Invoice Issuance Timing under Decree No. 70/2025/ND-CP: What Businesses Need to Know (2026)

The invoice issuance timing under Decree No. 70/2025/ND-CP is an important update that businesses should be aware of to ensure compliance with Vietnam‘s electronic invoicing regulations. Depending on the nature of the transaction, the type of goods or services provided, or the industry involved, the required invoice issuance timing may vary. Failure to issue invoices at the correct time can lead to challenges in tax declaration, document reconciliation, or even administrative penalties. Understanding these new regulations not only helps businesses remain compliant but also strengthens their accounting and tax management processes. This article summarizes the key provisions of Decree No. 70/2025/ND-CP, making them easier for businesses to understand and apply in practice.

Sale of Goods: When Should an Invoice Be Issued?

For the sale of goods, the invoice must be issued when ownership or the right to use the goods is transferred to the buyer. This rule applies to ordinary sales transactions, transfers of public assets, and the sale of national reserve goods, regardless of whether payment has already been received. In other words, businesses should determine the invoice issuance date based on when the goods are delivered to the buyer, rather than when payment is collected.

In addition to the existing rules for domestic sales, Decree No. 70/2025/ND-CP introduces specific guidance for exported goods, including goods processed for export. Businesses may choose when to issue an electronic commercial invoice, an electronic VAT invoice, or an electronic sales invoice. However, the invoice must be issued no later than the next working day after the goods have been cleared through customs in accordance with customs regulations. This new provision provides exporters with clearer guidance on meeting their electronic invoicing obligations while promoting more consistent application of the regulations.

Service Provision: Receiving Payment Does Not Always Mean an Invoice Must Be Issued

Unlike the sale of goods, the timing for issuing invoices for services is linked to the completion of the service rather than the delivery of goods. Under the new regulations, businesses must issue an invoice once the service has been completed, including services provided to foreign organizations or individuals. Whether the customer has made payment does not affect this requirement. In practice, many businesses receive partial or full payment before completing a service. In such cases, the invoice must generally be issued when the payment is received. However, not every advance payment requires an invoice. Deposits or advance payments made solely to secure the performance of a contract are exempt from immediate invoicing for certain specified service categories. Businesses should therefore distinguish between payments for services already rendered and deposits intended only as contractual security. Properly identifying the nature of each payment helps prevent invoices from being issued at the wrong time.

Industries Allowed to Issue Invoices After Data Reconciliation

Not every business activity allows revenue to be determined immediately when a transaction occurs. In industries with a high volume of transactions, continuous data generation, or the need to reconcile information among multiple parties, businesses are permitted to complete the reconciliation process before issuing invoices. Decree No. 70/2025/ND-CP continues to recognize this approach while expanding the list of industries eligible for this special treatment.

Although businesses may wait until the reconciliation process is completed, invoices must still be issued within the prescribed deadline. Specifically, invoices must be issued no later than the 7th day of the month following the month in which the services were provided, or within seven days after the end of the agreed reconciliation period, whichever applies. Businesses operating in these industries should establish a clear data reconciliation process to ensure timely invoice issuance and minimize errors in tax reporting.

How Is the Invoice Issuance Timing Determined for Lending Activities?

For lending activities, the invoice issuance date is not based on the loan disbursement date. Instead, it is determined according to the interest collection schedule agreed upon in the credit agreement between the credit institution and the borrower. If an interest payment becomes due but the loan has been classified as an off-balance-sheet receivable under credit regulations, the invoice is issued only when the interest is actually collected. If the borrower pays interest before the agreed due date, the invoice must be issued when the early interest payment is received. These new rules ensure that invoice issuance accurately reflects the recognition of revenue from lending activities while maintaining consistency between accounting practices and tax administration.

New Invoice Timing Rules for Foreign Exchange Services

Previously, there was no specific guidance on when invoices should be issued for foreign exchange agency services or foreign currency collection and payment services. Decree No. 70/2025/ND-CP addresses this gap by introducing a clear rule for these activities. Accordingly, invoices for foreign exchange agency transactions and foreign currency collection or payment services provided by economic organizations must be issued at the time the transaction takes place. Although this change does not significantly affect existing business operations, it provides a clearer legal basis and promotes more consistent implementation of the invoicing requirements.

Taxi Services Using Fare Calculation Software Must Issue Invoices at the End of Each Trip

For passenger transportation services provided by taxis that use fare calculation software as required by law, the invoice must be issued immediately after the trip is completed. This means that taxi companies and cooperatives can no longer choose when to issue invoices at their own discretion. Instead, the electronic invoice must be generated as soon as the transportation service has been completed. This requirement helps synchronize data between fare calculation software and the electronic invoicing system while making it easier for passengers to access and use their invoices when needed.

Healthcare Facilities: What Should They Know About Invoice Issuance?

For healthcare facilities that use medical management and hospital fee management software, electronic invoices may be issued in a consolidated manner at the end of each day. At the close of the business day, the healthcare provider will compile all medical examination, treatment, and related service information to generate electronic invoices. This approach reduces the number of invoices issued throughout the day while ensuring that all transaction data is properly recorded for management and compliance purposes. If a patient requests an electronic invoice, however, the healthcare facility must issue and provide the invoice accordingly. A notable addition under Decree No. 70/2025/ND-CP concerns medical expenses covered by health insurance. In such cases, the healthcare facility must issue an invoice to the Social Security Agency when the agency settles or reimburses the medical expenses incurred by health insurance cardholders.

Insurance Businesses: Invoice Timing Based on Revenue Recognition

For insurance businesses, the timing of invoice issuance is no longer determined by when insurance premiums are collected. Instead, invoices must be issued when insurance revenue is recognized in accordance with the laws governing insurance business activities. This approach aligns invoice issuance with the industry’s revenue recognition principles, ensuring greater consistency between accounting records and tax reporting obligations.

Lottery Businesses: Invoices Are Issued After the Drawing Is Completed

Lottery operations have unique business characteristics, so the timing for issuing invoices differs from that of many other industries. Under the new regulations, businesses operating traditional lotteries and instant-win lotteries must issue invoices only after unsold tickets have been collected and the lottery drawing has officially concluded. This provision provides lottery operators with a clear legal basis for determining when revenue is recognized and when invoices should be issued.

Casinos and Prize-Winning Electronic Games: Invoice Deadline

For casino businesses and prize-winning electronic gaming activities, electronic invoices must be issued no later than one day after the end of the revenue determination day. The revenue determination day is defined as the period from 12:00 a.m. to 11:59 p.m. on the same calendar day. By establishing a specific deadline, the regulation enables businesses to manage revenue more effectively while ensuring that invoices are issued within the required timeframe.

Summary of Invoice Issuance Timing by Business Activity

The table below provides a quick reference to the invoice issuance timing for different business activities under Decree No. 70/2025/ND-CP.

Conclusion

The invoice issuance timing under Decree No. 70/2025/ND-CP has been clarified and expanded across a wide range of business activities, giving enterprises a clearer legal basis for determining when invoices must be issued in different situations. Keeping up to date with these new requirements not only helps businesses reduce tax compliance risks but also supports more transparent and efficient accounting and financial management. This is particularly important for foreign-invested enterprises and businesses planning to establish a company in Vietnam, as complying with invoicing regulations from the outset can help avoid unnecessary compliance issues later on.

If your business needs guidance on applying the new regulations or requires professional support with accounting, taxation, or electronic invoicing, Green NRJ is ready to assist. Our team provides practical solutions tailored to your business needs, helping you maintain compliance while focusing on your core operations.