Can You Issue Invoices for Unregistered Business Lines?

Short answer: Invoicing is considered primarily from the perspective of whether the economic transaction is genuine and tax obligations: if the goods or services were actually supplied and the enterprise fully declares and pays taxes, the invoice in principle reflects the actual transaction. However, conducting business in lines/sectors not declared/supplemented in the enterprise registration dossier violates enterprise registration regulations and may be subject to administrative sanctions. Enterprises should supplement the business lines promptly rather than letting this situation drag on.

Legal basis

• Article 7 of the Law on Enterprises 2020 — enterprises are free to do business in lines/sectors not prohibited by law;
• Law No. 76/2025/QH15 amending and supplementing the Law on Enterprises (effective from 01/7/2025);
• Decree 168/2025/ND-CP on enterprise registration;
• Current laws on invoices, documents and tax administration.

Two legal issues to separate

1. Validity of the invoice: the invoice must reflect the actual economic transaction, the correct timing and value; the enterprise must fully declare taxes. An invoice for a genuine, correctly declared transaction cannot be deemed an illegal invoice merely because of the business line;
2. Obligation to register business lines: enterprises are obliged to declare and notify the supplementation of business lines under enterprise registration regulations. Violating this obligation is subject to administrative sanctions in the enterprise registration sector.

What should enterprises do?

1. Review all lines/sectors actually being conducted against the declared contents;
2. Complete the notification procedure to supplement business lines under Decree 168/2025/ND-CP;
3. For conditional business lines: only conduct business after satisfying all conditions and obtaining licenses;
4. Keep complete contracts, delivery documents and payment records to prove genuine transactions during tax inspections.

Risks of not supplementing business lines

• Administrative sanctions in the enterprise registration sector;
• Difficulties during tax finalization and explanations to tax authorities about business activities outside the declared lines;
• Partners’ concerns about the enterprise’s legal transparency.

If you need to determine the option best suited to your enterprise’s specific situation, you should discuss it with a lawyer in advance for dossier review and advice on the handling plan.

For quick advice, you may contact a lawyer at 0966.475.966.

Related articles

• Must all business lines be registered?
• In which cases is an enterprise’s business license revoked?
• When do the details on the Enterprise Registration Certificate have legal effect?