2020 27 October

Vietnam: Implementation of E-invoicing Postponed Until July 2022


On 19 October 2020, the Government of Vietnam issued Decree 123/2020/ND-CP (“Decree 123”) that provides guidance on the implementation of the new invoicing and documentary procedures relating to e-invoicing in Vietnam.

Decree 123 will now take effect from 1 July 2022 postponing the deadline for the compulsory implementation of e-invoicing in Vietnam from 1 November 2020 to 1 July 2022. Taxpayers that meet the information technology infrastructure requirements under the Decree are encouraged to implement e-invoicing before this deadline.

Decree 123 includes provisions on e-invoicing along with others on compulsory content, issuance timeframes, and other e-documenting matters.

During the transition period up to 30 June 2022, the existing invoicing regulations will remain effective (including Decree 51/2010/ND-CP, Decree 04/2014/ND-CP and Decree 119/2018/ND-CP). However, a number of key provisions under these regulations will no longer apply, including:

  • The compulsory implementation of e-invoicing from 1 November 2020; and
  • The requirements for data transmission to the tax authorities and usage of e-invoices with verification codes under Clause 12, Article 5 of Decree 12/2015/ND-CP.

Some other notable points for taxpayers during the transition period include:

  • Taxpayers using self-printed invoices, pre-printed invoices and e-invoices either with or without a verification code before 19 October 2020 can continue using these until 30 June 2022.
  • A prescribed template (Form 03/DL-HDDT) must be submitted together with the VAT returns for taxpayers that have been instructed by the tax authorities to begin transitioning to e-invoicing, but nonetheless failed to meet the information technology infrastructure requirements and therefore are still using the traditional invoicing methods in Vietnam.
  • New enterprises that are established during the transition period and instructed by the tax authorities to implement e-invoicing, will need to follow these instructions. However in the event that these enterprises are unable to meet the information technology infrastructure requirements and cannot implement e-invoicing, the above Form 03/DL-HDDT must be submitted to the tax authorities.

This delay gives additional time for taxpayers to prepare for and implement e-invoicing in Vietnam. Taxpayers are recommended to make the due preparations to adopt and implement e-invoicing prior to the July 2022 deadline.

We trust that this is helpful. Please let us know if you have any questions or would like to discuss the above or any other tax issues in Vietnam.

The information provided here is for information purposes only, and is not intended to constitute legal advice. Legal advice should be obtained from qualified legal counsel for all specific situations.


Jack Sheehan

Partner & Head of the Regional Tax Practice 


Lan Hua

Tax Director, Vietnam


Phan Thi Lieu

Phan Thi Lieu

Senior Tax Manager, Vietnam


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