E-Invoices Get a Full Overhaul: Businesses Face a Wave of New Rules Under Decree 254/2026/ND-CP

18-08-26 MTParners

More than a month after taking effect, Decree 254/2026/ND-CP has introduced a wave of new requirements on invoice issuance timing, invoice content, and seller obligations — many businesses have yet to catch up.

As of July 1, 2026, Decree 254/2026/ND-CP officially replaces Decree 123/2020/ND-CP and Decree 70/2025/ND-CP, establishing an entirely new legal framework for e-invoices and e-documents under the 2025 Law on Tax Administration (Law No. 108/2025/QH15). The decree adds new rules on invoice issuance timing for a wide range of service industries, tightens requirements on buyer information, ends the use of tax-authority-printed paper invoices altogether, and for the first time introduces a reward mechanism for consumers who report businesses that fail to issue invoices. Businesses nationwide — especially those in services, e-commerce, and digital platforms — need to urgently review their invoicing procedures.

Invoice Issuance Timing: Several Changes Aligned With Business Realities

Under Clause 2, Article 9 of Decree 254/2026/ND-CP, deposits paid to secure or perform a service contract under the 2015 Civil Code no longer require an invoice to be issued at the time the deposit is received. This is a notable change, since previously the rule applied only to specific fields such as accounting, auditing, financial consulting, tax consulting, and valuation; it is now extended to service provision in general.

The decree also adds a list of high-volume, recurring services that may be invoiced after a reconciliation period, including digital technology and platform services, payment intermediary services, crypto-asset services, insurance, security services, industrial catering, credit information services, and technology-platform passenger transport (taxi, ride-hailing, motorbike-hailing) provided to corporate customers. For these services, businesses may issue invoices no later than 7 days after the end of the reconciliation period. For transactions occurring at night where the seller lacks automated invoicing software, the invoice may be issued no later than the next business day.

Tighter Invoice Content: Buyer Information Can No Longer Be Left Blank

Another notable change in the Appendix to Decree 254/2026/ND-CP: as of July 1, 2026, if a consumer buyer does not provide their name, address, and personal identification number, the seller may not leave the buyer information blank and must instead record “Sold to consumer.” Importantly, an invoice with no buyer information, or one recorded this way, cannot be used by businesses as a basis for expense accounting or tax finalization.

At the same time, the decree allows certain common abbreviations on invoices when the buyer’s name or address is too long (Ward → P., City → TP., Limited Liability → TNHH, Industrial Park → KCN, etc.), provided the information remains accurately identifiable and consistent with business and tax registration records.

End of Printed Paper Invoices, Expanded Inter-Agency Data Sharing

Under Clause 3, Article 44 of Decree 254/2026/ND-CP, as of July 1, 2026, all paper invoices printed by tax authorities are no longer valid for use. Any unused printed invoices must be destroyed according to procedures set by the Ministry of Finance. This marks the final step in the complete transition to e-invoicing.

The decree also expands the responsibility for connecting and sharing e-invoice data between the Tax Department and market management, land administration, geology and minerals, police, transport, and health authorities, aimed at strengthening data cross-checking and combating tax fraud.

Reward for Whistleblowers: A New Oversight Tool

For the first time, invoice regulations introduce a reward mechanism for consumers who report businesses failing to issue e-invoices. Under Clause 1, Article 41, the maximum reward is 10% of the administrative penalty imposed, capped at VND 10 million per case, subject to conditions: the information must be truthful, specify the time, location, and violator, and the tax authority must have issued a penalty decision based on the report. Consumers can submit reports via the eTax Mobile app, the National Public Service Portal, or directly to tax authorities.

Practical Impact

Service, e-commerce, and digital-platform businesses must review contracts and reconciliation processes to comply with the new 7-day invoicing deadline and avoid being deemed late in issuing invoices.
Penalty risk increases as consumers now have a financial incentive to report unissued invoices.
Invoices marked “Sold to consumer” cannot be counted as valid expenses, directly affecting corporate income tax finalization if the purchasing department fails to collect sufficient counterparty information.
Businesses still holding unused printed invoices must promptly destroy them following proper procedures to avoid violating invoice management regulations.

Recommendations for Businesses

Review the entire invoicing process against the 45 articles and Appendix of Decree 254/2026/ND-CP and update e-invoicing software accordingly.
Retrain accounting and sales staff on the new invoice timing rules, particularly for services with reconciliation periods and after-hours transactions.
Build a process to collect complete buyer information at the point of sale to avoid losing expense deduction and tax credit rights due to “Sold to consumer” entries.
Consult lawyers and accountants to properly destroy remaining printed invoices and update reconciliation clauses in existing service contracts.

MT & Partners Law Firm, with a team of experienced lawyers in corporate law, tax, and compliance, is ready to support businesses in reviewing and updating their e-invoicing processes in line with the new regulations. Contact hotline 0987140772 or email info@mtpartners.vn for consultation.

(*) This article is for reference only and does not replace specific legal advice.

Keywords: Decree 254/2026/ND-CP, e-invoice 2026 Vietnam, invoice issuance timing, e-invoices and e-documents, 2025 Law on Tax Administration, business e-invoicing Vietnam, corporate legal consulting.