Decree No. 70/2025/NĐ-CP (“Decree 70”) to amend and supplement several articles of Decree No. 123/2020/NĐ-CP (“Decree 123”) on invoices and documents.

Dear Valued Clients, 

On March 20, 2025, the Government issued Decree No. 70/2025/NĐ-CP (“Decree 70”) to amend and supplement several articles of Decree No. 123/2020/NĐ-CP (“Decree 123”) on invoices and documents. Decree 70 introduces several notable changes regarding the timing of invoice issuance, the integration of tax, fee, and charge receipts into invoices for purchasers, along with reforms in administrative procedures related to the use of electronic invoices for enterprises, household businesses, and individual businesspersons. Decree 70 officially takes effect from June 1, 2025.

Accordingly, in this Legal Update, we are pleased to present our analysis clarifying the key contents of Decree 70 and the potential legal implications arising from its practical application.

1. Supplementation of biometric authentication process for taxpayers when registering or changing information related to the use of electronic invoices

In order to prevent the falsification of personal information to establish enterprises and use invoices illegally, Decree 70 supplements regulations on biometric authentication in the process of registering or changing information related to the use of electronic invoices. This measure aims to enhance security and ensure authenticity in electronic tax administration, consistent with the digital transformation direction.

Specifically, within 01 working day from the receipt of the registration dossier, the electronic portal of the General Department of Taxation shall automatically cross-check the taxpayer’s information (including biometric data) with the National Population Database or the Electronic Identification and Authentication System. If the information does not match, the system will issue a rejection notice including details of the mismatched fields for the taxpayer to adjust. If the information is correct, the system will send a confirmation request via email or phone number; the taxpayer must confirm within the day or no later than the following working day. If the taxpayer fails to confirm or the confirmation is unsuccessful, the application will be rejected.

In case the taxpayer falls into a risk category such as: inactive tax identification number, tax arrears, invoice violations, or has a history of violations, the tax authority will require an explanation or conduct an on-site verification at the registered address. If the explanation is valid or the verification confirms actual operations, the dossier will be approved; otherwise, the tax authority will reject the registration and provide a specific reason.[1]

2. Integration of electronic invoices with state budget collection receipts

Decree 70 allows for the integration of electronic invoices with receipts for the collection of taxes, fees, and charges – a significant step forward in administrative procedure reform. Previously, enterprises and organizations were required to issue both invoices and receipts separately, resulting in duplication and increased administrative costs. Now, under Article 1.3(b) of Decree 70, from June 1, 2025, in cases where an entity collects both payments for the sale of goods or provision of services and related taxes, fees, or charges from the same client, the service provider or collecting organization may issue a single electronic document to the client. This document simultaneously serves as an electronic invoice and a receipt for tax, fee, and charge collection – provided that it contains all the required information for both types of documents and complies with the electronic data format prescribed by the tax authority.

This unification of two types of documents helps reduce paperwork, save costs, and streamline tax declaration and finalization. It also facilitates inspection and reconciliation by the tax authorities, ensuring transparency and traceability of data. However, the implementation of such integration must follow standardized formats issued by the Ministry of Finance and meet technical infrastructure, data security, and system connectivity requirements with the tax authority.

3. Supplementation of prohibited acts in the field of invoices and documents

According to Article 1.4 of Decree 70 amending and supplementing Article 5.2 of Decree 123, a number of prohibited acts are specified for organizations and individuals engaged in the sale and supply of goods and services, as well as those having related rights and obligations in the field of invoices and documents. Specifically, the prohibited acts include:

(i) Committing fraudulent acts such as using illegal invoices, unlawfully using invoices; forging invoices or documents to carry out illegal acts;

(ii) Obstructing tax officers in the performance of their official duties, specifically: acts that harm the health or dignity of tax officers during the inspection or examination of invoices and documents;

(iii) Unauthorized access to, alteration of, or destruction of information systems related to invoices and documents;

(iv) Offering bribes or committing other acts related to invoices and documents for unlawful personal;

(v) Failing transmit electronic data to the tax authority as prescribed by this Decree.

Therefore, compared to previous regulations, Decree 70 has added two notable prohibited acts to the list: (i) forging invoices or documents with the intent to commit illegal acts, and (ii) failure to fulfill the obligation to transmit electronic invoice data to the tax authority in accordance with regulations.

The expansion of prohibited acts demonstrates the State’s determination to tighten control and ensure transparency and discipline in the field of invoices and documents. Therefore, enterprises and organizations should proactively review their invoice systems, internal procedures, and IT capabilities to strictly comply with the new regulations and avoid legal risks in the future.

4. Clarification of the timing for issuing electronic invoices in specific situations

One of the notable new provisions in Decree 70 is the supplementation and clarification of the timing for issuing electronic invoices in specific scenarios – situations [2] that have caused considerable confusion for enterprises and organizations due to the lack of detailed guidance in previous regulations. Clearly stipulating the timing of invoice issuance helps standardize interpretation and implementation, minimize errors, and enhance taxpayer compliance. Details are as follows:

4.1 For Exported Goods

According to Article 9.1 of Decree 70, the Government stipulates that for the export of goods (including processing for export), the time for issuing electronic commercial invoices, electronic value-added tax invoices, or electronic sales invoices is determined by the seller but must be no later than the next working day from the date the goods are cleared through customs in accordance with the law on customs.

4.2. For cases involving the sale of goods or provision of services in large quantities and on a frequent basis, where time is needed for data reconciliation between the seller (goods or service provider) and the client or partner

In cases where services are provided periodically such as direct support services for air transportation, aviation fuel supply to airlines, electricity supply (except as specified at Point h of this clause), support services for railway and water transport, television services, advertising services on television, e-commerce services, postal and delivery services (including agency, collection/payment on behalf), telecommunications services (including value-added telecom services), logistics services, IT services (except as stipulated in Article 9.4(b) of Decree 123), banking services (except lending), international money transfer, securities services, electronic lottery, road use toll collection between the investor and the toll service provider, and other cases as guided by the Minister of Finance — the time for invoice issuance is the point when data reconciliation is completed between the parties, but no later than the 7th day of the month following the month of service provision, or 7 days from the end of the agreed cycle. The agreed cycle is based on the agreement between the seller/service provider and the buyer.

4.3. For oil and gas exploration, extraction, and processing

For the sale of crude oil, condensate, and refined products from crude oil (including government-backed offtake activities), the time of invoice issuance is when the buyer and seller determine the official selling price, regardless of whether payment has been received.

For the sale of natural gas, associated gas, and coal gas transported through pipelines to the buyer: the invoice issuance time is when the buyer and seller determine the delivered gas volume of the month, but no later than the last day of the tax declaration and payment period for the month in which the tax liability arises, as prescribed by tax law (previously, it was within 7 days from the date the seller sent the gas delivery notice).

If the government’s guarantee and commitment agreement stipulates a different invoice issuance time, then the provisions of that agreement shall prevail.

4.4. For lending and foreign exchange transactions

Under the new regulation, the time of invoice issuance for lending activities is determined based on the interest collection period in the credit agreement between the credit institution and the borrower. If interest is not collected on time and the credit institution monitors it off-balance-sheet under the law on credit, then the invoice is issued when the interest is actually collected from the client.

If early interest payment is made under the credit agreement, the time of invoice issuance is when such early payment is received. For foreign exchange agency activities and services for receiving, disbursing, and paying foreign currencies provided by credit institutions’ economic organizations, the invoice issuance time is the moment of currency exchange or completion of the relevant foreign exchange service.

Previously, these cases were governed by general provisions on banking, securities, insurance services, e-wallet money transfer services, and electricity reconnection/disconnection services to individual consumers (whether or not engaged in business), where no invoice was requested. In those cases, service providers could issue consolidated invoices at the end of the day or month based on detailed transaction records from their data management systems.

Service providers must ensure the accuracy of transaction information and provide a detailed summary of the services rendered upon request from the competent authority. If clients request invoices for individual transactions, the provider must issue separate invoices accordingly.

4.5. For passenger transportation by taxi using fare calculation software

At the end of the trip, enterprises or cooperatives engaged in passenger transport by taxi that use fare calculation software must issue an electronic invoice to the client and simultaneously transmit the invoice data to the tax authority in accordance with regulations.

4.6. 4.6. For lottery ticket business

For traditional lottery and instant-result lottery activities (lottery tickets), where tickets are printed with full face value and sold to clients, after collecting unsold tickets — and no later than before the next draw — the lottery business enterprise shall issue one electronic value-added tax invoice with a tax authority code for each agency (organization or individual) corresponding to the tickets sold during the period and submit it to the tax authority for coding.

4.7. For casino and electronic gaming with prizes

For casino and prize-winning electronic game business activities, the time of issuing an electronic invoice must be no later than one day from the end of the revenue recognition date. At the same time, the enterprise must transmit data recording total revenues (collected from exchanging tokens at the counter, gaming tables, and machines) minus the refunded amount to players (due to winnings or unused funds), using Form 01/TH-DT in Appendix IA issued with this Decree, to the tax authority at the same time as the invoice data is transmitted. The revenue recognition date is defined as the time period from 00:00 to 23:59 of the same day.

5. Specific provisions on electronic invoices generated from cash registers

According to Article 11 of Decree 123 as amended by Article 1.8 of Decree 70 (effective from June 1, 2025), certain cases are required to use electronic invoices generated from cash registers connected to the tax authority’s data system [3], including:

(i) Business households and individual businesspersons as prescribed in Article 51.1 with annual revenue of VND 1 billion or more, Article 90.2, and Article 91.3 of the Law on Tax Administration 2019, and enterprises that sell goods or provide services directly to consumers (such as shopping malls, supermarkets, and retail outlets, excluding automobiles, motorcycles, motorbikes, and other motor vehicles);

(ii) Food and beverage services; restaurants; hotels;

(iii) Passenger transport services, direct support services for road transport, artistic, entertainment, and recreational services, and cinema activities;

(iv) Other personal service activities as classified under the Vietnam Standard Industrial Classification system.

Accordingly, under the current provisions of Decree 123, the use of electronic invoices generated from cash registers is not mandatory. However, from June 1, 2025, under Decree 70, certain entities — such as business households and individuals with annual revenue of VND 1 billion or more, retail businesses, restaurants, hotels, transport, and entertainment services — will be required to use cash-register-generated electronic invoices and connect the data to the tax authority.

6. New points to note when recording invoice contents [4]

No.	Invoice Content	New provisions under Decree 70
1	Name, address, and tax identification number of the buyer	– If the buyer is a budget-related unit, the unit code must be clearly stated. – If the buyer provides a tax identification number or personal identification number, the invoice must fully reflect this information.
2	Goods and services information	– For transportation services, the vehicle license plate and travel itinerary must be specified. – Promotional, gift, donation, or complimentary transactions must have a summary invoice with an attached detailed list; the enterprise is responsible for retaining records and providing them upon request by competent authorities.
3	Time of digital signature	– This is the time the digital signature is affixed, displayed in the format day/month/year. – If the time of digital signature differs from the time of invoice issuance, the data must be transmitted to the tax authority no later than the following working day
4	Cases where complete invoice information is not required	– Invoices for sales at supermarkets or shopping centers to non-business individuals are not required to include the buyer’s name, address, tax identification, or signature. – The same applies to invoices for petroleum sales and casino or prize-winning electronic game activities.

As usual, we hope you find this Legal Update helpful and look forward to working with you in the upcoming time.

Kind regards,

ENT Law LLC
The full version of this Legal Update can be found here.

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[1] Article 1.11, Decree 70.

[2] Article 1.6, Decree 70.

[3] An electronic invoice generated from a cash register that is connected to and transmits electronic data to the tax authority (hereinafter referred to as “electronic invoice generated from cash register”) is an invoice bearing a tax authority’s code or electronic data that enables the purchaser to retrieve and declare information. This type of invoice is issued by organizations or individuals selling goods or providing services through a point-of-sale system, and the data is transmitted to the tax authority in the format prescribed under Article 12 of this Decree.

[4] Article 1.3, Decree 70.