As of June 1, 2025, e-invoices generated from cash registers will no longer be optional but will become mandatory for many businesses, particularly those operating in the retail and service sectors. This marks not only a transition in transaction management but also a significant milestone aimed at enhancing financial transparency, optimizing accounting processes, and strengthening tax supervision.
So, what should businesses do to comply with this requirement? Who will be subject to this regulation? The following article provides an analysis to clarify key considerations for businesses.
1. Definitions
1.1 Electronic Invoice
According to Clause 2, Article 3 of Decree No. 123/2020/NĐ-CP governing invoices and documents:
“An electronic invoice (e-invoice) is an invoice, with or without a tax authority’s code, presented in the form of electronic data, created by organizations or individuals selling goods or providing services using electronic means to record information on the sale of goods or provision of services in accordance with the provisions of the laws on accounting and taxation. This includes invoices generated from cash registers that are connected to and transmit electronic data to the tax authority.”
1.2 E-Invoice Generated from Cash Registers
According to Point a, Clause 2, Article 1 of Decree No. 70/2025/NĐ-CP, which supplements Point c to Clause 2, Article 2 of Decree No. 123/2020/NĐ-CP of the Government:
“c) An e-invoice generated from a cash register connected to and transmitting electronic data to the tax authority (hereinafter referred to as a ‘cash register-generated e-invoice’) is an invoice with a tax authority’s code or electronic data that enables the buyer to retrieve and declare invoice information. It is created by organizations or individuals selling goods or providing services through a point-of-sale (POS) system, and the data is transmitted to the tax authority in the format specified in Article 12 of this Decree.”
This newly introduced provision helps businesses clearly distinguish between different types of invoices and mitigates the risk of tax fraud.
For tax authorities, this system allows for more effective and stringent monitoring of business revenues, contributing to improved tax administration and reduced revenue loss.
2. Issuing E-Invoices Directly from Cash Registers
For businesses subject to the use of cash register-generated e-invoices, Clause 5, Article 12 of Circular No. 32/2025/TT-BTC provides guidance:
If a business engages in direct sales of goods or services to end consumers and has already registered to use e-invoices with or without a tax authority’s code for such sales prior to June 1, 2025, it may choose one of the following options:
- Transition to the use of cash register-generated e-invoices in accordance with Decree No. 70/2025/NĐ-CP; or
- Continue using the type of e-invoices already registered with the tax authority.
→ Therefore, if a business has already registered to use e-invoices, it is not required to switch to issuing invoices directly from cash registers.
→ However, if a business has not registered to use e-invoices and falls under the category required to use cash register-generated e-invoices as per Decree No. 70, it must register for such use starting from June 1, 2025.
3. Entities Subject to Mandatory Implementation
According to Clause 8, Article 1 of Decree No. 70/2025/NĐ-CP, which amends and supplements Article 11 of Decree No. 123/2020/NĐ-CP, the following entities are required to use e-invoices generated from cash registers connected and transmitting data electronically to the tax authority starting from June 1, 2025:
a) Business households and individual businesspersons:
- Those paying tax under the presumptive (lump-sum) method with annual revenue of VND 1 billion or more (as stipulated in Clause 1, Article 51 of the Law on Tax Administration 2019);
- Those using cash registers (pursuant to Clause 2, Article 90 of the Law on Tax Administration);
- Those whose revenue and number of employees meet the highest thresholds for micro-enterprises as defined in the legislation on supporting small and medium-sized enterprises and are subject to the accounting regime and tax declaration method (under Clause 5, Article 51);
- Other cases where revenue can be determined at the time of sale of goods or provision of services using e-invoices with tax authority codes (under Clause 3, Article 91).
b) Enterprises directly selling goods or providing services to end consumers, including:
- Shopping malls, supermarkets, and retail outlets (excluding automobiles, motorcycles, motorbikes, and other motor vehicles);
- Food and beverage businesses; restaurants; hotels;
- Passenger transport services, auxiliary services directly related to road transport, arts and entertainment services, cinema operations, and other personal service activities as defined in the Vietnamese Standard Industrial Classification system.
4. Enforcement Mechanisms
Business households that fail to use e-invoices generated from cash registers connected and transmitting data to the tax authority may be subject to an administrative fine ranging from 4,000,000 VND to 8,000,000 VND, pursuant to Point g, Clause 4, Article 24 of Decree No. 125/2020/NĐ-CP on penalties for administrative violations in taxation and invoicing.
In cases where no invoice is issued when selling goods or providing services to customers as required under Clause 5, Article 24 of the same Decree, the violator shall be subject to a fine ranging from 10,000,000 VND to 18,000,000 VND.
Additionally, remedial measures shall be imposed, namely the obligation to issue invoices or e-invoices in accordance with regulations if requested by the buyer.
The new provisions under Decree No. 70/2025/NĐ-CP regarding cash register-generated e-invoices not only promote financial transparency but also lay the groundwork for digital transformation in tax administration. Businesses must adapt to systems that connect directly with the tax authority, enabling tighter revenue monitoring and fraud prevention. However, this also introduces challenges in terms of technology investment and workforce training.
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