🌙 1. Transactions arising during night-time working hours

Under Clause 5, Article 9 of Decree No. 254/2026/ND-CP:

When the seller:

• ❌ Does not have automated invoicing software; and
• 🌙 Has transactions involving the sale of goods or provision of services during night-time working hours as
  prescribed by the Labour Code.

This is an important point for enterprises that conduct business during night-time hours but whose systems are
not yet able to automatically issue invoices at the time the transaction arises.

The key conditions are:

• ✅ The transaction actually arises during night-time working hours;
• ✅ The seller does not have automated invoicing software;
• ✅ The invoice must be issued no later than the next working day.

👤 2. Certain services provided directly to individual consumers
are subject to specific management requirements

Point r, Clause 4, Article 9 of Decree No. 254/2026/ND-CP provides specific rules for certain enterprises providing
services directly to individual consumers.

The sectors referred to include:

💻 3. Key requirement: a system capable of managing each
transaction in detail must be in place

For the above services, enterprises should satisfy system-related requirements such as:

• ✅ Having software that manages each transaction in detail;
• ✅ Storing payment collection data on a transaction-by-transaction basis;
• ✅ Ensuring that transaction data can be retrieved and reconciled;
• ✅ Being able to provide relevant data and supporting documents when requested by the tax authority or
  other competent state authorities.

The seller is responsible for the accuracy of transaction information and the complete retention of relevant data.

🔎 4. The key change lies in how transaction data is managed

This regulation shows that invoice management is gradually shifting from merely checking individual invoices to
ensuring the ability to trace the full data flow:

For sectors with a high volume of daily transactions, an enterprise’s data system becomes an important part of
demonstrating the completeness and accuracy of reported revenue.

⚠️ 5. Not all night-time transactions may be invoiced on the
following day

The provision under Clause 5, Article 9 applies only when both of the following conditions are met:

If the enterprise already has an automated invoicing system or is subject to specific rules on the timing of invoice
issuance, it must follow the mechanism applicable to that particular case.

Therefore, enterprises should avoid applying the “next working day” rule to all transactions arising outside normal
business hours.

✅ 6. What should enterprises review?

Enterprises that frequently have transactions arising outside normal business hours or during the night should review:

• 🔹 Whether the enterprise falls within the scope of Clause 5, Article 9;
• 🔹 Whether the current system is capable of automatically issuing invoices at the time the transaction arises;
• 🔹 Whether the transaction time and invoice issuance time are fully recorded and traceable;
• 🔹 Whether sales, payment and invoice data can be reconciled with one another;
• 🔹 Whether the invoicing process for night shifts and the following working day has been clearly defined.

💡 KEY POINTS TO REMEMBER

From 1 July 2026, the regulations on the timing of invoice issuance include a mechanism that is more suitable for
business models involving continuous transactions.