In manufacturing, machinery leaving a factory or goods being dispatched from a warehouse does not necessarily trigger an obligation to issue an electronic invoice. Similarly, in banking, financial services, and insurance (BFSI), not every transaction involving the movement of funds is subject to the same invoicing requirements. The determining factors are the nature of the business activity, the purpose of the transaction, and the applicable legal conditions.
Decree No. 254/2026/NĐ-CP and Circular No. 91/2026/TT-BTC further clarify these distinctions by specifying cases in which electronic invoices are not required and establishing distinct treatment for different types of transactions. This article examines the key changes affecting manufacturing and BFSI, along with their implications for transaction classification, reconciliation, and electronic invoice management.
Manufacturing
In manufacturing enterprises, a significant number of internal operations may involve movements of goods, assets, or tools recorded in enterprise systems without necessarily constituting sales transactions. Decree 254 further clarifies this distinction by identifying certain activities directly supporting production and business operations as cases in which electronic invoices are not required.
One example involves machinery and equipment transferred to another entity for use in processing goods. Under previous regulations, invoices were still required for goods issued under loan or lending arrangements. Decree 254 introduces a specific exception for machinery and equipment lent as fixed assets or tools and supplies for the purpose of processing goods belonging to the lender. The conditions are strict. The assets must be lent specifically for processing the lender’s goods, no payment may be received for their use, and ownership must remain with the company providing the assets. As a result, the same physical movement of machinery out of a factory may be subject to entirely different invoicing requirements depending on the nature of the transaction. If a company sells equipment, rents it out for a fee, or transfers ownership, the transaction does not qualify for this specific exception. However, if the company simply sends molds, machinery, or tools to a contract processor for use in manufacturing goods on its behalf and subsequently receives those assets back, the transaction may not require an electronic invoice, provided all the conditions are met.
From an operational perspective, this change shifts the focus of controls from automatically generating an invoice whenever an asset leaves the premises to accurately classifying the purpose of each asset transfer. Asset management systems or enterprise resource planning (ERP) systems need to distinguish, at a minimum, between sales, rentals, lending for contract processing, and other types of asset transfers. Supporting documentation must also be sufficient to establish which entity received the assets, which processing contract they support, whether any payment is involved, and whether ownership has been transferred. If this information remains fragmented across contracts, production departments, and accounting records, businesses may still incorrectly route transactions qualifying for the exception through the invoicing process, or fail to issue invoices for transactions that do not qualify.
The second category concerns goods and services produced or provided by businesses for use in their own production and business operations. Before July 1, 2026, Decrees 123 and 70 still required invoices for goods and services used for internal consumption, except for goods transferred internally to continue the production process, such as internal warehouse transfers or the issuance of materials and semi-finished goods for further production. Decree 254 expands the cases in which electronic invoices are not required to include goods and services issued or provided by businesses for use in their own production and business activities, including fixed assets constructed or manufactured in-house. This provision cross-references the corresponding cases under Decree No. 181/2025/NĐ-CP on value-added tax (VAT).
This change is particularly significant for businesses managing multiple types of internal warehouse dispatches. Within a single ERP or warehouse management system (WMS), transactions may involve goods sold to customers, raw materials transferred to the next production stage, semi-finished goods moved between departments, tools manufactured in-house and put into use, and goods issued for other purposes. Not all of these goods issue transactions follow the same invoicing workflow. Systems must therefore determine whether a transaction should be routed to the electronic invoicing system based on its business purpose, rather than solely on whether goods have been dispatched from a warehouse.
Banking, Financial Services, and Insurance (BFSI)
In BFSI, invoicing requirements vary significantly depending on the nature of each transaction. Within the same banking or financial system, service fees, deposits, foreign exchange transactions, securities issuance, debt sales, and insurance premiums may be subject to entirely different invoicing treatments. Under Decree 254, a critical control point therefore lies in classifying transactions before the relevant data is transferred to the invoicing system.
For banks, certain transactions are explicitly identified as cases in which electronic invoices are not required. These include accepting deposits; issuing certificates of deposit, primary-market securities, and other valuable papers; selling debt; and conducting foreign exchange and derivative transactions. However, this does not mean that all revenue generated in connection with these activities is excluded from invoicing requirements. For example, a money transfer fee or banking service fee must still be assessed separately based on the nature of the service provided. Banking systems must therefore be able to identify transaction types before determining whether the associated data should proceed through the invoicing workflow.
Foreign currency sales are subject to a separate procedure. Under Decree 254, banks are not required to issue an electronic invoice for each foreign currency sale. Instead, detailed information on individual transactions is retained in their systems. At the end of each month, banks prepare and retain a consolidated statement detailing all transactions conducted during that month. This statement does not need to be submitted periodically to the tax authority but must be provided upon request by the tax authority or another competent state authority. The operational focus therefore shifts from issuing invoices for individual transactions to ensuring that transaction records are complete, accurate, and readily retrievable when needed.
In addition, banks are now explicitly included among the entities eligible to use electronic invoices without a tax authority’s code, provided they meet the requirements for IT infrastructure, accounting software, invoicing software, invoice retrieval, data storage, and data transmission. Under this model, invoices are issued and sent directly to customers, while the corresponding data is transmitted to the tax authority in accordance with the mechanism applicable to electronic invoices without a tax authority’s code. Individual invoices therefore do not need to await the assignment of a code by the tax authority before issuance.
A separate mechanism applies to certain services provided directly to individual consumers. Decree 254 introduces the Detailed Transaction Information Statement (Form No. 01/TTGD) for services such as banking, payment intermediation, credit information services, securities trading, insurance, money transfers through electronic wallets, and certain other financial services. To qualify, businesses must have software capable of managing individual transactions in detail and retaining the corresponding payment collection data for each transaction. These records are maintained at the individual transaction level throughout the reporting period and subsequently consolidated into Form No. 01/TTGD for submission to the tax authority within the prescribed deadline. This mechanism differs from the consolidated statement for foreign currency sales: Form No. 01/TTGD is submitted periodically to the tax authority, whereas the foreign currency sales statement is retained internally and provided only upon request.
For finance companies and securities firms, a similar challenge arises in distinguishing the value of the underlying financial transaction from any associated service fees. Decree 254 identifies primary-market securities issuance, the issuance of valuable papers, debt sales, and derivative products as cases in which electronic invoices are not required. However, fees for issuance advisory, brokerage, distribution, management, and other services must still be assessed separately. A single transaction record may therefore contain both components that do not require electronic invoices and components for which invoices remain mandatory. Business and accounting systems must distinguish between these components to ensure that only transactions falling within the scope of Article 7 are excluded from the invoicing process.
Certain business-to-consumer (B2C) financial services, including securities trading, crypto-asset transactions, and services supporting transactions on carbon exchanges, may also use Form No. 01/TTGD if they meet the requirements for detailed transaction management and payment collection records. In such cases, businesses cannot simply retain a single aggregate figure at the end of the reporting period. They must preserve detailed records of each transaction to support consolidation, reconciliation, and submission to the tax authority using the prescribed form.
In insurance, invoicing procedures are further differentiated by transaction type. For reinsurance activities, fees and other receipts, including those arising from reinsurance cessions, ceding commissions, and other related income, fall within the category of transactions for which electronic invoices are not required. This provision applies specifically to reinsurance and does not extend to all insurance business activities. Insurance systems must therefore distinguish direct insurance transactions from reinsurance transactions at the outset to prevent invoices from being automatically generated for amounts covered by the exception.
For insurance transactions requiring time for reconciliation, Decree 254 adds insurance to the category of high-volume, recurring services for which the invoice issuance date is determined by the completion of data reconciliation. Previously, this mechanism was explicitly applicable to certain cases, such as insurance services provided through agents. Under Decree 254, its scope has been expanded to include insurance operations that meet the relevant conditions concerning transaction frequency and reconciliation requirements. Systems must therefore distinguish between transactions for which invoices are issued upon recognition of insurance revenue and those for which invoicing may be deferred until reconciliation is completed.
Coinsurance arrangements follow different invoicing procedures depending on which insurer collects the premiums. If each participating insurer collects its own share of the premium, each insurer issues an invoice to the customer for the corresponding amount. If the participating insurers authorize one insurer to collect the entire premium on their behalf, the collecting insurer issues an invoice to the customer for the full contract value. The other participating insurers then issue invoices to the collecting insurer for their respective shares of the premium. Accordingly, the system must capture each insurer’s participation percentage, the party authorized to collect premiums, and the premium share allocated to each insurer from the contract stage to correctly determine who must issue and receive each invoice.
Circular 91 also introduces a specific mechanism for insurance premiums that have already been invoiced but remain uncollected at the end of the reporting period. Based on data on uncollected premiums from the previous month, insurers prepare a consolidated adjustment invoice accompanied by a supporting schedule specifying the relevant invoice numbers, amounts, and corresponding tax amounts requiring adjustment. The process therefore does not end when an invoice is issued. Premium collection systems must continue tracking the collected or outstanding status of each premium and reconcile this information against invoice records at the end of the reporting period to identify amounts requiring adjustment. The Circular also permits adjustment invoices without references to the original invoices in certain cases, with adjustment reasons such as premium refunds, premium reductions, reductions in insurance brokerage commissions, and other payments that reduce revenue in accordance with insurance business regulations.
Conclusion
The changes introduced under Decree 254 and Circular 91 demonstrate how electronic invoicing requirements are becoming increasingly aligned with industry-specific business operations. In manufacturing, the same warehouse dispatch or asset transfer may be subject to different invoicing treatments depending on its purpose and the nature of the transaction. In BFSI, these distinctions extend to invoicing procedures, data retention, transaction consolidation, and reconciliation requirements for different types of services.
These changes require businesses to review not only their invoicing procedures but also how data is recorded and processed within their underlying business systems. By establishing invoicing rules that reflect the nature of each transaction, businesses can minimize errors arising between systems while maintaining consistency in financial management, accounting, and regulatory compliance.
