2026 E-Invoices: With or Without Code, Timing, Errors

From 01/7/2026, together with the new Law on Tax Administration, the legal framework for e-invoices moves to Decree 254/2026/NĐ-CP and Circular 91/2026/TT-BTC. A business needs to know three things: which type of invoice it uses, when it issues the invoice, and how to handle an invoice that has already been issued with an error.

Quick answer: when selling goods or providing services, a business must issue an e-invoice to the buyer, except in the cases listed in Article 7. By default, a business uses an invoice with a code issued by the tax authority. Businesses in the listed sectors, and businesses that meet the infrastructure and software conditions, may use invoices without a code. An invoice is issued when goods are handed over or a service is completed. An invoice issued in error is corrected by notice, by an adjusted invoice or by a replacement invoice.

Which businesses must use e-invoices and how do they register?

Under Clause 1, Article 4 of Decree 254/2026/NĐ-CP, a seller must issue an e-invoice when selling goods or providing services. This includes promotional goods, advertising, samples, gifts, goods used to pay wages in kind, internal consumption, and goods lent out. Before using e-invoices, a business must register (Clause 3, Article 4), mainly through an e-invoice service provider (Article 6, Circular 91/2026/TT-BTC).

Article 7 lists the cases where an e-invoice is not required. Three groups are common for businesses: capital contributions of assets to an economic organization (Clause 5); assets transferred when a company is divided, separated, merged, consolidated or converts its legal form (Clause 6); and fixed-asset machinery and tools used in processing, lent without payment and without transfer of ownership (Clause 7).

Invoices with and without a code: what is the difference?

	Invoice with a tax authority code	Invoice without a code
Who uses it	Economic organizations, household businesses and individual businesses, except for those that use another type (Point a, Clause 1, Article 6)	Businesses in the listed sectors (electricity, petroleum, postal, telecoms, banking, securities, insurance, e-commerce, supermarkets, transport and others); economic organizations that have transacted or will transact electronically with the tax authority and have the required infrastructure and software; excluding high-risk cases or businesses that register to use invoices with a code (Point b, Clause 1, Article 6)
How it is issued	Issued, digitally signed and sent to the tax authority to receive a code, then sent to the buyer (Article 12, Clause 3, Article 15)	Issued with software, digitally signed, sent to the buyer, and data sent to the tax authority (Article 13, Article 16)

Businesses that sell directly to consumers (shopping centers, supermarkets, retail excluding cars, motorcycles and motor vehicles, food and restaurant services, hotels, passenger transport and some other services) use invoices from cash registers. If they have already registered for an invoice with or without a code, they do not need to register again (Point c, Clause 1, Article 6). A household business with annual revenue above 1 billion VND uses an invoice with a code or a cash register connected to the tax authority (Point d, Clause 1, Article 6). See the article household business tax from 2026.

When is an invoice issued?

Article 9 of Decree 254/2026/NĐ-CP provides:

Sale of goods: the time when ownership or the right to use is transferred to the buyer, regardless of whether payment has been received. For export goods, no later than the next working day after customs clearance.
Provision of services: the time the service is completed, regardless of whether payment has been received. If payment is received before or during provision of the service, the invoice is issued at the time payment is received (excluding deposits under the Civil Code).
Deliveries or handovers in several stages: a separate invoice is issued for each part delivered.
Construction and installation (Point c, Clause 4): the time the works, items or completed volumes are accepted and handed over.

An invoice must include the content required by Clause 1, Article 10. This includes the seller’s digital signature, the time of issuance, the time of digital signing and, for invoices with a code, the tax authority code.

When is data sent to the tax authority?

An invoice with a code is sent to the tax administration information system to receive a code, and then sent to the buyer immediately. Invoices from cash registers send their data at the end of each day (Clause 3, Article 15). For invoices without a code (Clause 3, Article 16):

Full invoice content transmitted: sent to the buyer and the tax authority at the same time, no later than the next working day after the invoice is issued.
Summary Data Table: applies to postal, telecommunications, insurance, banking, air transport, securities and some other cases; sent no later than the deadline for filing the value-added tax return.
How to send: directly, if the connection standards are met, or through an e-invoice service provider.

If a force majeure incident prevents issuance, the seller issues and sends the invoice within 03 working days after the problem is resolved (Clause 5, Article 14).

How are invoices issued in error corrected?

Article 10 of Circular 91/2026/TT-BTC covers two groups of errors:

Errors in name, address, written amount or other content, where the tax code, amount, tax rate, tax and goods are correct: the seller notifies the buyer and the tax authority using Form No. 04/SS-HĐĐT. The invoice is not reissued.
Errors in the tax code, goods name or specification, amount, tax rate, tax or other mandatory content: the seller issues an adjusted invoice or a replacement invoice with a line clearly stating which invoice it adjusts or replaces. Before doing so, if the buyer is an organization, household business or individual business, the two parties sign an agreement stating the error. If the buyer is an individual, the seller notifies the buyer, or publishes the notice on its website.

An invoice from a cash register, or an invoice for the sale of an asset that requires registration of ownership or use, is corrected by a replacement invoice if there is an error (Point c, Clause 1). If the same information is wrong on several invoices for one buyer within a month, one adjusted or replacement invoice may be issued with a summary schedule in Form No. 01/BK-ĐCTT. When the tax authority notifies an incorrect invoice using Form No. 01/TB-RSĐT, the seller reviews and handles it under the two groups above (Clause 3).

Can companies that are suspended or dissolving issue invoices?

Yes, in the cases listed in the decree. Clause 2, Article 6 of Decree 254/2026/NĐ-CP allows the tax authority to issue invoices with a code for each transaction when a business has stopped operating but has not completed the procedure to end its tax code, and it needs an invoice for the disposal of assets or goods; or when a business has suspended operations but needs an invoice to perform a contract signed before the suspension notice. See tax finalization on company dissolution.

How Thái Tín supports e-invoice compliance

Thái Tín helps businesses check which invoice type they use and connects them with accounting and tax partners who handle the filings:

Determine whether the business uses an invoice with a code, without a code, or from a cash register.
Review the timing of issuance, prepare a schedule to handle invoices already issued in error, and prepare the agreement and notices to send to the tax authority.

Invoices are a condition for deductible expenses; see the article deductible expenses for corporate income tax. To start, please send us your business type, a typical sales contract and the invoicing software you currently use, so we can prepare a plan and connect you with the right specialist partners.

Questions and answers

Does Decree 123/2020/NĐ-CP on invoices still apply?

No. From 01/7/2026, Decree 123/2020/NĐ-CP, Article 1 of Decree 41/2022/NĐ-CP and Decree 70/2025/NĐ-CP expire (Clause 2, Article 43 of Decree 254/2026/NĐ-CP). Circular 32/2025/TT-BTC also expires from the date Circular 91/2026/TT-BTC takes effect (Clause 2, Article 25). Tax-authority-printed invoices lose their validity from 01/7/2026 (Clause 3, Article 44). Self-printed paper receipts and pre-ordered printed receipts that have not been used may be used until 31/12/2026 (Clause 2, Article 44).

Which businesses may use e-invoices without a tax authority code?

Under Point b, Clause 1, Article 6 of Decree 254/2026/NĐ-CP, these include businesses in sectors such as electricity, petroleum, postal services, telecommunications, clean water, finance and banking, securities, insurance, healthcare, e-commerce, supermarkets and transport, and economic organizations that have transacted or will transact electronically with the tax authority and have IT infrastructure, accounting software and invoicing software that meet the requirements for issuing, looking up, storing and transmitting data. A business is excluded from this group if it is classed as high-risk for tax purposes under rules set by the Minister of Finance, or if it has registered to use invoices with a code.

When is an invoice issued for a service paid for in advance?

Under Clause 2, Article 9 of Decree 254/2026/NĐ-CP, the invoice for a service is issued when the service is completed, regardless of whether payment has been received. If payment is received in advance or during provision of the service, the invoice is issued at the time payment is received. A deposit under the Civil Code that secures performance of the contract is not counted.

If an invoice has the wrong buyer address, must it be reissued?

No, if the error does not affect the tax code, amount, tax rate, tax or the goods stated on the invoice. Under Point a, Clause 1, Article 10 of Circular 91/2026/TT-BTC, the seller notifies the buyer of the wrong invoice and notifies the tax authority using Form No. 04/SS-HĐĐT, without reissuing the invoice.

When must data from a non-code e-invoice be sent to the tax authority?

For invoices that transmit the full invoice content (Point a.3, Clause 3, Article 16 of Decree 254/2026/NĐ-CP), the seller sends the invoice to the buyer and at the same time to the tax authority no later than the next working day after the invoice is issued. Some sectors, including postal, telecommunications, insurance, finance and banking, air transport and securities, send data in a Summary Data Table no later than the deadline for filing the value-added tax return (Point a.1, Clause 3, Article 16).

Legal basis · verification date

Verified 20 October 2026 · next review 18 January 2027. The content is general guidance and does not replace advice for a specific case.

Decree 254/2026/NĐ-CP (issued 30/6/2026, effective 01/7/2026; Official Gazette No. 402, 16/7/2026), detailing the Law on Tax Administration 108/2025/QH15 on e-invoices and electronic vouchers: Article 2, Article 4 (principles of issuance), Article 6 (users), Article 7 (cases where e-invoices are not required), Article 8 (types of invoice), Article 9 (timing of issuance), Article 10 (content), Articles 12 and 13 (invoices with and without a code), Article 14 (incident handling), Articles 15 and 16 (seller obligations and data transmission), Articles 43 and 44 (effect and transition).
Circular 91/2026/TT-BTC (issued 30/6/2026, effective 01/7/2026; Official Gazette No. 464, 08/8/2026): Article 6 (registration of use), Article 10 (handling of e-invoices already issued), Clause 2, Article 25 (replaces Circular 32/2025/TT-BTC).
Law on Tax Administration 108/2025/QH15 (issued 10/12/2025, effective 01/7/2026) is the legal basis for both documents above.
Checked for amendments or replacements on 20/10/2026: no decree or circular amending Decree 254/2026/NĐ-CP or Circular 91/2026/TT-BTC has been found. Decree 254/2026/NĐ-CP replaces Decree 123/2020/NĐ-CP and Decree 70/2025/NĐ-CP, and this was cross-checked against Clause 2, Article 43 of the original text. Penalties for invoice violations are not covered in this article because the separate penalty decree has not yet been checked.