The timing of invoicing for advertising services is a matter of considerable confusion for many accountants, especially with advertising contracts that arise continuously on a monthly or campaign basis. Decree 254/2026/ND-CP Effective from July 1, 2026, advertising services are required to issue electronic invoices; however, for television advertising and online newspaper advertising, invoices must be issued upon completion of data reconciliation, but no later than the 7th of the following month or no later than 7 days from the end of the agreed-upon period. This article provides a comprehensive overview of the legal basis, how to determine the agreed-upon period, cases of exemption from electronic invoices for digital advertising for foreign customers, and practical notes to help businesses and accountants avoid errors when issuing invoices.
Why is determining the correct time to issue invoices for advertising services important?
Imagine the following scenario: An advertising agency signs a contract to provide digital advertising services to a business for three consecutive months. Should the agency issue invoices immediately at the end of each campaign, monthly, or wait until both parties have reconciled their accounts before issuing invoices? This is a question many accountants in charge of advertising services face.
Incorrectly determining the timing of advertising service invoices is not just a simple operational error. It can lead to a series of consequences:
- The selling company was fined for administrative violations related to issuing invoices at an incorrect time.
- The tax authorities may reassess revenue and the timing of revenue recognition for tax purposes if discrepancies are discovered.
- Businesses that purchase advertising services risk having their expenses disallowed for tax deduction purposes due to invoices being invalid in terms of timing.
- This affects the reputation and long-term partnerships between parties in the advertising service supply chain.
From July 1st, 2026, regulations regarding the timing of invoice issuance for advertising services have been clarified in Decree 254/2026/ND-CP, providing businesses and accountants with a specific legal basis for consistent application.
Legal basis for regulations on advertising service invoices
Decree 254/2026/ND-CP on electronic invoices and documents
The most important legal document regulating this issue is Decree 254/2026/ND-CP, which came into effect on July 1, 2026. This decree stipulates the principles for the creation, management, and use of electronic invoices and documents, including specific provisions for particular service sectors, such as advertising services.
Advertising Law 2012
Besides Decree 254/2026/ND-CP, the 2012 Advertising Law is also an important basis for determining the rights and obligations of advertising service businesses, serving as a basis for comparison with the responsibility of issuing invoices according to tax and accounting laws.
Is it mandatory for advertising services to issue invoices?
Yes, according to current regulations, advertising services are required to issue invoices.
Specifically, based on Clause 1, Article 4 of Decree 254/2026/ND-CP, which stipulates the principles for the creation, management, and use of electronic invoices and documents, the following applies:
When selling goods or providing services, sellers must issue electronic invoices to buyers (including cases where goods and services are used for promotions, advertising, samples; goods and services used for giving, gifting, exchanging, paying as wages to employees, and internal consumption; goods exported in the form of loans or borrowings) and cases where invoices are issued as prescribed by the Minister of Finance, except for cases where electronic invoices are not required as stipulated in Article 7 of this Decree.
At the same time, electronic invoices must conform to standard data formats and must contain all the information required by tax and accounting laws, ensuring that they fully and truthfully reflect the economic transactions that have occurred. The seller is legally responsible for the accuracy of the issued invoice.
Therefore, when providing advertising services, whether it's television advertising, online newspaper advertising, or digital advertising on online platforms, the seller (the advertising service provider) must issue an electronic invoice to the buyer. The next issue that accountants need to understand is the specific timing for issuing advertising service invoices, as this is a unique aspect compared to other types of services.
The latest regulations stipulate the correct time for issuing invoices for advertising services.
In general, for regular services, the time of invoicing is the time when the service is completed, regardless of whether payment has been received or not. However, for certain sectors with specific characteristics involving large and frequent transactions, requiring time for data reconciliation between businesses and customers/partners, Decree 254/2026/ND-CP has specific regulations to facilitate the practical operations of businesses. Television advertising services and online newspaper advertising services are two of the service groups to which this special mechanism applies.
Time of invoice issuance for television advertising services
Based on point a, clause 4, Article 9 of Decree 254/2026/ND-CP, which regulates the timing of invoice issuance for certain specific cases, listing a series of specific service groups requiring time for data reconciliation, including services directly supporting air transport, television services, television advertising services, e-commerce services, telecommunications services, banking services, and many other service groups sold on a regular basis to corporate and organizational customers.
For this group of services, the regulations state:
The time of invoicing is the time when data reconciliation between the parties is completed, but no later than the 7th day of the month following the month in which the service was provided, or no later than 7 days from the end of the agreed period.
In other words, businesses providing television advertising services are not required to invoice immediately after each advertisement broadcast, but are allowed to wait until they have completed data reconciliation with the client. However, regardless of whether the reconciliation is completed early or late, the latest time for invoicing must still comply with regulations, not exceeding the 7th day of the following month, or not exceeding 7 days from the end of the agreed period.
Time of invoice issuance for online newspaper advertising services
Similar to television advertising services, advertising services on online news websites are also listed among the service groups subject to data reconciliation mechanisms under point a, clause 4, Article 9 of Decree 254/2026/ND-CP.
Accordingly, for advertising services on online newspapers, the time of issuing the advertising service invoice is also the time of completing the data reconciliation between the parties, but no later than the 7th day of the month following the month in which the service was provided, or no later than 7 days from the end of the agreed period – completely consistent with the principle applied to television advertising services.
This shows that Decree 254/2026/ND-CP has achieved uniformity in handling types of advertising services that arise frequently on mass media, facilitating both service providers and users of advertising services in managing cash flow and accounts receivable.
See more: Invoices must be issued in accordance with Decree 254/2026/ND-CP.
The concept of the conventional period in invoicing for advertising services.
An important concept to note when understanding the timing of invoicing for advertising services is the agreed-upon period. According to point a, clause 4, Article 9 of Decree 254/2026/ND-CP:
The agreed-upon period for calculating the quantity of goods and services supplied is based on the agreement between the seller of goods or service and the buyer.
Therefore, the agreed-upon period is not a fixed timeframe predetermined by law, but rather a mutually agreed-upon time between the two parties, the advertising service provider and the client, usually clearly stated in the advertising service contract. This is a point that accountants need to pay special attention to when drafting and reviewing contracts, because the agreed-upon period will be the direct basis for calculating the deadline of "no later than 7 days from the end of the agreed-upon period".
An example illustrating how to determine when to issue an invoice for advertising services.
To better understand how to apply the above regulation in practice, let's consider the following two scenarios with MAN – Master Accountant Network:
Situation 1: Company A, a television advertising service provider, signed a contract to provide advertising broadcasting services to Company B in August 2026. The two parties agreed to reconcile the data on September 3rd, 2026, and complete the reconciliation on that date. According to regulations, the invoice date will be September 3rd, 2026, while the reconciliation completion date is within the permitted limit of no later than September 7th, 2026 (the 7th day of the month following the month in which the service was provided).
Situation 2: Similarly, with Company A and Company B as above, but the data reconciliation process was delayed due to a dispute over the data, and the two parties only reached an agreement on September 20, 2026. In this case, Company A must still issue the invoice no later than September 7, 2026, in accordance with the regulations on the timing of issuing invoices for advertising services, and cannot wait until the reconciliation is completed to issue the invoice, in order to avoid violating the regulations on the timing of invoice issuance.
In cases where the internal accounting department lacks the resources to keep up with new regulations, the company may consider other options. hire accounting services Professionalism is key to ensuring all advertising service invoices are prepared on time and in accordance with regulations.
Cases where electronic invoices are not required for digital advertising services.
Besides the group of television advertising and online newspaper advertising services that must comply with regulations on the timing of invoice issuance as analyzed above, the Decree also stipulates some exceptions where electronic invoices are not required.
Based on Clause 2, Article 7 of Decree 254/2026/ND-CP, the following cases are exempt from the use of electronic invoices:
Household businesses and individual businesses with income from real estate rental activities; income from providing digital content products and services related to entertainment, video games, digital films, digital photos, digital music, and digital advertising to organizations and individuals abroad.
Therefore, for household businesses and individual businesses with income from digital advertising activities for organizations and individuals abroad, the use of electronic invoices is not required. This is an important exception that many individuals doing business in the digital advertising field, especially those earning income from cross-border advertising platforms, need to understand to avoid confusion with the obligation to issue invoices applicable to organizations and businesses providing advertising services domestically.
It should be noted that this exemption only applies to household businesses and individual businesses with clients who are organizations or individuals abroad. For domestic businesses and organizations providing advertising services, or providing advertising services to domestic clients, they must still fully comply with the regulations regarding the timing of invoice issuance for advertising services as presented in the sections above.
Rights and responsibilities of advertising service providers
According to the regulations at Article 13 of the 2012 Advertising LawAdvertising service providers have the following rights:
- Deciding on the form and method of conducting advertising services business;
- Advertisers must provide truthful and accurate information about the organization, individual, product, goods, or service being advertised, as well as relevant documents related to the advertising conditions;
- Participate in providing input during the development of local advertising plans and receive information from the local advertising authority regarding outdoor advertising plans;
- Request for evaluation of advertising products.
These rights come with corresponding responsibilities in fulfilling all obligations regarding invoices and documents as stipulated by tax and accounting laws. Specifically, advertising service providers, as service sellers, are legally responsible for the accuracy of the invoices issued and must ensure compliance with the regulations on the timing of invoice issuance for advertising services as stipulated in Decree 254/2026/ND-CP. Understanding both rights and obligations will help advertising service businesses operate legally, minimizing tax and invoice risks during their operations.
Some points to note when issuing invoices for advertising services to avoid errors.
Based on the above legal regulations, accountants in media and advertising companies need to note the following points to ensure compliance with the correct timing for issuing invoices for advertising services, avoiding risks during tax settlement:
- Closely monitor the latest deadline: Even if data reconciliation is not yet complete, businesses must issue invoices no later than the 7th of the month following the month in which the service was rendered, or no later than 7 days from the end of the agreed-upon period. This is a mandatory deadline; businesses cannot use the excuse of incomplete reconciliation to delay invoice issuance beyond this timeframe.
- Clearly define the billing period in the contract: Since the billing period is mutually agreed upon by both parties, businesses should specify this clearly in the advertising service contract, providing a solid legal basis for determining the invoicing date.
- Distinguishing between advertising service categories: Not all types of advertising services are subject to the data reconciliation mechanism under point a, clause 4, Article 9 of Decree 254/2026/ND-CP. This regulation only applies to television advertising services and online newspaper advertising services sold on a fixed-term basis to corporate and organizational clients. For other advertising services not included in this list, accountants should apply the general principle of issuing invoices at the time the service is completed.
- Note regarding individuals and businesses providing digital advertising services to foreign entities: If the business or individual is exempt from using electronic invoices according to Clause 2, Article 7 of Decree 254/2026/ND-CP, they must maintain complete records and documents proving that the customer is an organization or individual located abroad, for explanation purposes when requested by the tax authorities.
- Regularly review internal invoicing processes: Businesses should establish internal control procedures, assigning specific responsibilities to the accounting and sales departments for monitoring reconciliation progress and ensuring no invoice deadlines are missed. For agencies with a large volume of transactions and simultaneous debt reconciliation with multiple clients, using a system is essential. full accounting service With specialized and experienced units like MAN – Master Accountant Network, the process of reconciliation and invoice issuance deadlines will be closely monitored, minimizing the risk of errors regarding deadlines.
Conclude
In summary, from July 1st, 2026, according to Decree 254/2026/ND-CP, advertising services are required to issue electronic invoices, except for business households and individuals with income from digital advertising for organizations and individuals abroad. Specifically, for the issuance of invoices for advertising services in the television and online newspaper advertising categories, businesses may apply a data reconciliation mechanism, but must still ensure that invoices are issued no later than the 7th day of the month following the month in which the service occurred, or no later than 7 days from the end of the agreed-upon period with the customer.
To comply with this regulation, businesses and individuals providing advertising services need to proactively review contracts, debt reconciliation procedures, and internal invoicing processes, while regularly updating relevant legal documents to avoid unnecessary errors.
If you are still unsure how to apply the regulations to your specific business situation, please Contact MAN – Master Accountant Network For detailed support and advice, and for large businesses with many complex advertising contracts requiring periodic reconciliation, the solution... hire chief accountant It is also a worthwhile option for comprehensively monitoring the invoicing process and tax compliance.
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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 When Advertising Services Should Be Invoiced
Do advertising services require invoices?
Yes. According to Clause 1, Article 4 of Decree 254/2026/ND-CP, when providing advertising services, the seller must issue an electronic invoice to the buyer, even if the service is used for promotion, gifts, donations, or internal consumption, except for cases that are exempt from the use of electronic invoices according to Article 7 of this Decree.
When is the invoice for television advertising services issued?
This is the time when data reconciliation between the parties is completed, but no later than the 7th day of the month following the month in which the service was provided, or no later than 7 days from the end of the agreed period.
Is the timing of invoicing for online newspaper advertising services the same as for television advertising?
Yes. Advertising services on online newspapers are listed in the same group as television advertising services under point a, clause 4, Article 9 of Decree 254/2026/ND-CP, so the same principle applies: invoicing is issued at the time of data reconciliation, no later than the 7th day of the following month or no later than 7 days from the end of the agreed period.
If the data reconciliation is not yet complete, can a business wait until the reconciliation is finished before issuing an invoice?
No. According to regulations, the deadline is no later than the 7th of the following month or no later than 7 days from the end of the agreed-upon period. Even if the reconciliation is not yet complete, businesses must still issue invoices by this deadline to avoid violating regulations regarding the timing of invoice issuance.
For advertising services that do not fall under the categories of television or online newspaper advertising, how is the invoice date determined?
For advertising services not included in the list subject to the reconciliation mechanism under point a, clause 4, Article 9 of Decree 254/2026/ND-CP, businesses shall apply the general principle that the time of invoice issuance is the time of completion of service provision, regardless of whether payment has been received or not.
