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June 13, 2026Electronic Invoice Registration in Vietnam 2026: Biometric Verification and New Tax Authority Requirements
From 2026 onward, Electronic Invoice Registration in Vietnam has been subject to significantly tighter tax authority supervision compared to previous years. In addition to risk-based taxpayer assessment criteria under Circular 32/2025/TT-BTC, many enterprises are now also required to complete biometric verification of their legal representatives before being approved to use electronic invoices.
In practice, a considerable number of newly established companies or businesses that have changed their tax registration information have experienced situations where their applications were rejected, required additional explanations, or were asked to directly work with tax authorities before being granted permission for Electronic Invoice Registration in Vietnam.
When Can Tax Authorities Refuse or Temporarily Suspend the Use of Electronic Invoices?
According to Clause 3, Article 26 of the Law on Tax Administration 2025, electronic invoice data is managed centrally and uniformly to serve tax administration purposes. Based on risk analysis results, tax authorities are entitled to apply appropriate management measures, including suspending or temporarily stopping the use of electronic invoices for cases assessed as high tax and invoice risk.
This regulation shows that the registration and use of electronic invoices is no longer a mere administrative procedure, but has become an integrated part of the national tax risk management system.
Indicators That Lead to a High-Risk Taxpayer Assessment
Under Circular 32/2025/TT-BTC, indicators identifying high-risk taxpayers are currently grouped into three main categories:
| Risk indicator group | Content |
|---|---|
| Indicators related to legal representatives or owners | Enterprises may be subject to inspection if their legal representatives or owners have been involved in companies associated with invoice trading, tax fraud, business abandonment, or appear in warning lists issued under legal regulations. |
| Indicators related to business location | Companies registering unclear addresses, locations inconsistent with actual business purposes, or where tax authorities cannot verify real operations may be required to provide explanations or additional verification before being approved to use electronic invoices. |
| Indicators related to tax and invoice behavior | Cases showing signs of tax or invoice violations, irregular documentation, or previously flagged by tax authorities as risky may be subject to stricter management measures. |
New From 2026: Mandatory Biometric Verification for Electronic Invoice Registration
One of the most important changes is the introduction of biometric authentication for legal representatives when registering or updating electronic invoice usage information.
Pursuant to Decree 70/2025/ND-CP amending Decree 123/2020/ND-CP on invoices and documents, the General Department of Taxation has coordinated with the Department of Administrative Management of Social Order (C06) to implement biometric verification via the eTax Mobile application.
According to Official Letter 3078/CT-NVT, this verification applies to enterprises, organizations, household businesses, and individual business owners when registering or changing electronic invoice usage information related to the legal representative.
Conditions for Biometric Verification
The legal representative must have a Level 2 electronic identification account (VNeID Level 2), have installed the eTax Mobile application, and ensure that identification data matches the tax authority’s registration database.
Biometric Verification Process on eTax Mobile
After the enterprise submits Form 01/ĐKTĐ-HĐĐT to the system, the electronic invoice portal automatically sends a biometric verification request to the legal representative.
The legal representative performs facial recognition authentication via the eTax Mobile application. Only after successful verification will the system continue processing the electronic invoice registration dossier.
Applications May Be Cancelled After 24 Hours If Not Verified
This is a practical issue many businesses are currently facing. Submitting the declaration does not mean the application has been approved. If the legal representative fails to complete biometric authentication or fails verification within 24 hours from the time the system sends the request, the application may be cancelled and the enterprise must restart the procedure from the beginning.
What Should Foreign-Managed Companies Pay Attention To?
Although Official Letter 3078/CT-NVT stipulates that foreign legal representatives who do not meet Level 2 electronic identification requirements are an exception to biometric verification, in practice many tax authorities still conduct additional verification steps before approving initial electronic invoice registration. This is particularly important for FDI enterprises.
In addition, for readers who are planning to establish a foreign-invested company in Vietnam, it is worth noting that the company incorporation process is closely linked to tax registration and electronic invoice eligibility. A foreign company is typically required to prepare investment registration documents, enterprise registration certificates, lease agreements for office premises, and proof of actual operational capacity right from the incorporation stage. These documents will later be used as supporting evidence during tax onboarding and invoice registration procedures, so structuring them properly from the beginning can significantly reduce administrative friction.
According to practical dossiers received by tax authorities, enterprises with foreign legal representatives may be required to provide additional documents such as enterprise registration certificates, investment registration certificates, passports of the legal representative, office lease agreements, office photos, labor contracts, social insurance participation records, contracts with partners, output contracts, and other documents proving actual business operations.
In some cases, tax authorities may also conduct on-site verification of business premises before considering approval of electronic invoice registration.
What Should Businesses Prepare to Avoid Rejection of Electronic Invoice Registration?
For newly established companies, especially FDI enterprises with foreign legal representatives, early-stage preparation of documentation plays a critical role.
Businesses should proactively review the validity of their registered business address, office lease contracts, labor documentation, legal representative information, VNeID account status, eTax Mobile application setup, and all documents proving actual business operations before submitting electronic invoice registration.
Proper preparation and proactive handling of tax authority requests from the beginning can significantly reduce the risk of being rejected for electronic invoice usage, thereby avoiding disruptions in issuing invoices, signing contracts, and operating business activities after incorporation.
Green NRJ Supports Electronic Invoice Registration and Tax Authority Procedures
In cases where businesses encounter difficulties in registering for electronic invoices, are requested to provide explanations, or have foreign legal representatives, Green NRJ can support reviewing legal documentation, preparing required materials in accordance with tax authority requirements, and accompanying enterprises throughout the process of working with regulators to minimize potential risks.
