising during the month or quarter, corresponding to the VAT filing period, while retaining a detailed transaction list.
However, if the buyer requests an electronic invoice for each transaction, the seller must issue the invoice accordingly.
4. Common Errors When Issuing Electronic Invoices and How to Handle Them
During the electronic invoicing process, e-commerce sellers can easily make errors related to invoice timing, product data, and the handling of incorrect invoices. Below are 4 common cases:
-
Issuing invoices based on the platform payout date
The platform reconciliation and payout date does not always coincide with the time when an electronic invoice must be issued. For example, an order may be successfully delivered at the end of the month while the platform only releases the payment in the following month. If the payment date is used as the basis, revenue and tax may be recorded in the wrong period. To minimize errors, sellers should use successful delivery time as the basis for determining when to issue electronic invoices. Platform reconciliation reports should be used to track cash flow, platform fees, and adjustments.
-
Consolidating multiple deliveries into one invoice
For orders delivered in multiple batches or through multiple handovers, waiting until the end of the period and consolidating them into one invoice may result in the electronic invoice being issued at the wrong time. Sellers need to track each delivery and issue the corresponding electronic invoice for the goods transferred in accordance with regulations.
-
Product names on invoices are not sufficiently detailed
Product names on electronic invoices need to be stated in Vietnamese and be sufficiently detailed to identify the type of goods. Keeping the English product name from the platform listing or using an overly general name may make reconciliation difficult. If a foreign-language name needs to be shown based on the listing, the seller may place the foreign-language name in parentheses next to or below the Vietnamese name in accordance with regulations. Synchronizing the product catalog between the platform and the electronic invoicing system can help minimize manual editing.
-
Issuing a replacement invoice for errors that do not affect tax obligations
Under Clause 1, Article 10 of Circular 91/2026/TT-BTC, if an invoice contains only errors in the buyer's name, buyer's address, the amount in words, or other information that does not affect the tax obligation, while the tax identification number, amount, tax rate, tax amount, and goods information are correct, the seller must notify the buyer, does not need to issue a new invoice, and must submit Form No. 04/SS-HĐĐT to the tax authority. Conversely, if the tax identification number, amount, tax rate, tax amount, or goods information is incorrect, the seller must issue an adjusted or replacement invoice.
5. Issuing Electronic Invoices for Cross-Border Orders
For sellers on Amazon, Etsy, or self-operated websites, export orders need to be handled under separate electronic invoicing regulations. Where an economic organization, household business, or individual business exports goods or provides services overseas and meets the requirements for electronically transmitting commercial invoice data to the tax authority, the seller may use an electronic commercial invoice.
If the conditions for using an electronic commercial invoice are not met, the seller should issue an electronic VAT invoice or electronic sales invoice in accordance with regulations.
When setting up an electronic invoicing process for cross-border orders, three points require particular attention:
-
Determine the correct invoicing time: For exported goods, the electronic invoice issuance time is tied to the customs clearance date. Therefore, customs declaration data should be linked with order data to minimize manual processing and timing discrepancies.
-
Properly reflect transactions in foreign currencies: The invoice may state the unit price, amount, tax amount, and total payment amount in foreign currency, together with the exchange rate for conversion into Vietnamese dong as prescribed. Where goods or services are sold and payment is received in foreign currency and tax is paid in foreign currency, the applicable regulations on cases where conversion is not required shall apply.
-
Buyer information and signature: For invoices issued to overseas customers, a buyer's digital signature is not required in every case. For electronic commercial invoices, the buyer's personal identification number is also not a mandatory information field in every case.
For Amazon and Etsy sellers, issuing electronic invoices therefore depends not only on order data from the platform but also on the corresponding export and customs data.
6. GenInvoice - An Automated E-Invoicing Solution for E-Commerce Sellers
Accurate e-invoicing depends not only on the invoicing solution itself but also on standardized and synchronized order data. When information relating to delivery dates, buyers, transaction values, and customs clearance is processed consistently, sellers can significantly reduce manual work and minimize errors.
For Amazon and Etsy sellers, GenInvoice automates order data processing, accelerates e-invoice issuance, and centralizes invoice data management on a single platform.
Contact Sliner for detailed guidance from our professional team.
