Decree 254/2026/ND-CP not only clarifies the time of invoice issuance but also supplements regulations on buyer information, expands the cases in which invoices can be issued after reconciliation, clearly defines the legal validity of electronic invoices generated from cash registers, and provides guidance on handling printed receipts and invoices during the transitional period.
1. Clarifying the timing of electronic invoice issuance (Article 9)
One of the most notable aspects of Decree 254/2026/ND-CP is the clarification of the timing for issuing invoices for each type of transaction, thereby limiting the situation of issuing invoices at the wrong time.
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Sale of goods |
Provision of services |
Deposits |
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When transferring ownership or the right to use goods to the buyer, regardless of whether payment has been received or not. * For exampleIf a business delivers goods to a customer on July 28th but the customer pays on August 15th, the invoice must still be issued on July 28th. |
Upon completion of the service, regardless of whether payment has been received or not; if payment is received before or during the provision of the service, an invoice must be issued at the time of payment. * For exampleThe business completed the service on August 15th, and the customer paid on August 20th. The electronic invoice must be issued on August 15th, 2026 (the service completion date), not the payment date. |
This does not apply to deposits intended to guarantee the performance of service contracts under the 2015 Civil Code. *For example: The client paid a deposit of 30 million VND to sign the event organizing contract. The service provider is not required to issue an invoice upon receiving this deposit. |
Businesses should note: Issuing invoices at the wrong time can result in administrative penalties according to regulations on invoices and documents. Therefore, businesses need to clearly distinguish between the time of goods delivery, the time of service completion, the time of payment collection, and the time of security deposit to comply with regulations.
2. Additional cases where reconciliation invoices are required (Article 9)
Decree 254/2026/ND-CP supplements regulations allowing certain sectors to issue invoices upon completion of reconciliation, instead of requiring them to be issued immediately upon transaction occurrence. This regulation applies to activities with specific characteristics that generate numerous transactions and require time to consolidate and verify data before invoicing.
The areas of application include:
- Electricity and water;
- Telecommunications;
- Logistics;
- E-commerce and digital platforms;
- Banking, securities, insurance;
- Passenger transport;
- Information technology services.
Businesses should note: This regulation does not allow for an unlimited extension of the invoice issuance deadline. According to Decree 254/2026/ND-CP, invoices must still be issued no later than the 07th day of the month following the month in which the transaction occurred, or no later than 07 days from the date of completion of reconciliation, depending on the specific case.
3. New regulations on buyer information on invoices (Article 10 and Appendix attached to the Decree):
Decree 254/2026/ND-CP clarifies how to record buyer information on electronic invoices, especially in cases where consumers do not provide complete information. This regulation helps standardize invoice preparation in practice and clarifies the validity of invoices for each group of subjects. Specifically:
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Case |
How to record buyer information |
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The buyer did not provide information. |
In cases where the buyer is a consumer who does not provide their name, address, and personal identification number, the seller must not leave the buyer's information blank but must indicate "Sold to consumer" on the invoice. |
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The buyer provided complete information. |
The invoice must clearly show the full name, address, and personal identification number of the buyer. For foreign buyers, the personal identification number is replaced by their passport number or entry/exit document indicating their nationality. |
Businesses should note: Invoices without buyer information or invoices marked "Sold to Consumers" are invalid for use by organizations, businesses, household businesses, or individual businesses as a basis for accounting expenses or determining tax obligations according to tax laws.
Therefore, when the buyer is an organization, business, or individual business owner who needs to use invoices for tax declaration, accounting, or settlement, the business needs to collect complete information from the buyer before issuing the invoice to ensure that the invoice is valid for use according to regulations.
4. Transitional provisions for paper receipts and printed invoices issued by the tax authorities.
To ensure a consistent transition to electronic invoices and documents, Decree 254/2026/ND-CP clearly stipulates the continued use and handling of remaining paper receipts (self-printed) and invoices printed by tax authorities.
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Content |
Paper receipts (self-printed) |
Printed invoices issued by the tax authority. |
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Can it be used again? |
It will continue to be used until December 31, 2026. |
It is no longer usable; its intended use has expired according to regulations. |
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Handling of remaining stock |
The destruction shall be carried out in accordance with the procedures prescribed by the Minister of Finance. |
The destruction shall be carried out in accordance with the procedures prescribed by the Minister of Finance. |
Businesses should note: Businesses currently using paper (self-printed) receipts should proactively review their remaining stock to plan for their use before the deadline of December 31, 2026.
For invoices printed by the tax authorities, businesses are not allowed to continue using them and must destroy them in accordance with the procedures stipulated by the Ministry of Finance to avoid risks in the management and use of invoices.
5. Electronic invoices from cash registers are not required to have a digital signature (Article 8)
Decree 254/2026/ND-CP further clarifies regulations regarding electronic invoices generated from cash registers with electronic data transfer connections to tax authorities. Accordingly, this type of invoice is not required to have the seller's digital signature, but must still meet the prescribed conditions to be recognized as a legal invoice.
Electronic invoices generated from cash registers must meet the following requirements:
- An electronic invoice can be identified as one generated from a cash register that has an electronic data transfer connection with the tax authority;
- A digital signature from the seller is not required;
- Expenditures for goods and services using invoices retrieved from the Tax Management Information System are considered to have complete and legitimate invoices and documents when determining tax obligations according to regulations.
Businesses should note: The absence of a digital signature on an invoice does not automatically mean it is invalid. Businesses need to determine whether it is an electronic invoice generated from a cash register as required by regulations and check its searchability on the Tax Management Information System. Only when all these conditions are met will the invoice be considered legal and valid for accounting, declaration, and determination of tax obligations.
6. Conclusion
Decree 254/2026/ND-CP not only amends the technical aspects of electronic invoicing but also directly impacts the sales, accounting, and tax management processes of businesses.
Several changes, such as regulations on invoice timing, reconciliation invoices, or buyer information, require businesses to review their internal processes to avoid situations where invoices are issued at the wrong time or with missing information, affecting their legal validity. Proactively updating regulations and adjusting processes from the outset will help businesses minimize tax risks and ensure compliance throughout their operations.