From 1 June 2025, the familiar operation of “cancelling a wrong e-invoice” has officially disappeared from invoice law: Decree 70/2025/ND-CP amended Article 19 of Decree 123/2020/ND-CP so that every erroneously issued e-invoice may only be handled by adjustment or replacement. An FDI enterprise still running the old internal workflow — cancel whenever there is an error — is operating contrary to current rules and needs to rewrite that workflow now.
The root change: invoice cancellation no longer exists
Under the former rules, where a coded e-invoice had been issued but not yet sent to the buyer and an error was found, the seller cancelled that invoice and issued a new one. Clause 13, Article 1 of Decree 70/2025/ND-CP removed this mechanism: an erroneously issued e-invoice — whether or not already sent to the buyer — is handled in one of two forms: issuing an adjustment invoice or issuing a replacement invoice, with tighter procedural steps on agreement with the buyer and notification to the tax authority. The purpose of the change is to preserve the trail of the invoice’s entire life cycle in the tax authority’s data system, instead of letting invoices “vanish” from the system through cancellation.
Error classification and the corresponding handling
- Wrong buyer name or address but correct buyer tax code: the seller notifies the buyer of the error and notifies the tax authority of the erroneous invoice on form 04/SS-HDDT; no adjustment/replacement invoice is issued for this case.
- Wrong buyer tax code, amounts, tax rate, tax amount, or goods not matching specifications/quality: the seller chooses to issue either an adjustment e-invoice or a replacement e-invoice for the erroneous one. A single adjustment/replacement invoice may cover multiple erroneous invoices issued in the same month to the same buyer.
- An invoice already adjusted/replaced where further errors are found: subsequent handling must follow the same form chosen the first time (adjustment continues as adjustment, replacement as replacement) — switching forms mid-way is not allowed.
- Invoices issued with wrong template symbol, invoice symbol or number (where the e-invoice by rule has no such symbols): only an adjustment invoice is used.
Procedure: a written agreement is a precondition
The most important tightening in Decree 70/2025: before adjusting or replacing, where the buyer is an enterprise, economic organisation, other organisation, business household or business individual, the seller and buyer must have a written agreement clearly stating the erroneous content; where the buyer is a non-business individual, the seller notifies the buyer or posts the notice on the seller’s website (if any). On an adjustment invoice the substance must be shown correctly: upward adjustments recorded as positive amounts, downward adjustments as negative amounts per the actual adjustment, with lines/content linking to the original invoice being adjusted. Where the tax authority detects that an issued invoice (coded or non-coded) is erroneous, it notifies the seller to check, review and carry out the adjustment/replacement as prescribed — the taxpayer bears responsibility for that review. After handling, both sides declare tax for the period in which the error is detected/handled under tax administration law (the seller declares on the return of the period when the adjustment/replacement invoice is issued; the buyer adjusts the corresponding input tax).
How should the internal workflow be redesigned?
Three practical changes for an FDI accounting department: (1) remove the “cancel” button from the workflow and from habit — configure the invoicing system to lock the cancellation function if the provider leaves it open; (2) prepare a ready bilingual template of the adjustment/replacement agreement and embed it in the error-handling workflow as a mandatory step before issuing an adjustment invoice to a business customer; (3) maintain an erroneous-invoice tracking log: original invoice number, error type, the form chosen the first time, adjustment/replacement invoice number, declaration periods of both sides — because the rule “subsequent handling follows the first-chosen form” is only manageable with a log. Enterprises with high invoice volumes should also retrain sales/customer-care staff: the promise to customers of “cancelling and re-issuing the invoice” no longer exists in current law.
Frequently asked questions
Are erroneous e-invoices handled by adjustment or by replacement?
It depends on the error type: for a wrong tax code, amount, tax rate, tax amount or goods specifications, the seller chooses either adjustment or replacement (Article 19 of Decree 123/2020/ND-CP as amended by clause 13, Article 1 of Decree 70/2025/ND-CP); for a wrong buyer name/address with the correct tax code, only notification is made (to the buyer and to the tax authority on form 04/SS-HDDT), with no adjustment/replacement invoice.
Can an erroneously issued e-invoice still be cancelled?
No. From 1 June 2025, Decree 70/2025/ND-CP abolished the cancellation of erroneously issued e-invoices — including invoices not yet sent to the buyer. Every error is handled by an adjustment or replacement invoice under the amended Article 19 of Decree 123/2020/ND-CP.
Does invoice adjustment require a written agreement with the buyer?
Yes, where the buyer is an enterprise, economic organisation, other organisation, business household or business individual: a written agreement between seller and buyer clearly stating the erroneous content is required before adjusting/replacing. Where the buyer is a non-business individual, the seller only needs to notify the buyer or post a notice on its website (if any).
In which period is an adjustment invoice declared for tax?
The seller declares the adjustment/replacement invoice in the tax period when it is issued (the period the error is detected and handled), and the buyer adjusts the corresponding input VAT in the same period — under tax administration law and the amended Article 19 of Decree 123/2020/ND-CP.
This article has been quality-reviewed by the FLAW AI Legal Council
