Invoice Transition Roadmap for FDI Retailers After 2026: From Standard E-Invoices to Cash-Register E-Invoices

The title of this topic carries a premise that needs correcting at the outset: for retailers selling directly to consumers, e-invoices generated from cash registers are not a “post-2026” roadmap — the duty began on 1 June 2025 under Decree 70/2025. What remains of the roadmap is scope expansion, data synchronisation and tighter administration under the new tax administration law.

Governing Instruments

Who is covered under amended Article 11 of Decree 123/2020

Clause 8, Article 1 of Decree 70/2025/ND-CP amends Article 11 of Decree 123/2020/ND-CP to provide that business households and individual businesses with annual revenue of VND 1 billion or more in the statutory cases, and enterprises selling goods or services directly to consumers — shopping centres, supermarkets, retail (excluding cars, motorcycles and other motor vehicles), food and beverage, restaurants, hotels, passenger transport and direct support services for road transport, arts, entertainment, cinema and other personal services — must use e-invoices generated from cash registers connected to transfer electronic data to the tax authority. Decree 70/2025 took effect on 1 June 2025, so FDI retail chains in these sectors are already in the compliance phase, not the preparation phase.

That text cross-refers to the Law on Tax Administration 38/2019/QH14; as of writing, the governing tax administration statute is Law 108/2025/QH15, effective 1 July 2026. The replacement of the parent law does not displace the cash-register invoice mechanism — references are read under the current law — but enterprises should refresh the citations in internal regulations and invoice-registration dossiers to avoid citing a repealed statute when dealing with the tax authority.

How cash-register invoices operate

Amended Article 11 sets three principles: the invoice must be identifiable as printed from a cash register connected to transfer electronic data to the tax authority; this invoice type does not mandatorily require a digital signature; and purchases paid with a cash-register invoice count as expenses supported by lawful invoices and documents for tax purposes. Invoice content covers seller details, buyer details where the buyer requests, goods and service names, unit price, quantity and payment amount — with credit-method taxpayers required to show the ex-VAT price, the VAT rate and the VAT amount separately.

The biggest operational difference from ordinary e-invoices is that transaction data flows to the tax authority through the cash-register connection instead of sitting only with the enterprise until an inspection. Point-of-sale revenue thereby becomes near-real-time data in the hands of the tax authority: gaps among POS revenue, declared revenue and bank flows are visible within the period, rather than surfacing in an audit two or three years later.

Application Analysis

For an FDI chain with many outlets, the challenge is not buying cash registers but data architecture: the existing POS must issue invoices in the correct format at the moment of sale, transmit data reliably even when connectivity drops, and reconcile automatically with head-office accounting. Enterprises should treat this as a three-layer data-compliance project — outlet, head office, tax authority — rather than outsourcing it wholesale to the POS vendor. Outlets in different provinces must also be handled consistently on invoice-use registration and the managing tax authority under the e-invoice registration rules.

On cost, investment in cash-register systems, software and integration serves the business activity: qualifying portions are depreciated as fixed assets, the remainder allocated or expensed under the accounting regime; deductibility for corporate income tax requires actual expenditure related to the business, lawful invoices and documents, and non-cash payment for expenses of VND 5 million or more under the current framework. Outlet staff training and monthly connection maintenance are likewise deductible operating costs when fully documented.

Recommended Actions

Audit every outlet against the covered-sector list in Article 11: any covered outlet still issuing ordinary invoices must convert immediately, with the late-compliance exposure recorded.
Standardise the POS — invoice — accounting architecture: a single revenue data source, fallback data-transfer mechanisms for connectivity loss, and automatic end-of-day reconciliation.
Complete registration for cash-register e-invoices with the managing tax authority of each outlet before go-live.
Build the investment and operating cost file (contracts, invoices, non-cash payment documents) supporting depreciation and deductible expenses.

Frequently Asked Questions

From when does the transition to cash-register-generated e-invoices apply to retail enterprises?

From 1 June 2025, when Decree 70/2025/ND-CP took effect and amended Article 11 of Decree 123/2020/ND-CP. Enterprises selling directly to consumers in the sectors listed in Article 11 have been covered since that date; the notion of a “post-2026 roadmap” now fits only the further subject groups and data-synchronisation depth to be extended under the framework of the Law on Tax Administration 108/2025/QH15.

Which sectors of FDI retailers are mandatorily covered by cash-register e-invoices?

Under Article 11 of Decree 123/2020/ND-CP as amended: shopping centres; supermarkets; retail (excluding cars, motorcycles and other motor vehicles); food and beverage; restaurants; hotels; passenger transport and direct support services for road transport; arts, entertainment and cinema services; and other personal services under the Vietnam Standard Industrial Classification. The test is selling directly to consumers, irrespective of the size of the FDI capital.

How is the cash-register data connection with the tax authority implemented?

The cash register (an integrated device and software till system) connects to transfer e-invoice data to the tax authority in the tax sector data standard; the enterprise registers this invoice type with the tax authority, configures the POS to transmit per transaction or in daily batches depending on infrastructure, and preserves the identifiability of invoices printed from a connected register. Cash-register invoices do not mandatorily require a digital signature, unlike ordinary e-invoices bearing the tax authority code.

How are cash-register invoice system investment costs accounted for and deducted for tax?

System procurement and deployment costs are accounted for under the accounting regime: portions qualifying as fixed assets are depreciated, while small-value equipment and software are allocated to expenses over their use period. For corporate income tax, the expense is deductible if actually incurred for the business, supported by lawful invoices and documents, and paid non-cash for amounts of VND 5 million or more. Input VAT on goods and services purchased for taxable activities is creditable under the general rules where document and payment conditions are met.