VI Do export goods require electronic invoices? When should electronic invoices be issued? Let’s find out more with Pham Consult!
Do export goods require electronic invoices?
According to Article 8 of Decree 123/2020/ND-CP (supplemented by point c, clause 5, Article 1 of Decree 70/2025/ND-CP), the following is stipulated:
Types of invoices
Invoices regulated in this Decree include the following types:
2a. Electronic commercial invoices are invoices applicable to organizations, businesses, and individuals (exporters) engaged in exporting goods or providing services abroad, provided that the exporter meets the conditions for electronically transferring commercial invoice data to the tax authorities. Electronic commercial invoices must comply with the content regulations as stipulated in Article 10 of this Decree and the standard data format regulations of the tax authorities as stipulated in Article 12 of this Decree.
If the exporter does not meet the conditions for electronically transferring commercial invoice data to the tax authorities, they may choose to issue an electronic value-added tax invoice or an electronic sales invoice.
Therefore, the electronic commercial invoice is one of the currently available invoice types.
However, electronic commercial invoices are only applicable to organizations, businesses, and individuals (hereinafter referred to as exporters) that export goods or provide services abroad, provided that the exporter meets the conditions for electronically transferring commercial invoice data to the tax authority.
If the exporter does not meet the conditions for electronically transferring commercial invoice data to the tax authority, they cannot use electronic commercial invoices but must choose: (1) electronic value-added tax invoices or (2) electronic sales invoices in accordance with regulations.
When is the time to issue an electronic commercial invoice?
According to Clause 1, Article 9 of Decree 123/2020/ND-CP (amended by Point a, Clause 6, Article 1 of Decree 70/2025/ND-CP):
Time of Invoice Issuance
- The time of issuing an invoice for the sale of goods (including the sale and transfer of public assets and the sale of national reserves) is the time of transferring ownership or the right to use the goods to the buyer, regardless of whether payment has been received or not.
For the export of goods (including export processing), the time of issuing an electronic commercial invoice, electronic value-added tax invoice, or electronic sales invoice is determined by the seller, but no later than the next working day from the date the goods are cleared through customs according to the law on customs.
Therefore, the time of issuing an electronic commercial invoice for exported goods (including export processing) is determined by the seller, but no later than the next working day after the goods are cleared through customs according to customs regulations.
What are the regulations regarding the format of electronic commercial invoices?
According to Article 8 of Decree 123/2020/ND-CP (supplemented by point c, clause 5, Article 1 of Decree 70/2025/ND-CP), electronic commercial invoices must comply with the content regulations as stipulated in Article 10 of Decree 123/2020/ND-CP and the standard data format regulations of the tax authority as stipulated in Article 12 of Decree 123/2020/ND-CP.
Therefore, e-commerce invoices must comply with the tax authority’s standard data format for electronic invoices as stipulated in Article 12 of Decree 123/2020/ND-CP (amended by Clause 9, Article 1 of Decree 70/2025/ND-CP) as follows:
– The electronic invoice format is a technical standard specifying the data type and data length of information fields used for transmitting, storing, and displaying electronic invoices. The electronic invoice format uses the XML text formatting language (XML stands for “eXtensible Markup Language,” created for the purpose of sharing electronic data between information technology systems).
– The electronic invoice format consists of two components: a component containing the electronic invoice business data and a component containing the digital signature data. For electronic invoices with a tax authority code, there is an additional component containing data related to the tax authority code.
– Organizations and businesses selling goods or providing services that transmit electronic invoice data to the tax authorities via direct delivery must meet the following requirements:
+ Connect to the General Department of Taxation via a leased line or MPLS VPN Layer 3, including one primary and one backup transmission channel. Each transmission channel must have a minimum bandwidth of 5 Mbps.
+ Use encrypted Web Service or Message Queue (MQ) as the connection method.
+ Use the SOAP protocol to package and transmit data.
– Electronic invoices must display all the contents accurately and completely, ensuring that they are not misinterpreted and that buyers can read them electronically.
