Decree 70/2025/ND-CP, effective June 1, 2025, mandates that consumer-facing enterprises connect point-of-sale systems to the General Department of Taxation for real-time electronic invoice data transmission. The obligation covers restaurants, hotels, retail stores, shopping malls, supermarkets, entertainment venues, and passenger transport operators. For registered enterprises in these sectors, the mandate applies universally from June 1, 2025. For household businesses, the VND 1 billion annual revenue threshold determines when the obligation begins.
Foreign-invested enterprises operating in these sectors are not exempt. Decree 70/2025 and implementing Circular 32/2025/TT-BTC apply equally to domestically owned and foreign-invested companies. The penalty framework under Decree 310/2025/ND-CP, effective January 16, 2026, makes non-compliance costly. This checklist covers the five compliance steps every consumer-sector FDI operator must complete.
Who Is In Scope: Consumer Sectors Under Decree 70/2025
Sectors Required to Use POS Electronic Invoice Systems
Under Decree 70/2025/ND-CP, enterprises in the following sectors must connect POS cash registers to the GDT for real-time e-invoice issuance:
- Shopping malls and commercial centres
- Supermarkets and retail stores (excluding automobiles and motorbikes)
- Food and beverage services and restaurants
- Hotels and accommodation services
- Passenger transport services
- Direct support services for road transport operations
- Arts, entertainment, recreation, and cinema services
- Other personal consumer services
Scope for FDI Operators
The mandate covers all registered enterprises in these sectors from June 1, 2025. For household businesses, the VND 1 billion annual revenue threshold applies. FDI-owned restaurant chains, hotel groups, shopping mall operators, and entertainment venues are fully in scope. Decree 70/2025 provides no exemptions based on ownership structure or foreign investment status.
Checklist Point 1, Register With the GDT and Obtain Electronic Invoice System Approval
How to Register an E-Invoice System in Vietnam
Before issuing any e-invoices, an enterprise must register its electronic invoice system with the General Department of Taxation. Registration uses Form 01/DKTD-HDDT, submitted via the GDT web portal or the National Public Service Portal. The form must specify the enterprise’s tax identification number, the type of e-invoice system selected, and the name of any third-party e-invoice service provider authorised to issue invoices on behalf of the company.
Authenticated vs Unauthenticated E-Invoice
Two electronic invoice categories exist under Decree 70/2025. An authenticated e-invoice carries a tax authority code assigned by the GDT before the invoice reaches the buyer. An unauthenticated e-invoice is sent to the buyer without a pre-assigned GDT code. Consumer-facing FDI operators in retail, food and beverage, and hospitality generally issue authenticated e-invoices for B2C transactions.
Third-Party E-Invoice Service Providers
New under Decree 70/2025: enterprises may authorise a third-party service provider to issue electronic invoices on their behalf. This provision benefits FDI operators with legacy POS systems or multi-outlet operations. Third-party authorisation must be registered with the GDT alongside the main e-invoice system registration.
Checklist Point 2, Connect POS Systems to GDT for Real-Time Data Transmission
Technical Integration Requirements Under Circular 32/2025
POS cash registers in all in-scope consumer sectors must transmit electronic invoice data to the GDT in real time at the point of each transaction. Data must be transmitted in XML format, the mandatory electronic data standard under Vietnam’s e-invoicing framework. The GDT assigns a tax authority code and returns a QR code for display on the consumer receipt.
The Digital Signature Exemption for POS E-Invoices
POS-generated electronic invoices are specifically exempt from digital signature requirements under Decree 70/2025. This exemption covers only invoices generated at the point of sale through a GDT-connected POS system. It does not remove the real-time data transmission obligation. Enterprises that have procured GDT-approved digital signature certificates solely for their POS systems are incurring unnecessary cost. Enterprises that interpret the digital signature exemption as removing all GDT reporting obligations are non-compliant.
Checklist Point 3, Confirm Mandatory Invoice Content and VAT Rate Accuracy
Mandatory Content on POS-Generated Electronic Invoices
Every POS electronic invoice issued under Decree 70/2025 must include: the seller’s name, address, and tax identification number; the buyer’s name, address, and tax code or personal identification number (if the buyer requests it); a description of the goods or services; unit price, quantity, and total payment amount; the applicable VAT rate and VAT amount; and the GDT-assigned tax authority code or a QR code that allows the buyer to access and verify invoice data.
For anonymous consumer transactions where the buyer does not request a buyer-specific invoice, the buyer name and TIN fields may remain blank. The GDT tax authority code alone is sufficient for these transactions.
VAT Rate Accuracy Under the 2026 Rate Reduction
The 8% reduced VAT rate has been extended to December 31, 2026 under Resolution 204/2025/QH15. The standard rate remains 10%. Operators must confirm that POS systems apply the correct rate to each product and service category. Invoices applying the 10% standard rate to goods eligible for the 8% reduction are incorrect and require amendment under Decree 70/2025 error correction procedures. Rate misclassification also constitutes an invoice accuracy violation under Decree 310/2025.
Checklist Point 4, Establish Error Correction and 10-Year Archiving Procedures
Error Correction Procedures Under Decree 70/2025
When an electronic invoice contains an error after the GDT code has been assigned and the invoice issued, two correction pathways apply. For errors affecting the tax amount, seller or buyer details, or transaction value, the seller issues a replacement e-invoice and notifies the GDT. For minor errors that do not affect the tax amount or key transaction details, the seller may issue an adjustment notification rather than a full replacement invoice. In both cases, the seller must retain the written adjustment agreement (biên bản điều chỉnh) as documentary evidence for audit purposes.
10-Year E-Invoice Archiving Obligation
E-invoices and associated transaction data must be retained for a minimum of 10 years from the date of issue. Archiving must preserve the original XML data file, not only a PDF rendering or printed copy. The GDT retains a copy of all transmitted POS data. This does not discharge the enterprise’s independent archiving obligation. The GDT may request historical e-invoice data during tax audits covering periods up to 10 years prior. FDI operators should confirm that e-invoice archiving is integrated into their broader financial records management framework.
Checklist Point 5, Monitor the Lucky Invoice Programme and Consumer-Facing Compliance
The Lucky Invoice Programme as a Compliance Driver
The lucky invoice programme (hóa đơn may mắn) is administered by provincial Tax Departments. It operates as a consumer incentive mechanism for electronic invoice issuance in B2C transactions. Consumers who receive valid e-invoices from restaurants, retail stores, hotels, and other consumer-facing businesses are entered into provincial prize draws. The programme creates compliance pressure from the consumer side. Customers who request an invoice and do not receive a valid, GDT-compliant receipt can report the operator to the provincial Tax Department.
Staff Training and Operational Compliance
For FDI-operated restaurant groups, retail chains, and hotel operators, every consumer-facing transaction is a potential compliance touchpoint. Staff training must ensure front-of-house teams issue POS e-invoices as the default completion step for every transaction, not only when prompted by the consumer. POS systems should be configured so that electronic invoice issuance is a mandatory step in the transaction workflow, not an optional one.
Penalties for Non-Compliance Under Decree 310/2025
Fine Ranges for POS E-Invoice Violations
Decree 310/2025/ND-CP, effective January 16, 2026, sets the penalty framework for electronic invoice violations. Key fines for POS operators are:
| Violation | Fine Range |
|---|---|
| Failure to transmit POS e-invoice data to GDT in real time | VND 20–50 million |
| Issuing e-invoices with incorrect content or format | VND 10–20 million |
| Failure to issue e-invoices for taxable transactions | VND 10–30 million |
| Late e-invoice data registration with GDT | VND 3–5 million |
| Failure to archive e-invoices per requirements | VND 3–5 million |
Multi-Outlet Exposure for FDI Operators
Penalties under Decree 310/2025 are assessed per outlet and per violation, not as a single aggregate fine per enterprise. For an FDI restaurant group with 20 locations operating in non-compliance simultaneously, the combined exposure from one type of violation alone can reach VND 400 million to VND 1 billion. GDT enforcement activity in consumer-facing sectors increased significantly from mid-2024, with on-site inspections targeting restaurants, retail stores, and hotel operators in Hanoi and Ho Chi Minh City.
Conclusion
Vietnam’s POS electronic invoice mandate under Decree 70/2025 is fully operative. For FDI operators in retail, food and beverage, hospitality, and entertainment, the five-point compliance framework covers the full obligation: GDT registration and system approval; POS integration for real-time XML data transmission; mandatory invoice content accuracy including correct VAT rate; error correction procedures and 10-year archiving; and consumer-facing invoice issuance supported by the lucky invoice programme.
Operators with multi-outlet Vietnam operations or legacy POS systems face the highest implementation risk. Third-party e-invoice service provider authorisation under Decree 70/2025 provides a managed pathway for these cases. Viettonkin supports consumer-sector FDI operators in completing GDT registration, reviewing POS integration readiness, and building the internal compliance procedures required to manage ongoing electronic invoice obligations.
Frequently Asked Questions
Which businesses must use POS-connected electronic invoices in Vietnam under Decree 70/2025? Enterprises in shopping malls, supermarkets, retail stores (excluding vehicles), restaurants, food and beverage services, hotels, passenger transport, arts and entertainment, cinema, and personal consumer services must connect POS cash registers to the GDT. For household businesses, the mandate applies where annual revenue reaches VND 1 billion or above.
Do POS-generated electronic invoices in Vietnam require a digital signature? No. POS-generated electronic invoices are specifically exempt from digital signature requirements under Decree 70/2025. The digital signature exemption does not remove the real-time data transmission obligation to the GDT. All POS transactions must still transmit invoice data to the tax authority in XML format in real time.
What are the penalties for failing to issue POS e-invoices in Vietnam? Under Decree 310/2025/ND-CP (effective January 16, 2026), failure to transmit POS e-invoice data to the GDT carries fines of VND 20–50 million per violation. Failure to issue invoices for taxable transactions is fined VND 10–30 million. Fines are assessed per outlet, multi-location FDI operators face aggregate exposure across all non-compliant locations.
