The principles for handling erroneous invoices, as stipulated in Circular 91/2026, have just been detailed by the Ministry of Finance. Article 10 of Circular 91/2026/TT-BTCOfficially effective from July 1, 2026, specific instructions will be provided. Tax Administration Law 2025 and Decree 254/2026/ND-CPAccordingly, depending on the severity of the error, the accountant may only need to send Notification Form No. 04/SS-HĐĐT without reissuing the invoice, or they may have to choose to issue an adjustment invoice or a replacement invoice following the correct procedure to ensure validity. This article summarizes 11 cases for handling according to the latest legal documents, helping accountants and businesses apply the regulations accurately and avoid risks when declaring and settling taxes.
What does Circular 91/2026/TT-BTC stipulate regarding the handling of erroneous invoices?
Specifically, Article 10 of Circular 91/2026/TT-BTC, issued by the Ministry of Finance, provides detailed guidance on handling erroneous electronic invoices, to be applied uniformly from July 1, 2026. This document serves as implementation guidance for the 2025 Tax Administration Law and Decree 254/2026/ND-CP, therefore the principles in Circular 91/2026 are mandatory for all organizations, businesses, household businesses, and individual businesses using electronic invoices.
Compared to previous regulations, the principles for handling erroneous invoices under Circular 91/2026 are more clearly systematized according to different situation groups, from errors that do not affect the tax amount, errors that directly affect the tax amount, to cases occurring multiple times in the same month or consecutively on the same original invoice. A thorough understanding of each situation group helps accountants proactively handle errors correctly from the first attempt, avoiding repeated corrections that could jeopardize the validity of the invoice.
See more: New points in Circular 91/2026/TT-BTC.
Summary of principles for handling erroneous invoices according to Circular 91/2026, broken down by case.
This is the core content that accountants need to pay the most attention to. Below are all the cases of errors stipulated in Article 10 of Circular 91/2026/TT-BTC, along with the corresponding handling principles.
In case of incorrect buyer's name, address, or other details (but not incorrect tax identification number, tax amount, tax rate, or goods).
These are minor errors that do not affect the nature of the tax data. According to regulations, if an invoice only contains errors in the buyer's name, address, or other details, but not in the tax identification number, amount, tax rate, tax amount, or goods, the seller is not required to reissue the invoice.
Instead, the seller only needs to notify the buyer of the error and simultaneously send a Notice using Form No. 04/SS-HĐĐT to the tax authority for recording. This is a point that many new accountants often overlook, thinking that minor errors don't require notification. However, according to the principles for handling erroneous invoices under Circular 91/2026, sending this notification is mandatory to ensure transparency with the tax authority.
In case of errors in tax code, product/service name, unit price, quantity, tax rate, or tax amount.
For errors that directly affect declared figures, including incorrect tax identification numbers; product/service names; specifications, quality; unit prices; quantities; total amounts; tax rates; tax amounts; or other mandatory information, the seller may choose one of two options:
- Issue an electronic adjustment invoice; or
- Electronic invoicing is the alternative.
This is the key point in the principle of handling erroneous invoices according to Circular 91/2026, which allows accountants to proactively choose the method that suits the actual situation of the business, instead of being forced to follow a single form as in some previous regulations.
Instructions on how to fill in the content when preparing adjustment invoices and replacement invoices.
To make it easier for accountants to compare and avoid confusion when preparing invoices, here is a summary table of the required information to include for each option:
| Option | It is mandatory to include this on the invoice. | Processing nature |
| Adjustment invoice | Adjustment for Invoice Form No…, Symbol…, Number…, Date… Month… Year… | Only the difference (increase/decrease) compared to the original invoice is adjusted; the original invoice still retains some legal validity. |
| Replacement invoice | This replaces invoice Form No. ..., symbol ..., number ..., date ... month ... year ... | Replace the entire content of the previous incorrect invoice; the original invoice is no longer valid. |
Accurately citing the original invoice information (form number, symbol, invoice number, date of issue) in the aforementioned text is a mandatory requirement. This helps tax authorities and relevant parties easily verify and trace the invoice's adjustment history. Accountants need to carefully consider these two options depending on the extent of the error and reach an agreement with the buyer.
How to handle situations where multiple invoices from the same buyer contain the same incorrect information within a single month.
In practice, it is not uncommon for a business to issue multiple invoices to the same customer in a month, all containing the same error. In this situation, the principle for handling erroneous invoices according to Circular 91/2026 allows the seller to:
- Establish 01 adjustment invoice or 01 replacement invoice This applies to multiple incorrect invoices, along with the following: Statement according to Form No. 01/BK-ĐCTT.
This regulation significantly reduces the workload for accountants when dealing with a series of incorrect invoices due to the same reason, instead of having to create individual adjustment or replacement invoices for each original invoice.
Procedures before making adjustments or replacements for buyers who are organizations, businesses, households, or individual business owners.
Another important point in the principles for handling erroneous invoices according to Circular 91/2026 is the requirement for coordinated procedures between the two parties. Specifically, if the buyer is an organization, enterprise, household business, or individual business, before issuing an adjustment invoice or replacement invoice, both parties must comply with the regulations in Article 10 of Circular 91/2026/TT-BTC.
In other words, adjusting or replacing an invoice is not a unilateral decision from the seller, but requires agreement and coordination with the buyer to ensure the accuracy and validity of the new invoice.
Filing tax returns after correcting erroneous invoices.
After completing the process of issuing adjusted or replacement invoices, businesses must not skip the tax declaration step. According to regulations, the declaration must be made in accordance with the laws on tax administration and value-added tax (VAT), ensuring that it accurately reflects the actual nature of the transaction.
This is the most easily overlooked step in the process of handling erroneous invoices, because many accountants focus only on reissuing the invoice and forget to review the corresponding tax declaration data for the period in which the invoice was issued, leading to discrepancies between the invoice and the tax return.
In the case of returning all or part of the goods or services.
In addition to cases of errors in invoice content, Circular 91/2026 also clearly stipulates the situation where the buyer returns goods or services. In that case, the parties must... Issue an invoice to reflect the value of returned goods or services.This serves as the basis for adjusting the revenue and corresponding tax obligations of both parties.
Trade discounts are determined after the invoice is issued.
For the determined trade discount after the invoice has been issuedTherefore, the seller needs to issue an adjustment invoice or replacement invoice in accordance with regulations to correct the value and VAT amount of the previously issued invoice. This is also an inseparable part when discussing the principles for handling erroneous invoices according to Circular 91/2026, because essentially it is still a form of adjusting data on the original invoice.
Note regarding the lack of notes on the adjustment/replacement invoice.
If an adjustment or replacement invoice lacks a note referencing the original invoice as mentioned above, it will be considered invalid. This means that the entire legal validity of the adjustment or replacement will not be recognized, leading to tax risks for both the seller and the buyer.
Handling adjustment invoices and replacement invoices when further errors are discovered.
This is a complex but fairly common situation in practice: After issuing an adjustment or replacement invoice, the accountant discovers new errors. According to the principles for handling erroneous invoices as stipulated in Circular 91/2026, the seller... Continue to issue adjustment invoices or replacement invoices. For invoices containing errors as per regulations, specifically:
- For replacement invoices: The invoices are linked sequentially in the chain F0, F1, F2, F3, … Fn (each subsequent invoice replaces the previous one).
- For adjustment invoices: The values are added together using the formula F0 + F1 + F2 + F3 +…+ Fn.
In particular, accountants need to pay attention to the following principle: Previously issued adjustment invoices cannot be canceled. This regulation aims to ensure the continuity and transparency of the adjustment invoice chain, preventing arbitrary cancellations that could make data reconciliation difficult later on.
Why is it important to understand the principles for handling erroneous invoices according to Circular 91/2026?
After reviewing all the specific cases, it can be seen that the regulations in Circular 91/2026 are not merely administrative procedures, but also directly affect the validity of accounting and tax records of businesses.
If the accountant makes a procedural error, for example, choosing the wrong type of invoice for adjustment or replacement, forgetting to send Notification Form No. 04/SS-HĐĐT, or omitting a note referencing the original invoice, the invoice may be considered invalid. This can lead to the expense not being accepted for corporate income tax purposes, input VAT not being deductible, or the business being subject to back taxes or penalties during tax audits. This is also why many small and medium-sized enterprises choose to use this method. full accounting service To ensure that the professional team at MAN – Master Accountant Network updates and correctly applies the new regulations from the outset, instead of handling things yourself and risking errors.
Conversely, when businesses and accountants understand the principles for handling erroneous invoices according to Circular 91/2026 from the outset, the process of handling errors will be quick and correct, minimizing the risk of chain errors, especially in consecutive replacement invoice sequences which are prone to confusion if not closely monitored.
Some practical notes on applying the principles for handling erroneous invoices according to Circular 91/2026.
During implementation, accountants should note the following points to ensure compliance with regulations:
- Prioritize correctly identifying the nature of the error: Before deciding how to handle the error, whether it will change the tax identification number, amount, tax rate, tax amount, or goods, it is then determined whether a new invoice needs to be issued or simply a notification needs to be sent.
- Agree on a plan with the buyer.Before issuing an adjustment or replacement invoice, especially when the buyer is an organization, enterprise, or household/individual business.
- Carefully check the reference note. On the adjustment/replacement invoice, include (form number, symbol, invoice number, date of issue of the original invoice) to avoid the invoice being considered invalid.
- Closely monitor the invoice chain.In cases requiring multiple adjustments or replacements, under no circumstances should previously issued adjustment invoices be canceled.
- Review the tax declaration data.Immediately after correcting the erroneous invoice, ensure that the tax return accurately reflects the actual transaction.
- Maintain complete records.This includes Notification Form No. 04/SS-HĐĐT, Statement Form No. 01/BK-ĐCTT, and minutes of agreement (if any) with the buyer, for verification and explanation purposes when necessary.
Reference: 5 key changes when adjusting electronic invoices.
Conclusion and recommendations
As can be seen, the principles for handling erroneous invoices according to Circular 91/2026 are quite detailed and comprehensive, ranging from minor errors that do not affect the tax amount to serious errors directly related to the tax code, amount, and tax rate; from cases occurring individually to cases occurring in a series within the same month; and even situations requiring repeated processing on the same original invoice.
Understanding and correctly applying these principles right from the time Circular 91/2026 was issued will help accountants and businesses proactively handle erroneous invoices accurately, minimizing risks regarding invoice validity and issues arising during tax settlement later on.
If businesses require direct advice and support in handling erroneous invoices, filing and settling taxes in accordance with the latest regulations, the solution is... hire accounting services By partnering with specialized, experienced units like MAN, you can receive expert support, minimize risks, and save operational time.
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Responsible for production and professional content review by: Mr. Le Hoang Tuyen – Founder & CEO of MAN – Master Accountant NetworkHe is a CPA Vietnam auditor with over 30 years of in-depth experience in accounting, auditing, taxation, and corporate legal consulting.
Frequently Asked Questions about the principles for handling erroneous invoices according to Circular 91/2026
Is it mandatory to reissue an invoice with an incorrect buyer's name or address?
No. If the invoice only contains errors in the buyer's name, address, or other details, but not in the tax identification number, amount, tax rate, tax amount, or goods, the seller does not need to reissue the invoice. The seller only needs to notify the buyer and send Notification Form No. 04/SS-HĐĐT to the tax authority.
What should I do if the tax identification number on the invoice is incorrect?
This is a case of error affecting the mandatory content of the invoice. The seller has one of two options: issuing an adjustment invoice or issuing a replacement invoice, depending on the agreement with the buyer.
Should you issue an adjustment invoice or a replacement invoice?
Circular 91/2026 allows sellers to choose freely. Essentially, an adjustment invoice only addresses the difference from the original invoice, while a replacement invoice replaces the entire content of the incorrect invoice. Accountants should base their decision on the extent of the error and reach an agreement with the buyer before making a choice.
What should be done if an invoice has already been adjusted or replaced but errors are still discovered?
Continue issuing adjustment invoices or replacement invoices in accordance with regulations. For replacement invoices, the invoices follow a sequence F0, F1, F2, F3,… Fn. For adjustment invoices, the value is added together F0 + F1 + F2 + F3,…+ Fn. Under no circumstances should previously issued adjustment invoices be canceled.
After correcting the erroneous invoice, is it necessary to re-file the tax return?
Yes. After issuing an adjustment or replacement invoice, the business must declare it in accordance with the law on tax management and VAT, ensuring that it accurately reflects the actual transaction and avoids discrepancies between the invoice and the tax return.
