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New Regulation Guiding the Invoicing Timelines for Export, E-Commerce, Banking, Securities, Healthcare, Lottery, and Casino Services

Written by Associate Chau Nguyen

The Government has issued Decree 70/2025/ND-CP (“Decree 70”), amending and supplementing certain provisions of Decree 123/2020/ND-CP on invoices and invoicing.  Decree 70 takes effect on 1 June 2025.  

Decree 70 does not alter the general rule that, for the sale of goods, an invoice must be issued at the time ownership or the right to use the goods is transferred to the buyer, regardless of whether payment has been received.  However, it introduces new and detailed timing requirements for invoicing certain specified categories of goods and services, as summarized below.

Category of Goods or Services

Required Invoicing Time

Note

Export of goods including goods manufactured under contract

Latest the next business day following customs clearance.

This is newly added.

Provision of services

The earlier of the time of completion of the services and the time of payment (other than payment of deposits or advances for accounting, auditing, financial and tax consulting services, valuation, survey, technical design services, supervision consulting, construction investment project preparation).

Decree 70 adds an elaboration that this rule also applies to overseas provision of services.

Provision of goods or services in large volumes, on a recurring basis, which necessitates periodic account reconciliation between the vendor and the buyer.

The earlier of:

(1)  the time of account reconciliation between the parties; and

(2)  the 7th day of the month immediately following the month of the services or the 7th day of the following the cycle as mutually agreed between the vendor and the buyer.

Decree 70 adds the followings to the list of sales for which this rule may apply:

  • Auxiliary railway transport services
  • Television advertising services
  • E-commerce services
  • Banking services other than lending
  • International money transfers
  • Securities services
  • Electronic lottery services
  • Road usage fee collection between investors and toll service providers

Sale of natural gas, associated gas, and coal gas transported via pipelines to the buyer

At the time the vendor and the buyer determine the volume of gas delivered in the month, but no later than the tax declaration deadline for the relevant month, unless a government guarantee and undertaking specify otherwise.

This rule is slightly modified to remove the 7-day timeline, instead deferring to the tax declaration deadline prescribed under applicable laws, or, where relevant, to the government’s guarantee and undertaking for the specific project.

Lending activities of financial institutions

The later of the interest payment due date and the actual interest payment date (in case of early payment, the actual interest payment date).

This is newly added.

Foreign exchange agency and foreign exchange transactions

At the time of the transaction.

This is newly added.

Taxi services using fare-calculating software

At the completion of each trip (the vendor must issue an electronic invoice and simultaneously send the invoice data to the tax authority according to relevant laws).

Decree 70 removes the details of the data required to be sent to the tax authority, leaving it to be guided by the tax authority.

Healthcare services (hospitals using eligible medical expenses management software)

For patients:

  • For patients not requiring invoices, a consolidated electronic invoice is issued at the end of the day for all services rendered to such patients during the day;
  • For patients requiring invoices, an electronic invoice is issued for the services rendered to the respective patients on completion of the services.

For social security agencies: A consolidated invoice is issued at the time the agency settles medical expenses for covered patients.

Decree 70 adds the rules on invoices to social security agencies.

Insurance services

At the time of revenue recognition according to insurance business regulations.

For reference, current insurance regulations governing the time of revenue recognition is Circular 67/2023/TT-BTC of the Ministry of Finance on insurance business.

This amended rule defers the invoicing requirement to the revenue recognition rule for different categories of insurance revenues under the insurance business regulations.

Lottery ticket sales

After retrieving unsold lottery tickets and before the next drawing, the lottery enterprise must issue a single e-invoice with a tax authority code for each agent covering tickets sold during the period.

This is newly added.

Casino and electronic prize-winning games

No later than one day after the date of revenue recognition.  The enterprise must transmit data about the receipts less payouts according to a statutory form to the tax authority concurrently with the transmission of the e-invoice.  The date of revenue recognition is the time window from 0:00 to 23:59 of the same date.

This is newly added.