When to issue an invoice: 23 types of goods and services (from 1 July 2026)
Issuing an invoice at the wrong moment is a commonly penalised error. A quick reference for when to issue, by type of goods or service, under Article 9 of Nghị định 254/2026/NĐ-CP.
Published 12/09/2026
This article is an English summary prepared for convenience only. Vietnamese tax and accounting rules are issued in Vietnamese, and many technical terms have no exact English equivalent — a translation may therefore be imprecise or read differently from the original, and acting on it alone can lead to a genuine misunderstanding of the rule. Names and reference numbers of legal instruments are kept in Vietnamese so that you can check the source text. Where this translation and the Vietnamese version differ, the Vietnamese version governs. Please read the Vietnamese article, or contact TRÍ TÍN, before relying on anything here.
Issuing an invoice at the wrong moment is among the most commonly penalised errors found on inspection — and the question TRÍ TÍN is asked most often by clients' accounting staff. It is rarely deliberate: each type of goods or service has its own trigger point.
The table below summarises when an invoice must be issued under Article 9 of Nghị định 254/2026/NĐ-CP, applicable from 1 July 2026.
The general rule worth remembering
For most transactions the timing does NOT depend on whether payment has been received. This is the most common misunderstanding behind late invoicing.
Invoice timing reference
| Type of goods or service | When to issue | Notes |
|---|---|---|
| 1. Goods (including sale or transfer of public assets and national reserve goods) | On transfer of ownership or right of use | Regardless of whether payment has been received |
| 2. Exported goods (including processing for export) | No later than the next working day after customs clearance | Determined by the seller |
| 3. Services (including foreign organisations and individuals) | On completion of the service. Where payment is taken before or during provision, issue at the time of payment (deposits excepted) | Regardless of whether payment has been received |
| 4. Delivery in instalments, or handover by item or stage | Issue on each delivery or handover | — |
| 5. High-volume, recurring sales or services requiring reconciliation | On completion of data reconciliation between the parties | No later than the 7th of the following month, or within 7 days of the end of the agreed cycle |
| 6. Telecommunications and IT services | On completion of data reconciliation between the parties | No later than 2 months from the month the charge arose |
| 7. Construction and installation | On acceptance and handover of completed volume | Regardless of whether payment has been received |
| 8. Real estate, infrastructure construction, housing for sale or transfer | Rights not yet transferred: date of payment or as agreed in the contract. Rights transferred: on transfer | — |
| 9. Purchased air transport services issued via a website | No later than 5 days from provision of the service issued on the system | — |
| 10. Exploration, extraction and processing of crude oil | When buyer and seller establish the official selling price | Regardless of whether payment has been received |
| 11. Sale of natural gas, associated gas, coal gas | When buyer and seller determine the month's delivered volume | No later than the last day of the filing and payment deadline for that month, or per a government guarantee or undertaking |
| 12. Electricity sales | By period (month/quarter) after reconciling consumption data | Or per a government guarantee |
| 13. Retail petrol and oil sales | At the end of each sale | — |
| 14. Air transport services and insurance sold through agents | On completion of data reconciliation between the parties | No later than the 10th of the month following the month it arose |
| 15. Lending | Per the interest collection schedule in the credit contract, or when interest is received | — |
| 16. Taxi passenger transport | At the end of the trip | — |
| 17. Medical examination and treatment facilities | Where the customer does not request one: aggregate and issue at end of day. Where requested: issue an e-invoice immediately | — |
| 18. Road-use toll collection | The day the vehicle passes the toll station; by period, no later than the last day of the month the service arose | — |
| 19. Insurance business | When insurance revenue is recognised | — |
| 20. Pre-printed lottery tickets | After unsold tickets have been recovered | No later than before the next draw |
| 21. Casinos and prize-winning electronic games | No later than 1 day from the end of the revenue determination day | The revenue day runs from 06:00:00 to 05:59:59 the next morning |
| 22. Services supplied to individual consumers | Prepare a consolidated e-invoice schedule monthly/quarterly | No later than the VAT return deadline |
| 23. No automated invoicing software, transactions arising overnight | No later than the next working day | — |
Recommendation
If your business operates in a sector requiring reconciliation (telecoms, electricity, air transport, agency-sold insurance), review the internal reconciliation process: the invoice may only be issued after reconciliation, yet must still fall within the maximum period allowed — later than that is a penalty.
If your situation does not clearly fit any row above, or an invoice has already been issued at the wrong time and needs correcting, please contact TRÍ TÍN.
Legal basis
- Điều 9 Nghị định 254/2026/NĐ-CP ngày 30/6/2026 của Chính phủ
This summary reflects the legislation in force on the date of publication and is provided for general information. Rules may change or be interpreted differently in later guidance. It is not advice for any specific situation — please contact TRÍ TÍN before applying it to your own filings.
Need advice on your own situation?
Every business is different. Contact TRÍ TÍN to get advice for your specific case before you act.