Vietnam’s e-invoice system runs two forms in parallel: invoices with the tax authority’s code — each invoice is assigned a unique identifier before being sent to the buyer — and invoices without the code, which the enterprise issues itself and transmits data on to the tax authority as prescribed. Which form applies is not purely a technology preference: the law clearly delimits the groups required to use coded invoices, and the groups allowed non-coded invoices only when all conditions are met.
The two forms distinguished in one minute
An e-invoice with the tax authority’s code contains a unique identification code granted by the tax authority for each invoice (through the General Department of Taxation’s system or an authorised transmission organisation) before/during the seller sending it to the buyer; the buyer and any party can verify the invoice’s authenticity using this code on the tax authority’s portal. An e-invoice without the code does not pass through per-invoice coding; its validity rests on the seller’s digital signature and the seller’s duty to transmit invoice data to the tax authority under Article 22 of Decree 123/2020/ND-CP. The operational consequence: non-coded invoices allow fast issuance and deep ERP integration, but the enterprise bears the entire data-transmission discipline — missing or late transmission turns invoices into compliance risks.
Groups required to use coded invoices
Under tax administration law and Articles 12 and 13 of Decree 123/2020/ND-CP (as amended by Decree 70/2025/ND-CP), coded e-invoices are mandatory for: enterprises selling goods or services in sectors with large, frequent transaction volumes and mass consumer buyers — electricity, petroleum, post and telecommunications, clean water, finance and banking, insurance, healthcare, supermarkets, e-commerce, transport and similar prescribed sectors; enterprises in high tax-risk cases under the tax authority’s criteria; and e-invoices generated from cash registers in retail sales of goods and services directly to consumers (a separate statutory mechanism added by Decree 70/2025, with data connection to the tax authority). Newly established enterprises in specific prescribed cases (for example, those notified by the tax authority to apply coded invoices) must also use coded invoices. The key point: belonging to the mandatory group is determined by actual activities and the tax authority’s notice, not by the enterprise’s preference.
Conditions for using non-coded invoices
- Not belonging to the coded-mandatory groups above, and not being in a high tax-risk case per the tax authority’s assessment at registration;
- Holding a valid digital signature and meeting IT infrastructure conditions: invoicing software in the tax authority’s standard data format (XML), connectivity for data transmission via a solution provider/the General Department’s portal;
- Fully performing the duty to transmit e-invoice data to the tax authority under Article 22 of Decree 123/2020/ND-CP — Decree 70/2025/ND-CP tightened this duty so that sellers using non-coded invoices must transfer the full data of issued invoices to the tax authority, replacing the looser periodic-summary mechanism of the past;
- Registering the use of non-coded e-invoices in declaration form 01/DKTD-HDDT and being accepted by the tax authority (Article 15 of Decree 123/2020/ND-CP).
If during operations the enterprise falls into a high tax-risk group or into a case where the tax authority notifies a switch to coded invoices, the enterprise must convert as notified — continuing to issue non-coded invoices after the required switch point is using invoices contrary to the rules.
Frequently asked questions
Which enterprises may use e-invoices without the tax authority’s code?
Enterprises outside the coded-mandatory groups (large/frequent transaction sectors, cash-register retail), not in high tax-risk cases, holding a digital signature and standards-compliant IT infrastructure, with registration accepted, and transmitting full invoice data under Article 22 of Decree 123/2020/ND-CP (as amended by Decree 70/2025/ND-CP).
What are the conditions for using non-coded e-invoices?
Four conditions: (1) not in the coded-mandatory or high tax-risk groups; (2) a valid digital signature; (3) software/infrastructure meeting data format and transmission connectivity requirements; (4) registration on form 01/DKTD-HDDT accepted, with full and timely data transmission throughout use.
Must invoice data be transmitted to the tax authority when using non-coded invoices?
Yes — this is the core duty underpinning this form’s validity. Sellers using non-coded invoices must transmit e-invoice data to the tax authority under Article 22 of Decree 123/2020/ND-CP; Decree 70/2025/ND-CP tightened this towards full data transfer of each issued invoice. Missing or late transmission creates invoice-sanction risk and possible review for switching to the coded form.
How do non-coded invoices differ from coded invoices?
A coded invoice bears a unique identification code granted by the tax authority for each invoice before it is sent to the buyer, verifiable on the tax portal. A non-coded invoice skips the coding step; its validity rests on the seller’s digital signature and the seller’s transmission of invoice data to the tax authority as prescribed.
This article has been quality-reviewed by the FLAW AI Legal Council
