SOME KEY HIGHLIGHTS IN DECREE NO. 70/2025/NĐ-CP: AMENDMENTS AND SUPPLEMENTS TO CERTAIN ARTICLES OF DECREE NO. 123/2020/NĐ-CP OF THE GOVERNMENT ON INVOICES AND DOCUMENTS

Decree No. 70/2025/NĐ-CP was issued to amend and supplement several provisions of Decree No. 123/2020/NĐ-CP in order to better align with the practical implementation of electronic invoices in recent years. These updates are aimed at simplifying administrative procedures, enhancing transparency, and ensuring the legal validity of electronic invoices and documents. Accordingly, the amended and supplemented provisions will take effect from June 1, 2025, and are outlined in detail as follows:

Content	Regulation	Current provision	Update under Decree No. 70
Subjects of Application
	Article 1 of Decree No. 70/2025/ND-CP		Addition: Foreign suppliers without a permanent establishment in Vietnam, engaging in e-commerce, digital platform-based business activities, and other services are now allowed to voluntarily register for the use of electronic invoices.
			Additional subjects are now mandated to use electronic invoices generated from Point-of-Sale (POS) systems or computers, including the following: – Household businesses and individual businesspersons with annual revenue of VND 1 billion or more, as stipulated in the Law on Tax Administration 2019. – Enterprises involved in direct sales of goods or provision of services to end consumers, specifically: + Commercial centers, supermarkets, and retail stores (excluding automobiles, motorcycles, and other motor vehicles); + Food and beverage establishments, restaurants, and hotels; + Passenger transportation services and road transport support services; + Entertainment, recreational, performing arts, cinema services, and other personal service activities as defined by economic sector regulations.
		Entities authorized to issue invoices on behalf of others shall only apply to: enterprises, economic organizations, other organizations, and affiliated parties.	Additional provision: Authorization to issue invoices on behalf of a third party is now extended to household businesses and individual businesspersons.
		There is currently no clear regulation regarding the issuance of electronic invoices for export activities.	Addition of electronic invoice types used for export activities, including electronic commercial invoices, applicable to taxpayers who meet the conditions for transmitting electronic data to the tax authorities.
Time of invoice issuance
	Article 1 of Decree No. 70/2025/ND-CP
Export of goods (including export processing)		After completing the export procedures for goods	The seller shall determine the timing of invoice issuance, but no later than the next working day following the date the goods are cleared through customs.
The group must issue invoices no later than the 7th day of the following month due to the requirement for reconciliation		This applies to cases of service provision involving large volumes and frequent occurrences, where a period of data reconciliation between the buyer and the seller is required, as specified in Point a, Clause 4, Article 9 of Decree No. 123/2020/ND-CP.	Similarly, additional sectors are included, such as: Railway transport support services, television advertising services, e-commerce services, banking services (excluding lending activities), international money transfer services, securities services, electronic lottery services, road usage fee collection between investors and toll service providers, and other cases as guided by the Minister of Finance.
Retail trading and food and beverage services operating under a direct-to-consumer store system model, where all business accounting is conducted at the head office		Invoices may be issued at the end of the day	The regulation allowing invoice issuance at the end of the day is removed
Issuance of invoices at the end of the day/month for certain services (such as banking, securities, insurance, etc.) when the buyer is an individual who does not request an invoice		Invoices may be issued at the end of the day or month	The regulation allowing invoice issuance at the end of the day/month is removed
Taxi transportation business using fare calculation software		There is a requirement to transmit data/send information after each trip	At the end of each trip, the invoice must be issued and the data transmitted to the tax authorities
The time of electronic signing on the invoice may differ from the time the invoice is issued		Timing of invoice issuance and electronic signing: No restrictions	Timing of invoice issuance and electronic signing: The time of electronic signing, submission to the tax authority for code issuance, or data transmission to the tax authority must be no later than the next working day from the invoice issuance time.​
		Valid invoice: Not specifically addressed, but in practice, such invoices are accepted as valid	Valid invoice: An invoice is valid if it meets the prescribed timing requirements
		Tax declaration timing: No specific regulation; the declaration timing is guided by the following official dispatch: + For the seller: The tax declaration time is the time the invoice is issued​;​ + For the buyer: The tax declaration time is the time the invoice is correctly and fully received in terms of form and content​​	Tax declaration timing: ​​ ​+ For the seller: the time the invoice is issued; + For the buyer: the time the invoice is properly and fully received in both form and content.
Invoice content
Buyer information		Name, address, tax identification number	Addition of the use of the buyer’s personal identification number or the code of units related to the budget
Description of goods and services (G&S) for certain industries		No specific requirements yet	+ Food and beverage services: Specify the types of food and drinks (instead of a general “food and beverage service” description) + Transportation services: Indicate the vehicle’s license plate number and the route (departure point – destination) + Transport service business providing freight transport services on digital platforms and e-commerce activities: Include the name of the transported goods and information such as the name, address, tax code, or personal identification number of the sender.
Promotional, complimentary, or gifted goods		No specific guidance provided	+ It is permitted to issue an invoice for the total value of promotional goods + The invoice must clearly state: “attached with the detailed list number..., dated... day... month... year...” + The detailed list must specify the name, tax code, and address of the seller; the names of goods and services; quantity; unit price; total amount of goods and services sold; the date of preparation; and the name and signature of the person who prepared the list + The order of goods on the detailed list must follow the sequence of issuance during the day, and the list must clearly state: “attached to invoice number..., dated... day... month... year...”
Procedures for Handling Invoice Errors:
Invoices issued incorrectly before being sent to the buyer​		Incorrectly issued invoices may be canceled	The regulation allowing cancellation of incorrectly issued invoices is removed
Agreement minutes between the buyer and the seller		Not mandatory	A new provision requires that the seller and buyer must prepare a written agreement clearly specifying the error. In cases where the buyer is an individual, the seller must notify the buyer directly or publish the notice on the seller’s website
Issuance of a single corrective invoice to adjust multiple invoices		Not addressed	A new provision allows the issuance of a single corrective invoice to adjust multiple erroneous invoices issued within the same month and to the same buyer
Handling electronic invoices that were issued incorrectly and continue to have errors		Not addressed	For electronic invoices issued incorrectly, once the seller has handled the correction or replacement, if errors occur again subsequently, the handling must follow the same correction method applied during the initial resolution
Due to the nature of the transaction
The settlement value involves changes in price or project volume​		Not yet regulated	The seller issues a new electronic invoice for the settlement difference
Commercial discounts		Not yet regulated	+ Based on the quantity and turnover of goods and services: Adjustments are made on the invoice of the last purchase or the subsequent period, not exceeding the value of the goods;​ + Alternatively, a corrective invoice may be issued accompanied by a detailed list of invoices to be adjusted, including the adjusted amount and tax.
Return of goods		No clear regulation on the subjects responsible for issuing invoices in cases of goods returns	+ For full or partial returns: The seller issues a corrective invoice (except in cases where the buyer agrees to issue a return invoice); +For goods that are assets requiring registration of usage rights or ownership rights: The buyer issues a return invoice;
Issuance of invoices for advance payments before providing services or collecting money in real estate business, infrastructure construction, etc., followed by cancellation or termination of the transaction		Cancellation of the issued invoice and notification according to Form 04/SS-HĐĐT​	+ The seller issues a corrective invoice.
Tax declaration for incorrectly issued invoices
Correction and replacement for invoices previously issued with errors such: as incorrect tax identification number, incorrect amounts stated on the invoice, incorrect tax rates, tax amounts, or goods listed with incorrect specifications or quality		+ Not yet regulated in Decree No. 123/2020/ND-CP	The seller and buyer shall make supplementary tax declarations in the period when the adjusted or replaced invoice arises
Adjustment for cases arising from the nature of the transaction		+ Not yet regulated	+ Seller: Declare in the period when the corrective invoice arises; + Buyer: Declare in the period when the corrective invoice is received

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