How Do Enterprises Register to Use E-Invoices? Coded or Non-Coded E-Invoices

Conditions for enterprises to register to use electronic invoices

Under Article 15 of Decree 123/2020/ND-CP (effective from 01/07/2022) on registration and changes to registration of electronic invoice use, among which:

Registration to use electronic invoices is prescribed as follows:

– Enterprises, economic organizations, other organizations, households and individual businesses not subject to suspension of invoice use as prescribed in Clause 1, Article 16 of this Decree register to use electronic invoices (including registration of electronic invoices for sale of public assets and electronic invoices for sale of national reserve goods) through an electronic invoice service provider.

Where tax authority-coded electronic invoices are used without paying service fees, registration to use electronic invoices may be made through the tax authority’s electronic portal or through an electronic invoice service provider authorized by the General Department of Taxation to provide free tax authority-coded electronic invoice services.

Where an enterprise is an organization that transmits electronic invoice data directly to the tax authority, it registers to use electronic invoices through the tax authority’s electronic portal.

Registration information content follows Form 01/ĐKTĐ-HĐĐT in Appendix IA issued with this Decree.

The General Department of Taxation’s electronic portal sends electronic notices of acceptance of electronic invoice use registration through the electronic invoice service provider for enterprises, economic organizations, other organizations, households and individual businesses registering to use electronic invoices through an electronic invoice service provider.

The tax authority’s electronic portal sends electronic notices directly using Form 01/TB-TNĐT in Appendix IB on acceptance of electronic invoice use registration to enterprises, economic organizations, other organizations, households and individual businesses at the email address registered with the tax authority, for those registering to use electronic invoices directly on the tax authority’s electronic portal.

– Within 01 working day from receipt of the electronic invoice use registration, the tax authority is responsible for sending an electronic notice using Form 01/TB-ĐKĐT in Appendix IB issued with this Decree through the electronic invoice service provider or sending an electronic notice directly to the enterprise, economic organization, other organization, household or individual business on acceptance or rejection of the electronic invoice use registration.

For enterprises or economic organizations registering to transmit electronic invoice data directly to the tax authority as prescribed at Point b1, Clause 3, Article 22 of this Decree that receive the tax authority’s notice accepting electronic invoice use registration using Form 01/TB-ĐKĐT in Appendix IB but have not yet coordinated with the General Department of Taxation on technical infrastructure configuration, connection testing and data transmission/reception, then no later than 05 working days from the date the tax authority sends the notice using Form 01/TB-ĐKĐT in Appendix IB, the organization must prepare sufficient technical infrastructure conditions and notify the General Department of Taxation for coordination of connection. Implementation shall take place within 10 working days from the date the General Department of Taxation receives the request from the enterprise or organization. Where the connection testing and data transmission/reception results are successful, the enterprise or organization shall send electronic invoice data directly to the tax authority as prescribed in Article 22 of this Decree. Where, after 05 working days from the date the tax authority sends the notice using Form 01/TB-ĐKĐT in Appendix IB, the enterprise or organization does not notify the General Department of Taxation for coordination of connection, or the connection testing and data transmission/reception results are unsuccessful, the enterprise or organization shall change its electronic invoice use registration using Form 01/ĐKTĐ-HĐĐT in Appendix IA issued with this Decree and transmit data through an organization that connects, receives and stores electronic invoice data with the tax authority.

– From the time the tax authority accepts electronic invoice use registration as prescribed in this Decree, enterprises, economic organizations, other organizations, households and individual businesses must stop using electronic invoices previously notified for issuance under former regulations, and destroy paper invoices notified for issuance but not yet used (if any). The destruction sequence and procedures shall follow Article 27 of this Decree.

Notes: Where there is a change to the registered electronic invoice use information under Clause 1 of this Article, enterprises, economic organizations, other organizations, households and individual businesses shall change the information and resend it to the tax authority using Form 01/ĐKTĐ-HĐĐT in Appendix IA issued with this Decree through the tax authority’s electronic portal or through an electronic invoice service provider, except where they stop using electronic invoices as prescribed in Clause 1, Article 16 of this Decree. The General Department of Taxation’s electronic portal receives the information change registration form and the Tax Authority implements it as prescribed in Clause 2 of this Article.

– Monthly, the directly managing tax authority reviews subjects using free tax authority-coded electronic invoices and sends notices using Form 01/TB-KTT in Appendix IB issued with this Decree to such subjects notifying them of the switch to using tax authority-coded electronic invoices through an electronic invoice service provider, and to change their tax authority-coded electronic invoice use information as prescribed in Clause 4 of this Article.

For cases applying electronic invoices without tax authority codes, monthly the directly managing tax authority reviews and notifies using Form 01/TB-KTT in Appendix IB issued with this Decree if they are subject to switching to using tax authority-coded electronic invoices, to register for tax authority-coded electronic invoice use as guided in this Article.

Note: the quotations above are the original text of Decree 123/2020/ND-CP (issued in 2020). Since 01/3/2025, the General Department of Taxation has been reorganized into the Department of Taxation under the Ministry of Finance; references to the “General Department of Taxation” in the text are understood as the competent tax authority under the new organizational structure.

Do enterprises use tax authority-coded or non-coded electronic invoices?

Under Clause 2, Article 3 of Decree 123/2020/ND-CP (effective from 01/07/2022) as follows:

An electronic invoice is an invoice with or without a tax authority code expressed in electronic data form, prepared by organizations or individuals selling goods or providing services using electronic means to record information on sale of goods or provision of services as prescribed by accounting law and tax law, including invoices generated from cash registers with electronic data transfer connections to the tax authority, in which:

– An electronic invoice with a tax authority code is an electronic invoice assigned a code by the tax authority before the organization or individual selling goods or providing services sends it to the buyer.

The tax authority code on an electronic invoice includes a transaction number that is a unique number sequence generated by the tax authority’s system and a character string encrypted by the tax authority based on the seller’s information prepared on the invoice.

– An electronic invoice without a tax authority code is an electronic invoice sent by the organization selling goods or providing services to the buyer without a tax authority code.

Under current tax administration law (Law on Tax Administration 2025, No. 108/2025/QH15, effective from 01/7/2026, replacing the Law on Tax Administration 2019) and Decree 123/2020/ND-CP, the principle for using tax authority-coded/non-coded electronic invoices is as follows:

– Enterprises and economic organizations use tax authority-coded electronic invoices when selling goods or providing services, regardless of the value of each sale;
– Enterprises operating in electricity, petroleum, postal and telecommunications, clean water, finance and credit, insurance, healthcare, e-commerce, supermarkets, commerce, transport, and enterprises meeting conditions on IT infrastructure, accounting software and electronic invoice data transmission to the tax authority may use non-coded electronic invoices;
– Household businesses and individual businesses, when needing invoices to issue to customers, are issued tax authority-coded electronic invoices by the tax authority for each arising transaction and must declare and pay taxes as prescribed.

How are electronic invoices preserved and stored?

Under Article 6 of Decree 123/2020/ND-CP (effective from 01/07/2022) on preservation and storage of invoices and documents, specifically:

“Article 6. Preservation and storage of invoices and documents

1. Invoices and documents shall be preserved and stored ensuring:

a) Safety, confidentiality, integrity, completeness, and no alteration or deviation during the storage period;

b) Storage for the correct and full period as prescribed by accounting law.

2. Electronic invoices and electronic documents shall be preserved and stored by electronic means. Agencies, organizations and individuals may choose and apply forms of preserving and storing electronic invoices and electronic documents suitable to their operational characteristics and technology application capacity. Electronic invoices and electronic documents must be ready to be printed on paper or looked up upon request.

3. Invoices printed by the tax authority, ordered printed or self-printed documents must be preserved and stored in accordance with the following requirements:

a) Unissued invoices and documents shall be stored and preserved in warehouses under the valuable document storage regime.

b) Issued invoices and documents in accounting units shall be stored under the accounting document storage regulations.

c) Issued invoices and documents in organizations, households and individuals that are not accounting units shall be stored and preserved as their own assets.”

Thus, electronic invoices shall be preserved and stored by electronic means. Agencies, organizations and individuals may choose or apply forms of preserving or storing electronic invoices suitable to their operational characteristics and technology application capacity. Enterprises should also note that they must be ready to print on paper or look up upon request.

Notes on applying current legal regulations

This article belongs to the Corporate & M&A Knowledge knowledge group and is provided for reference purposes, helping readers gain an overview of the legal issue before preparing dossiers or conducting transactions.

Legal regulations may change depending on the time, locality, dossier type and specific circumstances. If you need to determine the exact legal basis applicable to your dossier, please contact ANT Legal’s lawyers at 0966.475.966 for review and advice before proceeding.

Common risks to note

• Applying legal documents that have been amended, supplemented or replaced.
• Preparing incomplete dossiers, documents or evidence.
• Misunderstanding the conditions, procedures, time limits or competent authorities.
• Signing, submitting dossiers or conducting transactions without fully assessing legal risks.

How can ANT Legal help?

ANT Legal assists in reviewing specific situations, checking dossiers, identifying the applicable legal basis, advising on handling plans, and representing clients in dealings with individuals, organizations or competent authorities when necessary.

For prompt advice, please contact our lawyers at 0966.475.966.

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