COUNTDOWN TO DECREE 254/2026/ND-CP: CORE CHANGES IN ELECTRONIC INVOICES, DIGITAL DOCUMENTS, AND ELECTRONIC LABOR CONTRACTS

Effective July 1, 2026, a new legal framework governing electronic invoices, digital documents, and electronic labor contracts will officially be deployed synchronously across Vietnam. In particular, Decree No. 254/2026/ND-CP (replacing Decree No. 123/2020/ND-CP and Decree No. 70/2025/ND-CP) alongside Circular No. 91/2026/TT-BTC is recognized as a major milestone aimed at standardizing financial data and optimizing tax administration.

Below is a summary of the core regulatory updates that enterprises, household businesses, and employees need to know to ensure proactive compliance.

1. CORE CHANGES IN ELECTRONIC INVOICES & DIGITAL DOCUMENTS

2. Mandatory E-Invoicing for Household Businesses with Annual Revenue Over VND 1 Billion

• Mandatory requirement: Household businesses and individual business owners with annual revenues exceeding VND 1 billion, or those disposing of assets subject to ownership/use registration, are strictly required to issue electronic invoices.

• Expanded registration scope: Introduces a voluntary registration mechanism for operators of e-commerce platforms and foreign digital platforms doing business in Vietnam.

2. Flexible Adjustments to Invoicing Timelines

• Security deposits: Service providers are not required to issue invoices at the time of receiving security deposits if such payments purely serve to guarantee contract performance under Civil Code provisions.

• Nighttime transactions: If a seller does not possess automated invoicing software, orders originating during nighttime working hours may postpone invoice issuance until no later than the following business day.

• Extended reconciliation cycle (within 7 days): High-volume service sectors (digital advertising, IT services, insurance, security services, B2B tech-based transport…) are permitted to reconcile data and issue invoices no later than 07 days after the month of transaction or the end of a conventional billing cycle.

• Consolidated healthcare service invoices: Medical facilities are permitted to issue a single summary e-invoice at the end of the day for healthcare services accompanied by payment receipts when patients do not request individual invoices.

3. Standardization of Content and Data Formats

• Mandatory XML format: Electronic invoices must strictly adopt XML syntax, comprising both business data elements and digital signature parameters.

• Display of buyer information: When selling to individual consumers who do not provide their name, address, or tax identification number, sellers must not leave these fields blank but must explicitly state “Sale to individual consumer” (“Bán cho người tiêu dùng”) on the invoice.

• Dependent business locations: Petroleum businesses or household businesses operating multiple stores/dependent locations must specify the official location code and address granted by competent authorities.

4. Monetary Rewards for Consumers Reporting Invoicing Violations

• For the first time, law introduces a reward mechanism for consumers who provide prompt and accurate information regarding sellers failing to issue or deliver electronic invoices.

• Reward amounts reach up to 10% of the administrative fine (capped at VND 10 million per case), processed via channels such as the eTax Mobile app, the National Public Service Portal, or direct submission to tax authorities.

5. Phasing Out Paper and Pre-Printed Invoices

• As of July 1, 2026, all unused paper invoices pre-printed by tax authorities, organizations, or household businesses will lose legal validity and must be destroyed.

• For paper receipts (self-printed or ordered), organizations may continue using them until December 31, 2026, and must destroy remaining stocks starting January 1, 2027, to fully transition to electronic receipts.

1. NATIONWIDE OPERATION OF THE ELECTRONIC LABOR CONTRACT PLATFORM

In parallel with tax administration, the labor sector records a major digital transformation starting July 1, 2026, under Decree No. 337/2025/ND-CP and Circular No. 08/2026/TT-BNV:

• Official launch of the shared platform: The national shared electronic labor contract platform officially becomes operational.

• Issuance of a unique Identification Code (ID): Every electronic labor contract, upon execution, must be submitted to the platform to receive a unique ID code. This ID code remains permanently unchanged, even when the contract is amended, supplemented, suspended, or terminated.

• Centralized digital data management: State authorities will use this ID code as a digital management key for electronic labor contracts to facilitate lookup, archiving, and cross-system integration.

III. ACTIONABLE RECOMMENDATIONS FOR ENTERPRISES AND HOUSEHOLD BUSINESSES

• Review invoice issuance workflows: Upgrade accounting and POS software to comply with XML data standards, handle nighttime transactions, and process “Sale to individual consumer” fields.

• Execute paper invoice disposal procedures: Inventory remaining pre-printed invoices to plan for proper destruction in accordance with regulatory guidance prior to the July 1, 2026 deadline.

• Prepare for E-Labor Contract Platform integration: Equip digital signatures, VNeID integration, and processes for synchronizing electronic labor contract data to the national platform.