Vietnam E-Invoicing: Requirements, Challenges and Solutions

Vietnam introduced e-invoicing as part of a broader tax modernization and digital transformation agenda. The government aims to enhance fairness and transparency in taxation, reduce fraud, and improve tax collection efficiency. By transitioning from paper to electronic invoices, authorities seek to close VAT reporting loopholes and gain real-time oversight of transactions.

Vietnam’s e-invoicing journey began in September 2018 with Decree 119/2018, initially mandating nationwide adoption by November 1, 2020. However, to allow more preparation time and align with the new Tax Administration Law, Decree 123/2020 postponed the mandate to July 1, 2022. A pilot program was launched in late 2021, and despite initial delays, including those caused by COVID-19, Vietnam successfully transitioned to mandatory e-invoicing as of July 1, 2022, rendering paper invoices obsolete in most cases.

Taxpayer Scope

The e-invoicing mandate in Vietnam has a broad scope. It applies to all enterprises, organizations, and entrepreneurs established under Vietnamese law, including domestic companies of all sizes and local branches of foreign companies.

However, exemptions exist for individuals and business households with annual revenue below VND 100 million, businesses in remote areas with limited internet access, and certain financial services such as banking, insurance, and securities transactions. Additionally, specific government-related transactions, such as defense purchases and agricultural products sold by small-scale farmers, may also be exempt from e-invoicing requirements.

The General Department of Taxation (GDT) has placed a strong focus on enforcing e-invoicing compliance in the digital economy, recognizing that many online businesses, e-commerce platforms, and marketplaces were initially slow to adopt the requirements. In mid-2024, the GDT launched targeted inspections to ensure all online business activities comply, closing gaps where digital sales had previously occurred without proper invoicing.

Transactional Scope

E-invoicing in Vietnam applies to all transaction types, including B2B, B2G, and B2C transactions, ensuring comprehensive coverage across different business models. Additionally, export transactions are included within the mandate, requiring businesses engaged in international trade to comply with the e-invoicing regulations.

Document Types

Vietnam’s e-invoicing system covers a variety of document types, including:

• Value Added Tax (VAT) invoices: Issued by organizations that declare VAT using the declaration method.
• Sales invoices: Issued by organizations and individuals that declare and calculate VAT using the direct method.
• Adjustment invoices: Used to correct errors in tax codes, amounts, tax rates, or product specifications.
• Other electronic documents functioning as e-invoices: Includes e-stamps, e-tickets, e-cards, and e-receipts.
• E-delivery notes: Used for internal stock transfers and shipments.
• Special categories: Covers public property sales and national reserve goods transactions.

Each of these document types is assigned a specific code or identifier within Vietnam's e-invoicing system and schema. As a result, businesses must accurately determine which document types they need to issue to ensure compliance with regulatory requirements.

Compliance Steps

Businesses must follow these steps to comply with e-invoicing regulations:

Determine Document Types and Issuance Method: Before registering with the tax authority, businesses must decide which e-invoice document types they need to issue, as each type has a specific code within Vietnam's e-invoicing system. Additionally, they must select an issuance method that best suits their operations:

• Direct integration via API
• Using an accredited service provider
• Manually uploading XML invoices to the GDT portal

Registration with GDT: Register for e-invoicing by submitting Form 01/ĐKTĐ-HĐĐT (registration for e-invoice use) via the GDT’s e-invoice web portal or through an accredited e-invoice service provider. This form includes business details and specifies the type of e-invoice system to be used. The GDT will review and approve the registration, after which the business is officially allowed to issue electronic invoices.

Obtain a digital signature: All e-invoices in Vietnam, except the ones issued via POS, must be digitally signed by the issuer to ensure authenticity and integrity. Businesses, therefore, need to procure a valid digital signature from a provider approved by GDT. Local accredited service providers typically assist with the registration process and acquiring a digital signature, ensuring compliance with regulatory requirements.

Issuance of E-Invoices: Once the tax authority confirms the registration and format approval, the business can start issuing e-invoices for all transactions. Many businesses operate under a real-time clearance system, where invoices must first be transmitted to the GDT platform to receive a unique verification code before being sent to the buyer. The GDT system validates the invoice and assigns a code that must be included on the final e-invoice.

However, certain businesses in regulated sectors or with strong internal controls may be permitted to issue e-invoices without prior tax authority authentication. These invoices must still be reported to the GDT, either asynchronously after issuance or periodically alongside VAT returns. Approval from the tax authority is required for businesses to issue invoices without the GDT code.

It’s important to note that GDT does not perform e-invoice exchange, meaning businesses need to exchange e-invoices with their trading partners after validating the e-invoice with the GDT code.

Upcoming Changes

As noted in the Scope section, the GDT has intensified enforcement efforts in the digital economy, launching targeted inspections in mid-2024 to ensure full compliance among online businesses, e-commerce platforms, and marketplaces. Building on this, upcoming regulatory changes are expected to further tighten indirect tax controls for these businesses.

Among the upcoming changes is a new framework allowing platform sellers to authorize e-commerce platforms to issue e-invoices on their behalf, streamlining compliance for individual sellers. Additionally, tax collection responsibilities will shift toward e-commerce platforms, requiring them to withhold and remit VAT and Personal Income Tax (PIT) on behalf of sellers before transferring payments. Platforms will also be required to issue annual withholding certificates and transmit this information to the GDT via e-invoicing service providers, ensuring greater transparency and oversight.

These changes are still in draft form, and further refinements can be expected before final implementation.

Challenges

Taking the first steps toward e-invoicing compliance in Vietnam can be challenging, as businesses must navigate multiple complexities from the outset. Determining the correct document types is crucial, as each is represented by specific letters and numbers that form the invoice symbol, a key compliance requirement on all e-invoices. This process is closely tied to registering with the tax authority and obtaining a digital signature, both of which are essential for issuing valid e-invoices. Given these intricacies, working with an experienced service provider can help businesses streamline setup, minimize errors, and ensure compliance from day one.

E-commerce platforms face additional unique challenges in Vietnam’s evolving e-invoicing landscape. While issuing invoices on behalf of third-party sellers is only an option, the more immediate challenge is managing VAT collection and issuing withholding certificates. Platforms will soon be required to withhold and remit VAT and PIT on behalf of sellers, adding to their compliance burden.

Fonoa’s Solution

Fonoa has seamlessly integrated Vietnam’s e-invoicing requirements into its standard e-invoicing product, providing a streamlined solution for businesses. By using Fonoa’s platform, users can benefit from:

• Single API Integration: Handle all document and transaction types through one unified API.
• CSV and Batch Uploads: Easily manage large volumes of invoices with CSV uploads and batch processing capabilities.
• Customizable PDF Templates: Generate visually appealing and tailored PDF invoices to meet specific branding or formatting needs.
• Support for E-commerce, Marketplaces, and Platform Economies: Ensure compliance for various business models, including those operating in the digital and platform economy.
• End-to-End Indirect Tax Compliance: Leverage Fonoa’s full suite of solutions—including tax ID validation, tax determination, e-invoicing, digital reporting, and VAT returns—to automate and manage the entire indirect tax lifecycle across global jurisdictions.

Existing Fonoa clients can quickly extend their compliance efforts to Vietnam, leveraging the same integration methods they use in other regions, ensuring a consistent and efficient e-invoicing process.