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E-Invoice Error Handling in Vietnam 2026

9 min readFLAT LAW FIRM
Màn hình máy tính hiển thị hóa đơn điện tử với con trỏ đang sửa một dòng bị đánh dấu đỏ, bên cạnh là kính lúp và con dấu, tông xanh navy và trắng.

E-Invoice Error Handling in Vietnam: 8-Step Checklist Under the New Rules

From 1/7/2026, e-invoice error handling follows Article 10 of Circular 91/2026/TT-BTC (replacing the mechanism in Article 19 of Decree 123/2020/ND-CP, now expired): classify the error first — wrong name/address only means notify without re-issuing; wrong tax code, amounts, rates, tax or goods means an adjustment or replacement invoice plus a written agreement; multiple same-month errors may be fixed with a single invoice; and the principle stands — never cancel an issued invoice.

Contents

1. Who this checklist is for

For accountants, tax officers and in-house counsel of enterprises using e-invoices in Vietnam — covering both tax-authority-coded and uncoded invoices.

How to mark: ☐ not done · ☑ done · ⚠ needs chief-accountant/counsel review. The golden rule: classify the error first, choose the fix second — misclassification breaks the whole procedure.

A note on the July 2026 shift: the mechanism moved from Article 19 of Decree 123/2020/ND-CP to Article 10 of Circular 91/2026/TT-BTC, which carries the same substance forward — the written agreement (or buyer notice for individuals) remains an explicit prerequisite for group-(b) cases, with forms 04/SS-HDDT and 01/BK-DCTT now in Appendix III. Once an adjustment or replacement form is chosen for the first fix, subsequent fixes must keep the same form. Finance teams should update internal SOPs and invoice-software checklists to block issuance until the agreement is on file, and note the new exemption for goods traded on e-commerce/digital platforms.

2. The detailed checklist

Item 1: Classify the error — "light" or "heavy" ☐

  • Do: Match the error to the two groups in Article 10(1) of Circular 91/2026/TT-BTC: Group (a) — light: only name, address, amount in words or other details wrong; tax code, amounts, rates, tax and goods correct. Group (b) — heavy: wrong tax code; wrong amounts, rates, tax; goods not as specified.
  • Why: The procedures are completely different. Group (a) needs no re-issue; group (b) needs an adjustment/replacement invoice plus a written agreement.
  • How: Print the erroneous invoice, mark each wrong field; classify before doing anything else.
  • Note: Name AND tax code wrong → group (b) (one group-(b) factor is enough).

Item 2: Group (a) — notify, don't re-issue ☐

  • Do: The seller notifies the buyer of the error and does not re-issue. Also notify the tax authority using Form 04/SS-HDDT (Appendix III of Circular 91/2026/TT-BTC).
  • Why: The simplest procedure — many businesses unaware of it still issue unnecessary adjustment invoices, messing up their books.
  • How: Notify the buyer (email/letter, keep proof); file Form 04/SS-HDDT electronically with the tax authority.
  • Note: Only when certain everything else (tax code, amounts, rates…) is right — if in doubt, re-check the whole invoice.

Item 3: Group (b) — choose adjustment or replacement ☐

  • Do: The seller may choose: (b.1) an adjustment e-invoice (recording increase/decrease), or (b.2) a brand-new replacement e-invoice.
  • Why: The law gives a choice — pick what fits reality instead of defaulting to one.
  • How: Adjust when only a few items are wrong (price, rate) and you want the link to the original; replace when many items are wrong or you want a clean slate. Use the exact mandatory wording (item 5).
  • Note: ⚠ Whichever you choose, item 4 (written agreement) comes FIRST — mandatory under Article 10 of Circular 91/2026/TT-BTC. Exception: e-invoices generated from cash registers and invoices for assets subject to ownership/use registration (real estate, vehicles…) MUST be handled by replacement invoice only — adjustment is not allowed, except for asset returns under point c.2, clause 5, Article 10.

Item 4: Sign the written agreement BEFORE adjusting/replacing ☐

  • Do: Before issuing the adjustment/replacement (group b): if the buyer is an enterprise, economic organization, other organization, household or individual business → both sides must sign a written agreement stating the error. If the buyer is an individual (non-business) → the seller notifies the buyer or posts notice on its website (if any).
  • Why: A mandatory duty under Article 10 of Circular 91/2026/TT-BTC (effective 1/7/2026) — without the agreement, the adjustment/replacement may be deemed procedurally defective on inspection.
  • How: Draft the agreement stating: erroneous invoice number/serial/date, the specific error, the fix (adjust or replace); both sides sign; the seller keeps it and produces it on request. A simple one-page template used consistently beats a lengthy bespoke agreement negotiated per case — speed matters because the buyer also needs the corrected invoice for its own VAT credit.
  • Note: Mind the chronology: the agreement must predate the adjustment/replacement invoice. No written agreement is required for goods traded on e-commerce/digital platforms, for e-invoices whose data is transmitted via the summary data table (point a.1, clause 3, Article 16 of Decree 254/2026/ND-CP), or for transaction-detail tables sent to the tax authority (point a.2, clause 3, Article 16).

Item 5: Issue the adjustment/replacement with exact wording ☐

  • Do: Adjustment invoices must bear: "Adjustment to invoice Form No. … serial … No. … dated …". Replacement invoices: "Replacement for invoice Form No. … serial … No. … dated …". The seller digitally signs the new invoice, then delivers to the buyer (uncoded) or via the tax authority for coding (coded invoices).
  • Why: Missing the mandatory line = formally invalid adjustment/replacement.
  • How: Check the invoicing software is updated to the new templates; verify the wording before signing.
  • Note: For authority-coded invoices, allow time for the tax authority to code the new invoice. Value rule on adjustment invoices: increases must be recorded as positive figures, decreases as negative figures — matching the actual adjustment.

Item 6: Batch multiple same-month errors (if eligible) ☐

  • Do: If in one month the same error (buyer, goods, unit price, tax rate) hit multiple invoices to the same buyer in that month: one adjustment/replacement invoice may cover them all, with schedule Form 01/BK-DCTT (Appendix III of Circular 91/2026/TT-BTC).
  • Why: Major effort-saver for systemic errors (e.g., a wrong tax rate across a month's invoices).
  • How: Filter the erroneous invoices meeting "same month + same buyer + same error"; complete Form 01/BK-DCTT. This batching rule is carried into Article 10 of Circular 91/2026/TT-BTC — update any old SOP that still says "one error, one invoice".
  • Note: The "same error" condition must be fully met — different error types across invoices can't be batched. Where invoice data was already sent to the tax authority via the e-invoice summary data table: adjust/replace directly on the next period's summary table — no Form 04/SS-HDDT is filed.

Item 7: Fix the tax filings for the bad and new invoices ☐

  • Do: Adjust filing obligations: file amended returns for the period containing the error if tax payable/creditable changes; book the adjustment/replacement invoice in the right period.
  • Why: Fixing the invoice but not the return = a tax error — still penalised on inspection.
  • How: Compare tax on the bad vs new invoice, compute the delta; file amended returns as needed; ⚠ filing period for adjustment/replacement invoices: cross-check Circular 80/2021/TT-BTC (see uncertain_points).
  • Note: The buyer must adjust its input-VAT credit accordingly — notify the buyer in time.

Item 8: Archive everything — and never "cancel" an issued invoice ☐

  • Do: Keep the full set: original erroneous invoice, agreement record, adjustment/replacement invoice, Form 04/SS-HDDT (group a), Form 01/BK-DCTT (if batched), amended returns. Never cancel an issued e-invoice on discovering an error — even authority-coded ones.
  • Why: "Cancel and re-issue" is a paper-invoice habit — with e-invoices the data is already with the tax authority, so cancelling breaches procedure.
  • How: Close a file per error case; archive electronically for the statutory retention period.
  • Note: Airline industry special case (ticket exchanges/refunds): the exchange/refund invoice counts as an adjustment invoice without the "increase/decrease…" line.

3. Common DIY mistakes

Mistake 1 — Cancelling the bad invoice and issuing a new one. Procedural violation — e-invoices may only be adjusted or replaced, never cancelled.

Mistake 2 — Forgetting the written agreement (mandatory under Article 10, Circular 91/2026/TT-BTC). Issuing the adjustment immediately without the buyer agreement — missing a mandatory step.

Mistake 3 — Missing the mandatory wording. Forgetting "Adjustment/Replacement to invoice Form No.… serial… No.… dated…" makes the new invoice formally invalid.

Mistake 4 — Agreement dated after the new invoice. Wrong chronology — the agreement must predate the adjustment/replacement.

Mistake 5 — Fixing the invoice but not the tax return. Invoice right, return still wrong — still fined on inspection. Coordinate both sides of the fix in a single checklist so the amended return is filed in the same cycle as the corrected invoice.

Mistake 6 — Adjusting instead of replacing a cash-register invoice or an asset-registration invoice. These two invoice types must be replaced, never adjusted, when erroneous.

4. After the checklist

With all 8 items ☑, the error is fixed under the new procedure with full supporting records. Next: review internal invoicing controls to prevent repeat errors (especially systemic ones like batch wrong tax rates).

Note: if the tax authority itself detects an erroneous invoice, it will notify the seller to review and handle it via adjustment/replacement — periodic self-review keeps you ahead of such notices.

Chief-accountant/counsel review is mandatory when: the error affects large tax amounts, involves VAT refunds, or the tax authority has asked for explanations.

📞 Need help with invoice errors? Contact FLAT LAW FIRM — hotline 0988424851.

5. FAQ

1. E-invoice with wrong buyer name/address? Notify the buyer, don't re-issue; notify the tax authority on Form 04/SS-HDDT (point a, Article 10(1), Circular 91/2026/TT-BTC).

2. Can a wrong-tax-code e-invoice be cancelled? No. Issue an adjustment or replacement invoice — issued invoices are never cancelled. Exception: cash-register e-invoices and invoices for assets subject to ownership/use registration must be replaced, not adjusted (except asset returns).

3. Is the written agreement mandatory? Yes, for business buyers — both sides must sign an agreement stating the error before adjustment/replacement. Exemptions: e-commerce/digital-platform trades; e-invoices transmitted via the summary data table; transaction-detail tables.

4. Adjustment vs replacement? Adjustment: increase/decrease vs original, line "Adjustment to invoice…". Replacement: brand-new invoice, line "Replacement for invoice…". Both digitally signed and delivered (or coded).

5. Many bad invoices in one month? One adjustment/replacement invoice may cover multiple same-month, same-buyer, same-error invoices, with Form 01/BK-DCTT schedule.

Language versions

References

  1. Circular 91/2026/TT-BTC guiding e-invoices and e-documents (Article 10: handling issued e-invoices with errors), effective 1/7/2026.
  2. Decree 254/2026/ND-CP on e-invoices and e-documents (effective 1/7/2026; replacing Decree 123/2020/ND-CP and Decree 70/2025/ND-CP).