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Issued on June 30, 2026 and effective from July 1, 2026, Decree 254/2026/NĐ-CP provides the new regulatory framework for electronic invoices and electronic documents under the Law on Tax Administration No. 108/2025/QH15. From the same date, Decree 123/2020/NĐ-CP and Decree 70/2025/NĐ-CP cease to have effect.
The decree updates the rules governing e-invoices and e-documents to reflect the regulatory requirements applicable from July 2026. This article provides an overview of its scope, key changes, major invoicing requirements, and implications for businesses and tax administration.
Objectives and Legal Significance
The overarching goal of Decree 254 is to establish an updated and consistent legal framework for electronic invoices and electronic documents under the Law on Tax Administration No. 108/2025/QH15. It standardizes the issuance, management, transmission, storage, lookup, and use of electronic invoice and document data, while strengthening transparency and the use of such data in tax administration. Legally, the decree consolidates the regulatory framework previously governed by Decree 123/2020/NĐ-CP and its amendments, including Decree 70/2025/NĐ-CP, into the new framework implementing the 2025 Law on Tax Administration.
Unlike the earlier nationwide transition to e-invoicing under Decree 123, Decree 254 does not establish a new general adoption deadline. Issued on June 30, 2026, it took effect on July 1, 2026, with specific transitional provisions applying to certain documents and existing arrangements. This means the decree functions primarily as the legal basis for the next stage of Vietnam’s e-invoice and e-document regime rather than as the starting point of electronic invoicing itself
Scope of Application
Decree 254/2026/NĐ-CP has a broad scope of application, covering organizations and individuals involved in the sale of goods and provision of services, as well as other parties participating in the management and use of electronic invoices and electronic documents. The primary subjects include enterprises, cooperatives and cooperative unions; branches and representative offices of foreign enterprises operating in Vietnam; household and individual businesses; public service units engaged in commercial activities; and other organizations conducting business activities. The decree also covers foreign organizations, including operators of overseas e-commerce and digital platforms, that generate taxable revenue in Vietnam and voluntarily register to use e-invoices.
In addition to sellers, the decree applies to buyers of goods and services; organizations collecting taxes, fees and charges; taxpayers and tax withholding entities; providers of electronic invoice and electronic document services; tax authorities; and other organizations and individuals involved in the management and use of invoices and documents.
Compared with the previous framework, Decree 254 updates the applicable entities to reflect a fully electronic invoice and document regime. It expressly aligns the treatment of foreign suppliers and overseas platform operators with the 2025 Law on Tax Administration, while removing entities associated solely with printing or self-printing paper invoices and documents from the list of applicable subjects
Regulatory Coverage and Provisions
Decree 254 governs the management and use of electronic invoices in the sale of goods and provision of services, as well as electronic documents used in tax, fee, and charge administration. It establishes principles for the issuance, management, use, storage, and retention of e-invoices and e-documents; identifies cases involving the use of unlawful invoices and documents; and sets requirements for invoice issuance timing and required invoice contents across different business scenarios.
Among its notable provisions is a new transaction-data mechanism for certain services provided to individual consumers. For qualifying businesses with electronic transaction management systems, Decree 254 introduces a Detailed Transaction Information Table and related data-transmission requirements, allowing detailed transaction data to become part of the tax administration process alongside e-invoice information.
The decree also contains transitional provisions for the remaining paper-based invoices and receipts. From July 1, 2026, unused tax-authority-ordered printed invoices cease to be valid, while unused self-printed or ordered-printed paper receipts under Decree 123 may continue to be used until December 31, 2026. Paper sales invoices for national reserve goods remain subject to separate transitional arrangements until the Ministry of Finance announces the conversion to electronic national reserve sales invoices.
Key Changes Under Decree 254/2026/NĐ-CP
Compared with the framework under Decree 123/2020/NĐ-CP, as amended by Decree 70/2025/NĐ-CP, Decree 254 updates and reorganizes a number of rules to implement the Law on Tax Administration No. 108/2025/QH15. Key differences include:
- Updated e-invoice user framework: Decree 254 expands the group of businesses eligible to use e-invoices without a tax authority code to include sectors such as banking, securities, crypto assets, and services supporting transactions on carbon exchanges. For household businesses and individual businesses, it retains the VND 1 billion annual revenue threshold already reflected in the previous framework while clarifying the applicable e-invoice options.
- Explicit cases where e-invoices are not required: A dedicated provision now identifies transactions and activities that do not require the use of e-invoices, including certain transactions of household and individual businesses, financial activities, asset contributions, and internal asset transfers.
- More detailed invoice issuance timing: The decree adds and refines timing rules for specific business models, including an exception for qualifying deposits and additional rules for services that require data reconciliation, such as digital technology, digital platforms, insurance, crypto-asset services, and carbon-market services.
- Updated invoice content requirements: Decree 254 supplements the rules on seller and buyer information, descriptions of goods and services, authorized e-invoices, auction transactions, and other transaction-specific invoice contents.
- Refined cash-register e-invoice framework: Rather than introducing this mechanism for the first time, Decree 254 further clarifies the businesses subject to e-invoices generated from cash registers and provides that economic organizations, household businesses, and individual businesses that have already registered to use qualifying coded or non-coded e-invoices are not automatically required to register for cash-register e-invoices as well.
- Expanded rights, responsibilities, and e-document rules: The decree adds provisions on system incident handling, the rights and responsibilities of sellers and buyers, duties of service providers and tax authorities, incentives for consumers reporting failures to issue and deliver invoices, and the creation and transmission of electronic documents
Transaction-Based E-Invoicing: A Key Innovation
One of the notable innovations under Decree 254 is a new transaction-data mechanism for certain services provided to individual consumers. It applies to qualifying businesses in areas such as banking, payment intermediation, securities, insurance, crypto-asset transactions, e-commerce, passenger transport, parking, and cinema services, provided that they operate software capable of managing each transaction in detail and storing payment data on a transaction-by-transaction basis.
For these businesses, detailed transaction data is transmitted to the tax authority through a prescribed Detailed Transaction Information Table. The seller remains responsible for the accuracy and completeness of the data and must ensure that the data can be stored, retrieved, reconciled, and provided to the tax authority or other competent authorities when required.
The Detailed Transaction Information Table is prepared for the relevant month or quarter and submitted to the tax authority no later than the deadline for filing the corresponding VAT return. This creates a structured reporting mechanism for businesses handling large volumes of consumer transactions while preserving transaction-level information for tax administration and verification.
This approach reflects a broader shift toward data-driven e-invoice administration. Rather than relying solely on invoice data, the framework also incorporates detailed transaction information maintained in qualifying businesses’ electronic systems, better reflecting the operating model of high-volume digital and consumer services.
Timing of Invoice Issuance
Decree 254 provides specific rules for determining when an invoice must be issued across different transaction scenarios. For the sale of goods, the invoice issuance time is when ownership or the right to use the goods is transferred to the buyer, regardless of whether payment has been received. For services, invoices are generally issued upon completion of the service; where payment is collected before or during service provision, the invoice is issued when payment is received. An exception applies to deposits collected in accordance with the Civil Code to secure the performance of a service contract, which do not trigger invoice issuance. Where goods are delivered multiple times or services are handed over in separate stages, an invoice must be issued for each corresponding delivery or completed stage.
For high-volume, recurring transactions that require data reconciliation between the parties, invoice issuance generally occurs when the reconciliation is completed, but no later than the 7th day of the month following the month in which the service was provided, or within seven days after the end of the agreed billing period. Decree 254 extends this mechanism to additional specified services that require data reconciliation. It also introduces a specific rule allowing sellers without automated invoicing software to issue invoices no later than the next working day for transactions arising during night working hours
Cases Where E-Invoices Are Not Required
A notable addition under Decree 254 is a dedicated provision identifying cases where e-invoices are not required. Article 7 sets out eight categories, covering certain activities of household and individual businesses; lottery, insurance, and multi-level marketing agency arrangements where tax has already been withheld; specified reinsurance and financial transactions; asset contributions; internal asset transfers; and certain movements or uses of assets and goods that do not constitute ordinary sales transactions.
The provision helps distinguish transactions that trigger invoice issuance from those that are tracked through other documents, data, or tax records. However, not being required to use an e-invoice does not necessarily remove related recordkeeping obligations. For example, the relevant entity must prepare a monthly detailed transaction summary based on their data management systems and provide it to the tax authority or other competent authorities upon request
Benefits for Businesses and Tax Authorities
For businesses, Decree 254 provides a more structured framework for e-invoice and e-document management, with clearer rules on invoice issuance timing, required contents, data transmission, system incidents, and the rights and responsibilities of relevant parties. Standardized electronic data and more specific rules for different business models can reduce uncertainty in invoice handling, support more consistent accounting and reconciliation processes, and make invoice information easier to store, retrieve, and provide when required.
For tax authorities, Decree 254 strengthens the role of e-invoice and e-document data as a source of information for tax administration. Standardized data transmission and more detailed transaction information improve the ability to verify and reconcile transactions, identify compliance risks, and support data-based tax management. Together with the broader digital framework under the 2025 Law on Tax Administration, these provisions support greater transparency and more efficient administration while reducing reliance on manual processes.
Conclusion
Decree 254/2026/NĐ-CP marks the next stage of Vietnam’s e-invoice and e-document framework, with more detailed requirements tailored to different transaction types and business models.
Businesses should therefore review whether the new rules affect their current invoicing workflows, particularly invoice issuance timing, transaction-data reporting, cases where e-invoices are not required, cash-register e-invoice obligations, and related data management processes. Aligning internal procedures and information systems with these requirements will be essential for applying the new framework consistently in practice.
