Invoice Issuance Timing for E-Commerce Services under Decree No. 254/2026/ND-CP
Pursuant to Article 9 of Decree No. 254/2026/ND-CP, the time for issuing invoices for e-commerce services is determined based on the nature and method of service provision, specifically as follows:
1. E-Commerce Services Requiring Data Reconciliation
For services provided in large volumes, on a regular basis, and requiring time for data reconciliation between the service provider and customers or partners:
- The invoice issuance time is the time when data reconciliation between the parties is completed;
- However, the invoice must be issued no later than the 7th day of the month following the month in which the service is provided, or within 7 days from the end of the agreed billing period.
- The agreed billing period used to determine the quantity of goods or services provided shall be based on the agreement between the service provider and the buyer.
👉 This case generally applies to e-commerce services involving a large number of transactions, where time is needed to consolidate and reconcile data before accurately determining revenue and service fees.
2. Ordinary E-Commerce Services
For cases that do not require data reconciliation as specified above:
- The invoice issuance time is the time when the service is completed, regardless of whether the service provider has received payment.
- If the service provider receives payment before or during the provision of the service, the invoice issuance time is the time of receipt of payment.
- The requirement to issue an invoice upon receipt of advance payment does not apply to deposits made in accordance with the Civil Code to secure the performance of a service contract.
👉 In Summary
For e-commerce services, it is necessary to determine whether the service is provided regularly, in large volumes, and requires data reconciliation:
- With data reconciliation: Issue the invoice upon completion of data reconciliation, but no later than the 7th day of the following month or within 7 days from the end of the agreed billing period.
- Ordinary services: Issue the invoice when the service is completed.
- Payment received in advance/during service provision: Issue the invoice at the time of payment, except for a deposit securing the performance of the contract.
Can E-Invoices Be Consolidated at the End of the Month on E-Commerce Platforms? What Are the Invoice Issuance Requirements?
Under Clause 1, Article 17 of Decree No. 254/2026/ND-CP, sellers have the right to:
Request the operator of an e-commerce platform or digital platform to provide buyer information, transaction-related information, delivery time, and confirmation of the order completion status on the system so that the seller can issue e-invoices in accordance with regulations for the sale of goods and provision of services through e-commerce or digital platforms.
In addition, Clause 2, Article 19 of Decree No. 254/2026/ND-CP stipulates that e-commerce and digital platform operators are responsible for providing buyer information, transaction-related information, delivery time, and order completion status on the system so that sellers can issue e-invoices in accordance with regulations.
Therefore, sellers operating on e-commerce platforms may request the platform operator to provide the necessary buyer and transaction information for e-invoice issuance.
Under Article 26 of the 2025 Law on Tax Administration, sellers are required to issue and deliver e-invoices to buyers when selling goods or providing services.
👉 Conclusion: E-invoices cannot be consolidated at the end of the month for e-commerce transactions.
Sellers must issue a separate e-invoice for each transaction in accordance with the applicable regulations.
Reporting Failure to Issue an E-Invoice: Reward of Up to VND 10 Million
From July 1, 2026, consumers who report sellers for failing to issue and deliver e-invoices may be eligible for a reward under Decree No. 254/2026/ND-CP.
Pursuant to Clause 5, Article 41 of Decree No. 254/2026/ND-CP:
Consumers who report sellers for failing to issue and deliver e-invoices may be rewarded.
The reward for providing information regarding a case of failure to issue and deliver an invoice is no more than 10% of the administrative fine imposed, subject to a maximum of VND 10,000,000 per case.
👉 Therefore, from July 1, 2026:
Consumers reporting a seller for failure to issue and deliver an e-invoice may receive a reward of:
Up to 10% of the administrative fine imposed, with a maximum of VND 10,000,000 per case.
⚠️ Important Notes
A consumer’s report may be considered for a reward when the following conditions are satisfied:
- Accurate, truthful, and timely information is provided, with sufficient grounds to identify the time, location, and person committing the violation;
- The reported information accurately reflects the actual circumstances and provides sufficient grounds for the tax authority to determine the nature and severity of the violation and conduct inspection and verification;
- Based on the information provided, the tax authority has issued a decision imposing an administrative penalty for a tax or invoice violation in accordance with tax administration regulations.
