On March 20, 2025, the Vietnamese Government published Decree No. <a href="https://vanban.chinhphu.vn/?pageid=27160&amp;docid=213179" target="_blank" rel="noopener">70/2 025/ND-CP,</a> which includes essential regulatory updates for electronic invoicing and supporting documents, set to take effect as of June 1, 2025.
&nbsp;
This decree amends and supplements a range of articles in Decree No. 123/2020/ND-CP, &ldquo;The government regulating invoices and documents&rdquo; from 2020, and aims to enhance compliance, simplify e-invoice issuance, and improve integration with the tax authority&rsquo;s systems by clarifying taxpayers, intermediaries, and software providers' responsibilities.
&nbsp;
Some of the main changes include the following.
<ul>
<li>Extended scope: Compliance requirements for foreign suppliers without a permanent establishment in the country, including digital platform-based businesses and companies engaged in e-commerce activities. These requirements involve implementing specific timelines for issuing invoices across different transactions. This group of companies may voluntarily register to issue electronic VAT invoices.</li>
<li>Invoice issuance and timings: 
<ul>
<li>Sellers, including individual businesses, are allowed to appoint a third party for invoice issuance following a written agreement;</li>
<li>Clarifications on invoice types are provided for 'export processing enterprises' involved in additional business activities beyond export and processing. These clarifications outline whether electronic sales invoices or electronic VAT invoices should be used based on these companies&rsquo; tax declaration method;</li>
<li>Businesses are allowed to issue e-commerce invoices when exporting goods or services, provided they meet the content, format, and transmission requirements;</li>
<li>For exported goods, sellers may decide when to issue the invoice, but it must be no later than the workday following the customs clearance of the goods;</li>
<li>Additional amendments concerning the issuance timing for specific scenarios, such as the sale of&nbsp;national reserve goods and sectors, e.g., credit institutions, insurance businesses, passenger transport, and retail trading.</li>
</ul>
</li>
<li>Invoice content:&nbsp; 
<ul>
<li>Invoices must include additional information such as budget-related unit code or the personal identification number of end consumers, as provided by the buyer;</li>
<li>If the digital signature time differs from the e-invoice issuance time, the invoice must be submitted to the tax authority no later than the next working day after the e-invoice was issued.</li>
</ul>
</li>
<li>Rectification process:&nbsp; 
<ul>
<li>The invoice cancellation process is replaced by either adjustment or replacement processes, depending on the specific scenario;</li>
<li>Before adjusting or replacing an e-invoice, the buyer and seller must have a written agreement specifying any incorrect content for B2B invoices. For B2C transactions, the seller must either notify the buyer or announce it on their website;</li>
<li>It is allowed to issue one invoice to replace or adjust multiple incorrect invoices issued in the same month to the same buyer;</li>
<li>Additional clarification for invoice scenarios when goods are returned.</li>
</ul>
</li>
</ul>
<ul>
<li>Extended scope for cash register e-invoices:&nbsp; 
<ul>
<li>Business households, individual businesses with annual revenue of 1 billion VND (approximately 34,000 EUR) or more, and companies with B2C transactions, such as shopping centers, supermarkets, restaurants, and passenger transportation services, are required to use e-invoices generated by cash registers connected to tax authorities for data transmission.</li>
</ul>
</li>
</ul>
&nbsp;
Decree 70 also introduces numerous amendments and additions to certain forms and report templates. Additionally, the list of prohibited actions includes failing to transmit electronic data to tax authorities and forging invoices and documents.
&nbsp;
Businesses operating in Vietnam and their tax advisors are recommended to review and analyze this decree&rsquo;s impact on their business models and compliance requirements.
&nbsp;
&nbsp;
&nbsp;

On March 20, 2025, the Vietnamese Government published Decree No. 70/2025/ND-CP, which introduces significant regulatory updates for electronic invoicing and supporting documents, effective June 1, 2025. It covers an expanded scope, new invoice issuance and types provisions, updated timing regulations, invoice content requirements, and amended rectification rules for e-invoices.

Decree 70/2025: Important updates to electronic invoices

On November 26, 2024, Vietnam&rsquo;s National Assembly passed a new Value Added Tax (VAT) Law, <a href="https://chinhphu.vn/?pageid=27160&amp;docid=212476&amp;classid=1&amp;typegroupid=3" target="_blank" rel="noopener">Law 48/2024/QH15</a>, which will come into effect on July 1, 2025. The new VAT Law will replace the existing VAT Law No. 13/2008/QH12 and its amendments.
&nbsp;
The new VAT Law introduces significant changes and simplifies the regulatory framework by consolidating the provisions from previous decrees and amendments.
&nbsp;
What are the main changes?
<ul>
<li>Widened taxpayer definition:The new VAT law includes obligations for foreign suppliers without a permanent establishment in Vietnam, e.g., foreign suppliers engaging in e-commerce with both organizations and individuals, and foreign organizations operating on digital platforms.</li>
<li>Time of Determining VAT Liability: The timing of VAT liability is now explicitly regulated in the law. VAT obligations are triggered:
<ul>
<li>for goods at the time of the transfer of the ownership or the right to use the goods;</li>
<li>for services, when the provision of services is completed; or</li>
<li>at the time when an invoice is issued, regardless of whether payment has been received (applicable to both goods and services).</li>
</ul>
</li>
<li>Increased VAT exemption threshold: The VAT exemption threshold for businesses, households, and individuals will be increased from lower than 100 million (ca. 3.820 EUR) VND to lower than 200 million VND (ca. 7.640 EUR).</li>
</ul>
&nbsp;
Reclassified VAT Rates 
Some items have been reclassified, for example:
<ul>
<li>0% rate -&nbsp;The rate will apply to the export of goods and services provided for consumption outside of Vietnam, goods and services provided directly to organizations within tax-free zones including an additional requirement of directly serving export production activities.</li>
<li>5% rate -&nbsp;This rate will apply to specialized machinery and equipment used for agricultural production, animal feed, and fertilizers; offshore fishing vessels are reclassified and will be subject to the 5% VAT (previously exempt from VAT).</li>
<li>10% rate -&nbsp;Services supplied through e-commerce or digital platforms by foreign suppliers without a permanent establishment in Vietnam, such as film production, import, and distribution (previously subject to the 5% rate).</li>
</ul>
&nbsp;
Furthermore, it should be noted that more detailed and specific not-subject-to-VAT rules will apply to some goods and services, such as plant and forest products, plant breeding materials, life insurance, health insurance, agricultural insurance services, insurance of ships and boats, insurance of oil and gas works, and equipment.
&nbsp;
Finally, it&rsquo;s worth highlighting that to continue boosting consumption and support production, Resolution No.&nbsp;<a href="https://chinhphu.vn/?pageid=27160&amp;docid=211967" target="_blank" rel="noopener">174/2024/QH15</a>&nbsp;extends the reduced VAT rate from 10% to 8% for certain goods and services, specified in Resolution No.&nbsp;<a href="https://vanban.chinhphu.vn/?pageid=27160&amp;docid=205183" target="_blank" rel="noopener">43/2022/QH15</a>, until the end of June 2025.

A new Value Added Tax Law will come into effect on July 1, 2025, replacing existing VAT Law No. 13/2008/QH12 and its amendments. The new VAT Law simplifies the regulatory framework and brings significant changes, such as broadening the taxpayer definition, increasing the VAT exemption threshold, and redefining the VAT rates for certain goods and services.

New VAT Law becomes effective from July 1, 2025 in Vietnam

<a href="https://cfovietnam.wordpress.com/" target="_blank" rel="noopener">Resolution 101/2023/QH15</a> allows the Vietnamese Government to manage the VAT reduction in a timely manner and guarantee that there will be no negative impact on the State budget collection and overpayment.
&nbsp;
From 1 July to 31 December 2023, <a href="https://thuvienphapluat.vn/van-ban/EN/Thue-Phi-Le-Phi/Decree-44-2023-ND-CP-prescribing-value-added-tax-reduction-under-Resolution-101-2023-QH15/572031/tieng-anh.aspx" target="_blank" rel="noopener">Decree No. 44/2023/ND-CP</a> will be in effect. Goods and services currently subject to the 10% VAT rate will be subject to the reduced rate of 8%. However, the reduced VAT rate of 8% will not apply to the supply of certain goods and services, including:
&nbsp;
<ul>
<li>Telecommunications, IT services;</li>
<li>Finance and banking services, securities, insurance;</li>
<li>Real estate business;</li>
<li>Metal production and manufacture of prefabricated metal products;</li>
<li>Mining industry (excluding coal mining), production of coke (&ldquo;than cốc&rdquo;), refined petroleum, production of chemicals and chemical products; and</li>
<li>Goods and services that are subject to special sales tax.</li>
</ul>
&nbsp;
The General Customs Department issued the official letter <a href="https://thuvienphapluat.vn/cong-van/Thue-Phi-Le-Phi/Cong-van-3431-TCHQ-TXNK-2023-thuc-hien-Nghi-dinh-44-2023-ND-CP-571348.aspx" target="_blank" rel="noopener">No. 3431/TCHQ-TXNK</a> on 30 June 2023. This letter guides the implementation of the reduction of VAT at the rate of 8% for imported goods.

On 30 June 2023, the Government of Vietnam reduced the VAT from 10% to 8% through Decree No. 44/2023/ND-CP. This decree implements the VAT rate reduction policy approved by the National Assembly in Resolution 101/2023/QH15.

Vietnam Introduces a Reduced VAT Rate from 1 July 2023

As we wrote in our <a href="https://www.pagero.com/news/mandatory-e-invoicing-in-vietnam/" target="_blank" rel="noopener">previous news</a>, the Vietnamese government will impose mandatory e-invoicing on 1 July 2022. Currently, the Ministry of Finance has issued <a href="http://www.gdt.gov.vn/wps/wcm/connect/6cff381f-30f1-46bc-a90e-445828b33853/Thong-tu_so-78_2021_TT-BTC.pdf?MOD=AJPERES&amp;CACHEID=ROOTWORKSPACE6cff381f-30f1-46bc-a90e-445828b33853" target="_blank" rel="noopener">Circular 78/2021/TT-BTC</a> guiding the implementation of electronic invoices and documents.
&nbsp;
Along with the Circular, the General Department of Taxation (GDT) has announced a roadmap for e-invoicing implementation in 2 following phases:
&nbsp;
&nbsp;
<ul>
<li>November 2021 to March 2022: 6 provinces and cities, incl. Hanoi, Ho Chi Minh City, Quang Ninh, Hai Phong, Phu Tho and Binh Dinh;</li>
<li>April 2022 to July 2022: countrywide deployment.</li>
</ul>
&nbsp;
To deploy e-invoicing, the Tax Departments of provinces would review and classify taxpayers into enterprises, economic organizations, business households, and individuals. Local e-invoice service providers will be reviewed and notified about the implementation by the tax administrations to ensure that the infrastructures and solutions fulfil the requirements.
&nbsp;
The Tax Department of Ho Chi Minh City would also announce a hotline to regularly monitor and handle problems during the preparation and initial implementation.
&nbsp;
The GDT encourages organizations and individuals to adopt e-invoicing as early as possible. As of 1 July 2022, electronic invoices will replace paper ones. All enterprises, business households and individuals, except for <a href="http://gdt.gov.vn/wps/portal/!ut/p/z1/tVNNT4NAEP0rXnokO3wsQ4_YNkARLVqg7IUgIEUFWtm09t-7xHjw0FJD3Mtkkjfvzb59SxjZENakh6pMedU26bvoY6YnM9-dhW4IYASrOTieh2HgzAHWSKJvgGXaGt4JgGYBONrtw70982VwVMKumYczx4Sh-ZAwwrKG7_iWxGXOb7K24UXDJ9Cliej7KlVZNwE1p1qRyShlSEHSpnQqGYhTiSoyPqeprmKBPdkuq3ISX4WOhtxhl-8W9Xq_GFYLYZrno66jrBgO_QFc8HdIJBZL4tkllxqJDlVxJEHTftTixZ_-6IE9qKCPVLhIb7nwv_TKSPrlUILFF6te93tmihz32f3kZDM-yLs6CGpDPUlvj8Zx_bIt68RbqLQv3Rft9jAD/dz/d5/L2dBISEvZ0FBIS9nQSEh/p0/IZ7_CQKCVKV008UPD0IMM7VUID00J4=CZ6_CQKCVKV008UPD0IMM7VUID00T7=MECTX!QCPgdtQCAcontentQCPsa_gdtQCPsa-icsQCPhddt-tintucQCP0e4c96df-cba3-4e9f-b856-0333cb7b8916==/p0/IZ7_CQKCVKV008UPD0IMM7VUID00J4=CZ6_CQKCVKV008UPD0IMM7VUID00T7=MECTX!QCPgdtQCAcontentQCPsa_gdtQCPsa-icsQCPhddt-tintucQCPe32f4247-a60d-4b1e-a938-7476f8502eab==/" target="_blank" rel="noopener">special cases</a>, will have to issue invoices electronically.

The Vietnamese Ministry of Finance has announced a roadmap for ensuring the implementation in two phases. Six provinces and cities will pilot the e-invoice implementation already from November 2021.

Vietnam confirms the introduction of the nationwide e-invoicing mandate in July 2022

On 19 October 2020, the Vietnamese government issued <a href="https://thuvienphapluat.vn/van-ban/Ke-toan-Kiem-toan/Nghi-dinh-123-2020-ND-CP-quy-dinh-hoa-don-chung-tu-445980.aspx" target="_blank" rel="noopener">Decree 123/2020/ND-CP</a>, deferring the 1 November 2020 deadline for mandatory e-invoicing and annulling certain articles of the previously announced Decree 119/2018. The new entry into force date for mandatory &ldquo;clearance type&rdquo; e-invoicing in Vietnam is 1 July 2022.
&nbsp;
Companies may continue to use any pre-printed, self-printed or electronic invoices that they purchased from the GDT (General Department of Taxation) before 19 October 2020. These invoices, with or without the GDT authentication code, will remain valid until 30 June 2022.
<h4>Exceptions to the new timeline</h4>
The following scenarios require businesses to implement e-invoicing before the official deadline of 1 July 2022:
<ul>
<li>Businesses established between 19 October 2020 and 30 June 2022, if they have received a notice from the GDT;</li>
<li>If an established business has run out of GDT allocated paper invoices, the GDT may decide to require the business to switch to e-invoicing. Businesses without technological capabilities to do so may be awarded pre-printed invoices under the condition that it sends invoice data and VAT return submission to the tax authority using Form No. 03 / DL-HDĐT, published in the appendix of Decree 123/2020.</li>
</ul>
<h4>Two e-invoicing processes remain the same</h4>
The two types of e-invoicing processes have not been altered in the new decree: one using e-invoices with GDT tax verification codes and one without. Various factors determine which process businesses must adhere to:1. E-invoices with GDT verification codesE-invoices with tax verification codes are eligible for tax declarations and will be mandatory for:
<ul>
<li>Self-employed individuals;</li>
<li>Businesses operating in agriculture, forestry, fishery and construction with an annual turnover greater than VND 3 billion (EUR 116 000), and with more than 10 employees;</li>
<li>Individuals and companies in the trade and service industry with an annual revenue of at least VND 10 billion (EUR 380 000);</li>
<li>&ldquo;High tax risk enterprises&rdquo; must submit e-invoices with verification codes for 12 consecutive months, after which the business will be reassessed. A high tax risk enterprise is defined as having equity of less than VND 15 billion and meeting a condition, for example:
<ul>
<li>The registered business address has changed twice or more within a 12-month period without the business making a prescribed declaration or failing to declare and pay tax at the new registration place according to regulations;</li>
<li>Enterprises which have been penalised for breaches in invoice rules in the last year</li>
</ul>
&nbsp;
</li>
</ul>
2. E-invoices without GDT verification codesIndustries not listed above can issue e-invoices without verification codes that are not eligible for tax declarations. The e-invoice data elements must still be sent to tax authorities, either directly or through an authorised e-invoicing service provider.
<h4>GDT XML e-invoice format and eSignature</h4>
There are also no changes in the required e-invoice format. Businesses should use the GDT XML format, consisting of two components: the component containing e-invoice business data and the component containing mandatory electronic signature data. For e-invoices with tax authority codes, there are additional components containing data related to tax agency data.
<h4>Advantages of e-invoice adoption</h4>
The government is generally encouraging businesses to switch to e-invoicing before the 1 July 2022 timeline. Several incentives have been created, including relieving businesses from reporting data separately on invoices issued under the new standards.

The Vietnamese government has issued a decree nullifying the November 2020 deadline for mandatory e-invoicing in Vietnam and pushing forward the date of entry into force. The decree also announces exceptions and further requirements for the future mandate.

New timelines on mandatory e-invoicing in Vietnam

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Regulatory updates - Vietnam

E-Invoicing/CTC Model:
Clearance
Mandatory Infrastructure:
The General Department of Taxation portal
Mandatory Format:
Local XML from 2022
Mandatory for Issuing:
Starting from July 2022
Mandatory for Receiving:
No explicit requirements
eSignature:
Mandatory
Archiving Period:
10 years
Archiving Abroad:
Allowed under conditions

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