Analysis of Decree 70/2025/ND-CP amending and supplementing several articles of Decree 123/2020/ND-CP on invoices and documents

Decree 70/2025/ND-CP is issued to amend and supplement several articles of Decree 123/2020/ND-CP, which regulates invoices and documents. This new decree takes effect from June 1, 2025. Notable changes include new regulations on electronic invoices generated from cash registers, responsibilities of electronic invoice service providers, invoice issuance time for specific cases, electronic invoice content, value-added invoices combined with tax refund declarations, electronic documents, and other related issues. These amendments are likely to impact many entities, including businesses, organizations, and individuals.

Decree 70/2025/ND-CP focuses on perfecting regulations on electronic invoices and documents, especially electronic invoices generated from cash registers and the responsibilities of service providers. Compared to Decree 123/2020/ND-CP, this new decree provides more detailed regulations on the invoice issuance time in various specific cases, supplements regulations on the content of electronic invoices and documents, and enhances the responsibilities of relevant parties. A notable new point is the addition of the provision "e) Overseas suppliers without permanent establishments in Vietnam engaged in e-commerce, digital platform-based business, and other services voluntarily register to use electronic invoices as prescribed in this Decree" (Clause 1 Article 1). However, detailed implementation guidelines are still pending issuance by the Ministry of Finance.

The changes in Decree 70/2025/ND-CP may bring about several potential impacts on the regulated entities:

• Businesses will need to update their accounting systems and business processes to comply with the new regulations on electronic invoices, especially for electronic invoices generated from cash registers and the invoice issuance time. The use of electronic invoices can help reduce the printing, storage, and management costs of paper invoices while enhancing transparency and efficiency in transactions. However, businesses may also face initial costs to upgrade or convert to a suitable electronic invoice system.

• Electronic invoice service providers will have to meet the new requirements on obligations and responsibilities, ensuring the provision of quality and secure services. Tax withholding and collection organizations will also need to adjust their electronic document usage procedures according to the new regulations.

• Buyers of goods and services will benefit from the use of electronic invoices, making it easier for them to store and look up information on purchase transactions. Having electronic invoices can also facilitate better protection of consumer rights.

Some details amended and supplemented by Decree 70/2025 are as follows:

Electronic invoices generated from cash registers:

Decree 70/2025/ND-CP introduces new regulations related to electronic invoices generated from cash registers. Accordingly, this type of invoice must ensure recognizability and not require a digital signature (Clause 8 Article 1). The cost of purchasing goods and services using electronic invoices from cash registers will be considered legitimate when determining tax obligations. Mandatory content of electronic invoices from cash registers includes the seller's name, address, and tax identification number; the buyer's name, address, and tax identification number/personal identification/phone number (if requested); and the tax authority's code or electronic data for the buyer to look up.

The addition of this regulation is understood to facilitate retail transactions directly to consumers and enhance tax management of these activities. This guidance specifically applies to business households and individuals with annual revenue of 1 billion VND or more and businesses engaged in direct sales of goods and services to consumers.

Obligations and responsibilities of electronic invoice service providers:

Decree 70/2025/ND-CP supplements regulations on the obligations and responsibilities of electronic invoice service providers, divided into two groups:

• For organizations providing electronic invoice solutions to sellers and buyers: These organizations are responsible for providing solutions for generating, transmitting, receiving, storing, and processing electronic invoice and document data; they must also ensure timely and complete data transmission and storage of results. Transparency in operational methods and the security of electronic invoice information are also important requirements. Clearly defining these responsibilities aims to ensure service quality and information security in the use of electronic invoices.

• Organizations that connect to receive, transmit, and store electronic invoice data with tax authorities are responsible for issuing tax authority codes if authorized and providing free coded electronic invoices to entrusted entities. They must also establish a secure and continuous connection channel with the General Department of Taxation and publicize service information. This aims to ensure a seamless and secure connection between businesses and tax authorities in electronic invoice management.

Invoice Issuance Time:

Decree 70/2025/ND-CP amends and supplements regulations on the invoice issuance time for the sale of goods and provision of services. According to the new regulations, the invoice issuance time is the time of transfer of ownership or usage rights of goods to the buyer or the time of completion of service provision, regardless of whether payment has been received.

For specific industries such as aviation, electricity, water, and telecommunications, the invoice issuance time can be the data reconciliation time but must not exceed the 7th day of the following month or 7 days from the end of the agreed period.

For export goods, the electronic invoice issuance time is determined by the seller but must not exceed the next working day from the date of customs clearance.

In cases where the service provider collects money in advance or during service provision, the invoice issuance time is the time of money collection, except for deposits or advances for specific services such as accounting, auditing, financial consulting, tax, valuation, and technical survey and design.

The decree also supplements regulations on the invoice issuance time for insurance, lottery, casino, and prize-winning electronic game businesses.

Electronic invoice content:

Decree 70/2025/ND-CP also amends and supplements regulations on the content of electronic invoices. Specifically, information such as the buyer's name, address, tax identification number; the name, unit of measurement, quantity, and unit price of goods and services; and the digital signature time on the electronic invoice are specified in more detail. The decree also adds regulations on value-added invoices combined with tax refund declarations.

Value-added invoices combined with tax refund declarations:

The addition of regulations on this type of invoice demonstrates the management authority's effort to simplify administrative procedures, facilitating taxpayers in both conducting goods and service purchase transactions and carrying out value-added tax refund procedures more conveniently. The Ministry of Finance is expected to issue detailed guidance on this type of invoice.

Responsibilities of sellers of goods and services using uncoded electronic invoices:

Decree 70/2025/ND-CP adjusts the responsibilities of sellers of goods and services when using uncoded electronic invoices, especially regarding the method and time of transmitting electronic invoice data to tax authorities. This aims to ensure that even when using uncoded electronic invoices, transaction information is fully and timely reported to tax authorities for management purposes.

Regulations on electronic documents:

Decree 70/2025/ND-CP amends and supplements regulations on electronic documents, including issuance time, content, form symbols, usage registration, error handling, and responsibilities of tax-withholding organizations and tax, fee, and charge collection organizations when using electronic documents. The issuance time for documents is specified as the time of personal income tax withholding, the time of tax, fee, and charge collection, and the time when organizations must issue documents and receipts to income earners subject to tax withholding and payers of taxes, fees, and charges. The content of electronic documents is also adjusted, including document names, form symbols, symbols, serial numbers, and the names, addresses, and tax identification numbers of income-paying organizations and individuals. Receipt numbers are specified in detail regarding how to record and start. These regulations aim to standardize the use of electronic documents, ensuring legal validity and convenience in management.

Management and use of tax, fee, and charge collection receipts:

The decree also includes amendments and supplements related to the management and use of tax, fee, and charge collection receipts. This may include new regulations on receipt forms, issuance methods, and the use and storage of electronic receipts, aiming to enhance transparency and efficiency in state budget revenue collection.

Disclaimer

This Newsletter contains only brief notes and includes legislation in force as of March 2025. The information herein is general and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one is entitled to rely on this information, and no one should act on such information without appropriate professional advice obtained after a thorough examination of the particular situation.