Vietnam’s new regulatory framework governing electronic invoices (e-invoices) and electronic documents came into effect on 1 July 2026 under Decree No. 254/2026/NĐ-CP and Circular No. 91/2026/TT-BTC.
While these regulations introduce several technical changes, their impact extends well beyond the accounting function. Businesses should take this opportunity to reassess their contractual arrangements, invoicing procedures, internal controls and supporting technology to ensure continued compliance and minimise tax risks.
Below are five key areas that businesses should review under the new framework.
1. Review How Deposits and Advance Payments Are Treated
One of the most practical changes is the clearer distinction between service deposits/security deposits and advance payments.
Amounts received solely as deposits or security deposits to secure the performance of a service contract do not trigger an obligation to issue an e-invoice upon receipt. By contrast, advance payments received for goods or services remain subject to the normal invoicing rules and generally require an e-invoice to be issued when payment is received.
Businesses should not rely solely on the terminology used in their contracts. In practice, the tax authorities are likely to assess the substance of the transaction rather than its label. A payment described as a “deposit” may still be treated as an advance payment if it effectively represents consideration for future goods or services.
What businesses should do: Review contract templates, payment clauses and approval procedures to ensure that the invoicing treatment reflects the actual commercial substance of each transaction.
2. Reassess Invoice Issuance Timing
The new regulations provide additional flexibility for certain business activities where standard invoicing timing has been difficult to apply in practice.
Examples include:
- Services that require revenue reconciliation before the final amount can be determined;
- Transactions eligible for daily or monthly summary invoices; and
- Businesses operating continuous overnight shifts.
These clarifications better align the legal requirements with operational realities. However, businesses should also ensure that internal procedures are updated consistently across different business units and functions.
What businesses should do: Reassess invoicing procedures for business lines involving complex revenue recognition or specialised operational processes, particularly in retail, logistics, transportation, telecommunications and technology sectors.
3. Confirm Transactions That Do Not Require E-Invoices
The new framework also clarifies several situations where issuing an e-invoice is not required, including:
- Capital contributions made in the form of assets;
- Internal asset transfers between dependent accounting units within the same legal entity; and
- Certain transactions supported by other prescribed electronic documents.
Correctly identifying these transactions can help reduce unnecessary administrative work while improving compliance consistency across the organisation.
What businesses should do: Develop internal guidance for non-standard transactions to ensure consistent application across finance, accounting and operational teams.
4. Evaluate Internal Processes and Technology Readiness
The regulatory focus is increasingly shifting beyond individual invoices towards the integrity and management of electronic data.
Businesses should therefore review whether their existing processes adequately support the new requirements, including:
- Internal invoice approval and issuance procedures;
- Electronic invoice transmission and document retention processes;
- Integration between e-invoicing platforms, ERP systems and accounting software; and
- User access controls and governance over invoice-related data.
Strong internal controls and reliable system integration will become increasingly important as tax administration continues to rely more heavily on digital data.
What businesses should do: Finance, accounting and IT teams should work together to assess system readiness and identify any process or technology improvements required before compliance issues arise.
5. Pay Particular Attention to Retail, E-Commerce and Digital Business Models
The updated regulations continue to strengthen compliance requirements for businesses operating in the digital economy.
Areas receiving increased regulatory attention include:
- E-invoices generated from cash registers in retail operations and F&B operations;
- E-commerce transactions; and
- Digital and cross-border business models that generate taxable income in Vietnam.
Businesses operating in these sectors often manage large transaction volumes and increasingly complex data flows. As a result, robust invoicing controls and effective system integration will play an increasingly important role in managing tax compliance risks.
What businesses should do: Businesses involved in retail, e-commerce, F&B, digital platforms or cross-border transactions should periodically review their invoicing controls and assess potential tax risks associated with high-volume and cross-border transactions.
How Russell Bedford KTC Can Help
Implementing the new e-invoicing framework requires more than updating accounting procedures. It also involves reviewing commercial contracts, business processes, internal controls and technology infrastructure.
Russell Bedford KTC can assist businesses by:
- Assessing compliance with the new e-invoicing and electronic document requirements;
- Reviewing contracts, invoicing procedures and operational workflows;
- Advising on complex invoicing scenarios and practical implementation issues;
- Evaluating ERP systems and accounting software from a tax compliance perspective; and
- Delivering tailored training programmes for finance, accounting and business teams.
Final Thoughts
The new regulations reflect a broader shift in Vietnam’s tax administration towards greater transparency, stronger digital governance and more comprehensive data-driven compliance.
For businesses, compliance is no longer limited to issuing invoices correctly. It increasingly depends on the alignment between contractual arrangements, operational processes, internal controls and technology systems.
Taking a proactive approach today will help businesses strengthen governance, reduce compliance risks and better prepare for the evolving regulatory landscape.
If you would like to understand how these changes may affect your organisation or require assistance in reviewing your e-invoicing framework, our Tax Advisory team at Russell Bedford KTC would be pleased to assist.
