When errors arise in issued electronic invoices, the primary principle of handling them lies in the mechanism for replacement or adjustment (depending on the type of error), along with the obligation to notify the tax authorities in legally mandated cases.
1. The legal framework to understand when handling erroneous electronic invoices.
📑 Legal basis:
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Decree 123/2020/ND-CP Regulations on invoices and supporting documents (currently in effect and as amended/supplemented).
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Decree 70/2025/ND-CP Amending and supplementing certain articles of Decree 123/2020/ND-CP, Effective from June 1, 2025.
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Circular 32 / 2025 / TT-BTC, Effective from June 1, 2025 (This guidance document replaces Circular 78/2021/TT-BTC from the effective date).
The current focus of handling erroneous electronic invoices lies in: Article 19 of Decree 123/2020/ND-CP (amended by Decree 70/2025/ND-CP).
2. Classify the “error type” and “invoice status” before processing.
In compliance management practice, correct handling doesn't begin with software operations, but with classification:
2.1. Common errors categorized by incorrect content
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Incorrect buyer name/address but correct tax identification number (TIN) and other criteria.
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Incorrect buyer's tax identification number (MST).
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Amount error, incorrect tax rate, Incorrect tax amount.
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Incorrect specifications/quality of goods and services (misrepresenting the nature of the service provided).
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Multiple invoice errors In the same month, by the same buyer, with the same type of error (an optimal solution for the file is needed).
2.2. The "invoice status" group is incorrect.
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Electronic contracts no code Tax authorities vs. e-invoices has a code The tax authorities (especially at the re-issuance stage: invoices with codes usually have to be sent to the tax authorities to obtain a new code for the invoice before being sent to the buyer).
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Errors due to businesses self-discover vs The tax authorities discovered and notified..
3. What are the recommended procedures for handling erroneous electronic invoices: should you choose "do not reissue," "adjust," or "replace"?
Case A — Incorrect buyer's name/address but correct tax identification number and other details.
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No need to re-invoice..
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Business & Investment notify the buyer regarding the incorrectly issued invoice and perform notify the tax authorities. according to Form 04/SS-HĐĐT.
This is a category of data errors. Internal control plans should focus on reducing occurrences rather than "fixing" them.
Case B — Incorrect Tax Identification Number (TIN), incorrect amount, incorrect tax rate/tax amount, incorrect specifications/quality of goods/services…
Business & Investment selected One of two options:
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Issue an adjustment invoice. For invoices that were incorrectly issued (the adjusted invoice must include the phrase "Adjustment for invoice… symbol… number… dated… month… year").
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Issue a new replacement invoice. The invoice was issued incorrectly (the replacement invoice must include the phrase "Replacement for invoice… symbol… number… dated… month… year").
After signing digitally:
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If used Electronic invoices without codes Tax authorities: send an adjusted/replacement invoice to the buyer.
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If used Electronic invoices with codes tax authority: send to the tax authority to assign code Prepare a new invoice first, then send it to the buyer.
Case C — Multiple invoices are incorrect within the same month (profile optimization)
If the business makes a mistake in the records during the month. along with buyer information/item name/unit price/tax rate on multiple invoices From the same buyer, a business can Create an adjustment or replacement invoice for multiple invoices., with Statement Form 01/BK-ĐCTT.
Case D — Requires documentation of agreement with the buyer before making adjustments/replacements.
Before making adjustments/replacements (for the group of buyers being businesses/organizations/household businesses/individual businesses), Both parties need to draw up a written agreement clearly stating the incorrect information.The seller stores and presents this upon request. If the buyer is individualThe seller will notify you directly or via website (if available).
Case E — The tax authority discovers the error and sends a notification.
When the tax authorities discover that an electronic invoice (with or without a code) has been incorrectly issued, the tax authorities will take action. Notification using Form 01/TB-RSĐT This allows the seller to check for incorrect content and make corrections/replacements as required.
4. Standard procedure for handling electronic invoices that have been created but contain errors.
Below are the standard, appropriate steps for SMEs/FDI businesses to handle tax risks, documentation risks, and audit footprints:
Step 1: Identify the error and determine the appropriate course of action.
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Identify belonging Case A (Only the name/address is wrong, the tax identification number is correct) or Case B (Incorrect Tax Identification Number/Amount/Tax Rate/Tax Amount/Specifications…).
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Identify the invoice as has a code or no code (Decision on shipping route).
Step 2: Complete the legal paperwork with the buyer (if required).
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Establish agreement with buyers (B2B/B2C as defined).
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For B2B/B2C business customers: establish agreement Clearly state the incorrect information (for use in the control record).
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For individual customers: notification will be given directly or publicly on the website (if applicable).
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Step 3: Prepare an adjustment invoice or replacement invoice with correct wording.
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If it falls under Case A: to send Form 04/SS-HĐĐT to the tax authorities and notify the buyer.
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If it falls under Case B: choose điều chỉnh or thay thếEnsure that the required text "Adjust for..." or "Replace for..." is formatted correctly.
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If there are widespread errors: consider the mechanism 01 invoice + statement 01/BK-ĐCTT to optimize compliance costs.
Step 4: Submit notification/receipt on the tax system (when subject to notification).
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If notification is required, the business shall comply with the following procedures. Form 04/SS-HĐĐTThe tax authority's automated system will respond and acknowledge receipt accordingly. Form 01/TB-SSĐT.
Step 5: Send the invoice via the correct route (with/without a code).
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No code: send to buyer.
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With a code: send it to the tax authority to get a code for the new invoice before sending it to the buyer.
Step 6: Filing and accounting: Processing the tax return correctly and logically.
The regulations differentiate between situations requiring adjustment/replacement of declarations:
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For adjustment/replacement invoices due to errors under the adjustment/replacement mechanism, the seller and buyer shall proceed accordingly. supplementary declaration during the period when the invoice is adjusted/replaced.
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In some cases, adjustments are made based on business transactions (specified separately in the terms and conditions), the declaration method may be based on the period of issuance of the adjustment invoice or the period of receipt of the adjustment invoice, depending on the situation.
5. Common Compliance Issues
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Choosing the wrong mechanismInstead of simply notifying (Case A), an adjustment/replacement was created → increasing the number of files to be processed and the risk of chain reaction errors.
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Lack of written agreement With buyers (especially B2B) before adjustment/replacement → lack of documentation when explaining, leading to the invoice potentially being considered invalid.
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The required wording was not entered correctly. “Adjustment for…” / “Replacement for…” → Risk of being assessed as a document that does not meet information standards.
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Do not follow the correct route “with/without code” → Incorrect publishing and tracking procedures.
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Failing to react in time when notified by the tax authorities. Errors in the template → create potential risks in tax administration.
6. Ways to minimize errors in e-invoices from the outset.
These are systemic measures that help reduce electronic invoice errors right from the source, rather than just optimizing the processing stage:
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Standardize customer information sources. (Name, address, tax code): Establish a process for regular updates, approvals, and reconciliation; prioritize integration from CRM/ERP to reduce manual data entry.
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Design a pre-release checklist. according to 3 classes:
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Verify buyer data;
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Check the cash and tax figures;
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Check the "coded/uncoded" condition and the routing path.
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Establish exception handling mechanisms: All invoices requiring correction or adjustment must be accompanied by an internal request (ticket), clearly approved by a designated person, and fully documented with supporting evidence.
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Discipline during the declaration periodEstablish internal regulations regarding the responsibility for supplementary/amended declarations; avoid having adjusted invoices "pending" between accounting and tax authorities.
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Regularly reconcile invoice data – revenue – VAT. Monthly/quarterly checks allow for early detection of errors before tax authorities discover them and issue notices.
View more: Identifying legal, valid, and reasonable invoices and documents.
7. The role of Expertis in handling erroneous electronic invoices
In a business environment where speed and strict compliance are crucial, Expertis' services typically deliver value at the following bottlenecks:
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Review and classify errors and select the optimal solution. (No repetition/adjustment/replacement), reducing the risk of mishandling the mechanism.
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Standardize explanatory documents.: Agreement document with the buyer, accompanying supporting documents, and storage logic for payment/inspection purposes.
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Process design & internal control (SOP + control points) For the invoice lifecycle: create – sign – send – amend – save – declare.
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Tax filing and handling advice When adjusting/replacing invoices requires supplementary declarations, ensure that the process is "correct period - correct documentation - correct trace".
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Assisting with work with tax authorities. when an error notification or a request for data review arises.
Please note the following:
This article provides a general overview based on published legal regulations and administrative procedures; when applying it to specific situations (especially those related to supplementary declarations and transaction documents), businesses should review actual data and systematize evidence before proceeding with the software.