What are the regulations on issuance of unauthenticated e-invoice in 2025?

What is an authenticated e-invoice in Vietnam?

Based on the provisions of point b, clause 2, Article 3 of Decree 123/2020/ND-CP, an unauthenticated e-invoice is defined as an e-invoice issued by an organization selling goods or providing services, sent to the buyer without a tax authority's code.

What are the regulations on issuance of unauthenticated e-invoice in 2025?

Based on Article 18 of Decree 123/2020/ND-CP, the latest regulations on issuing unauthenticated e-invoice in 2025 are as follows:

- Enterprises and economic organizations are allowed to use unauthenticated e-invoice when selling goods or providing services after receiving an acceptance notification from the tax authority.

- Enterprises and economic organizations use software to issue e-invoices when selling goods or providing services, digitally signing the e-invoice and sending it to the buyer by e-means, as agreed upon between the seller and the buyer, ensuring compliance with the legal regulations on e-transactions.

What are regulations on issuing unauthenticated e-invoice in Vietnam in 2025? (Image from the Internet)

Which enterprises or economic organizations are allowed to use unauthenticated e-invoice in Vietnam?

Based on the provisions of Article 91 of the Law on Tax Administration 2019 regarding the application of e-invoices when selling goods and providing services:

Application of e-invoices when selling goods and providing services

1. Enterprises and economic organizations use authenticated e-invoice when selling goods or providing services, regardless of the value of each sale or service, except as provided in clauses 2 and 4 of this Article.

2. Enterprises operating in fields such as electricity, petroleum, telecommunications, clean water, financial credit, insurance, healthcare, e-commerce, supermarket business, commerce, air transportation, road, rail, sea, and waterway transport; and enterprises, economic organizations that have or will conduct transactions with the tax authority by e-means, building IT infrastructure, have accounting software systems, e-invoice software that meets the requirements for issuing, searching, and storing e-invoices according to regulations, and ensuring the transmission of e-invoice data to the buyer and to the tax authority, are allowed to use e-invoices without a code from the tax authority when selling goods or providing services, regardless of the value of each transaction, except in cases of high tax risks as regulated by the Minister of Finance and cases of registering to use authenticated e-invoice.

3. Business households and individuals falling under the provisions of clause 5, Article 51 of this Law and cases where revenue can be determined when selling goods and services use authenticated e-invoice when selling goods or providing services.

4. Business households and individuals that do not meet the conditions for using authenticated e-invoice as per clauses 1 and 3 of this Article, but need invoices for customers, or in cases where enterprises, economic organizations, or other organizations are permitted by the tax authority to issue e-invoices for customers, the tax authority will issue e-invoices with a code for each instance. They must declare and pay taxes before the tax authority issues the e-invoices for each instance.

Enterprises and economic organizations allowed to use unauthenticated e-invoice include:

- Enterprises operating in fields such as electricity, petroleum, telecommunications, clean water, financial credit, insurance, healthcare, e-commerce, supermarket business, commerce, air transportation, road, rail, sea, and waterway transport;

- Enterprises, economic organizations that have or will conduct transactions with the tax authority by e-means, build IT infrastructure, have accounting software systems, e-invoice software that meets the requirements for issuing, searching, storing e-invoices according to regulations, and ensure the transmission of e-invoice data to the buyer and the tax authority.

Note: The aforementioned enterprises and economic organizations must use invoices with a tax authority's code if they are subject to high tax risks as determined by the Minister of Finance and in cases where they register to use authenticated e-invoice.