Troubleshooting when using electronic invoices is a topic of great interest to many businesses and accountants. Decree 254/2026/ND-CP Officially effective from July 1, 2026. During the process of creating, issuing codes, or transmitting electronic invoice data, technical issues may arise from the seller, the tax authority, or the service provider. Understanding the regulations in Article 14 of Decree 254/2026/ND-CP will help businesses handle each situation correctly, meet deadlines as prescribed, and ensure compliance with tax management laws. This article summarizes all cases of handling incidents when using electronic invoices according to legal regulations, making it easy for you to apply them in practice.
Why do accountants need to know how to handle problems when using electronic invoices?
Electronic invoices have become a mandatory tool in the buying and selling of goods and services for most businesses today. However, because they are entirely dependent on information technology systems, electronic invoices are susceptible to disruptions at any time, such as transmission errors, code issuance system errors, infrastructure errors of the service provider, or even unforeseen circumstances beyond control.
Without a thorough understanding of the troubleshooting process for using electronic invoices, businesses can easily fall into situations of delayed invoice issuance, delayed tax declaration, or even be considered in violation of tax obligations, even if the cause stems from objective factors.
Risks of not knowing how to properly handle electronic invoice issues.
When problems arise and accountants don't know how to handle them using electronic invoices according to legal procedures, businesses may face many consequences:
- Delays in preparing and sending invoices to customers.
- This affects the timing of revenue and expense recognition.
- In some cases, compliance with reporting obligations may be misjudged if there is no valid evidence or documentation to support the claim.
Therefore, proactively understanding regulations and preparing contingency plans is essential for all accounting and finance departments within a business.
Legal basis applicable when handling electronic invoice issues.
The entire content of the troubleshooting guide for using electronic invoices is specifically stipulated in Article 14 of Decree 254/2026/ND-CP, based on the platform. Law on Tax Administration No. 108/2025/QH15This is the latest legal document, replacing previous regulations, and applies uniformly to all organizations and individuals selling goods or providing services using electronic invoices, as well as tax authorities and organizations providing electronic invoice services. Adhering strictly to this legal basis helps accountants avoid misapplying outdated regulations that are no longer in effect.
See more: Full text of Decree 254/2026/ND-CP.
5 troubleshooting steps when using electronic invoices according to the latest regulations.
According to Article 14 of Decree 254/2026/ND-CP, the handling of incidents when using electronic invoices is divided into five main groups of situations, corresponding to each cause of the incident. Each case has a clearly defined handling procedure and responsibilities of the relevant parties.
Case 1: Problem originating from the seller of goods or provider of services.
This is the most common scenario in practice. Specifically:
Sellers of goods and services who are using electronic invoices with tax authority codes may encounter technical problems that prevent them from using these electronic invoices.
In this case, the procedure for troubleshooting when using electronic invoices is as follows:
- Sellers should immediately contact the tax authorities or the electronic invoicing service provider for assistance in resolving the issue.
- While waiting for the issue to be resolved, if the seller needs to use an electronic invoice with a tax authority code immediately, the seller can go directly to the tax authority to receive assistance in creating the invoice with the code.
For accountants, when faced with this situation, the first thing to do is to clearly identify whether the problem stems from the equipment, internal software, or the tax authority's system, and then choose the appropriate contact channel to minimize the disruption to invoice issuance.
Case 2: Problems with the tax authority's code issuance system.
The second case involves a malfunction within the tax authority's own electronic invoice issuance system, leading to widespread disruption in the issuance of codes. In this situation, the responsibility for resolving the issue related to the use of electronic invoices rests with the Tax Department, specifically:
- Activate the backup system to ensure that the code issuance process is not interrupted for an extended period.
- The Tax Department's website will publicly announce the scope of the impact, the start time of the incident, and the expected time for resolution.
- If necessary, the Tax Department may authorize a qualified electronic invoice service provider to issue the code on its behalf as prescribed.
Note: Corporate accountants should proactively monitor announcements on the Tax Department's website during this period to stay informed about the progress of corrective actions and avoid being caught off guard when urgent invoices need to be issued to customers.
Case 3: Technical infrastructure failure of the electronic invoicing service provider.
Many businesses currently use electronic invoices through intermediary service providers. When errors arise from the technical infrastructure of these organizations, the troubleshooting process for using electronic invoices is as follows:
- The organization providing electronic invoicing services is responsible for immediately notifying the seller of any technical issues.
- At the same time, the service provider must coordinate with the Tax Department to receive timely support in resolving the issue.
- Organizations providing electronic invoicing services must resolve issues as quickly as possible and provide support to sellers in creating electronic invoices to submit to the tax authorities for code issuance in the shortest possible time.
Case 4: The tax management information system experiences a technical error.
The fourth scenario occurs when the Tax Management Information System experiences a technical error, preventing it from receiving electronic invoice data without a code from the business. This is a central system-level incident affecting all economic organizations, other organizations, and electronic invoice service providers transmitting data. The specific procedures for handling this type of incident are as follows:
- During the system outage, economic organizations, other organizations, and electronic invoice service providers will temporarily not transfer invoice data without codes to the tax authorities.
- Within two working days from the date the Tax Department announces that the Tax Management Information System has returned to normal operation, the aforementioned organizations must complete the transfer of invoice data to the tax authority.
This is a crucial timeframe that accountants need to pay special attention to and remember accurately, because data transfer delays of more than two business days compared to the system's return to normal may no longer be considered a consequence of an objective incident.
Case 5: Incident due to force majeure
The most exceptional case in the regulations on handling incidents when using electronic invoices is force majeure. According to Clause 21, Article 4 of the Tax Administration Law No. 108/2025/QH15, events considered as force majeure include:
War, riots, strikes causing production or business interruptions, or risks not attributable to the seller's subjective cause or responsibility, prevent the seller or the tax authorities from creating, issuing codes, or transmitting electronic invoice data within the specified timeframe..
In this case, the troubleshooting procedure for using electronic invoices is as follows:
- Within 3 working days from the date the force majeure event is resolved, the seller is allowed to create and send electronic invoices to the tax authorities.
- The seller is responsible for maintaining complete accounting records of sales transactions occurring during the incident, and for retaining documentation proving the force majeure event in accordance with legal regulations.
In particular, Decree 254/2026/ND-CP also clearly affirms:
The delay in issuing, sending, and transferring invoices due to the reasons mentioned in all five cases above is considered a force majeure event according to tax management laws. This is an important basis for businesses to explain to the tax authorities when requested for inspection or verification.
A summary of key timelines to remember when troubleshooting issues with electronic invoices.
For ease of quick reference during operations, businesses can refer to the summary table of responsibilities and processing deadlines for each case below:
Summary of key timelines for troubleshooting when using electronic invoices.
| Type of incident | Primary responsibility for handling | Deadline/Important Note |
| Problem from the seller | The seller contacts the tax authorities or the service provider. | Go directly to the tax office if you need an invoice with a code urgently. |
| System failure in the tax authority's code issuance system. | Tax Department | Activate the backup system; make a public announcement on the website. |
| Infrastructure failure of the service provider | Organization providing electronic invoicing services | Notify the seller, coordinate with the Tax Department, and resolve the issue as quickly as possible. |
| Tax management information system error | The Tax Department announces that organizations are temporarily suspending data transfers. | Data transfer will take 2 business days after the system is back online. |
| Force majeure (war, riots, strikes, etc.) | Seller | Issue an invoice within 3 working days after the problem is resolved; retain supporting documentation. |
Important notes for proactively handling electronic invoice issues.
In addition to understanding the five specific cases mentioned above, businesses also need to build an internal management system or consider referencing existing ones. full accounting service We rely on specialized and experienced units like MAN – Master Accountant Network to ensure smooth operations and minimize legal risks.
Actively monitor notifications from the Tax Department and service providers.
In most cases of incidents related to the tax code issuance system or the tax management system, the tax authority is responsible for making a public announcement on the Tax Department's website.
Therefore, accountants should regularly check information from this official channel instead of relying solely on internal announcements or rumors, in order to accurately understand the start date and estimated time for resolving the issue.
Maintain complete records and documents proving the incident or force majeure.
In cases of force majeure, regulations require sellers to maintain accounting records and retain supporting documentation. Therefore, as soon as an incident occurs, businesses should proactively gather relevant evidence such as notifications from tax authorities, notifications from service providers, and meeting minutes (if any), to facilitate explanations later if necessary.
Conduct periodic reviews of contracts with electronic invoicing service providers.
Since the responsibility for resolving technical infrastructure errors and assisting sellers in troubleshooting issues when using electronic invoices rests with the service provider, businesses should review the terms in their service contracts regarding commitment to troubleshooting timelines and emergency support channels to ensure their rights are protected in the event of actual problems. external tax accountant It is also a solution that helps businesses stay up-to-date with new regulations, monitor and handle electronic invoice issues in a timely manner.
Conclude
Decree 254/2026/ND-CP has established a clear legal framework for handling incidents when using electronic invoices, covering issues ranging from seller-related problems, tax authority code issuance system failures, service provider infrastructure errors, tax management information system errors, to force majeure situations. Each case has specific procedures, responsibilities, and timelines. Understanding these regulations is key for accountants and businesses to proactively respond to incidents while ensuring compliance with the 2025 Tax Administration Law.
However, not all businesses have the resources to promptly update and professionally handle troubleshooting when using electronic invoices in all situations. If businesses want to reduce this burden, the solution is... hire accounting services This will help businesses always have a team of experts on hand, closely monitoring legal changes and handling any electronic invoice issues correctly and promptly.
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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 Troubleshooting When Using Electronic Invoices
According to Decree 254/2026/ND-CP, if the issuance, sending of invoices, or transfer of invoice data is delayed due to force majeure events as stated in Article 14, this is considered a force majeure event under the tax management law, provided that the enterprise complies with the deadline and retains complete supporting documentation as required.
When the tax authority's code issuance system experiences a technical problem, the Tax Department is responsible for activating the backup system, making a public announcement, and may authorize a qualified service provider to issue codes on its behalf during the repair period.
The regulations do not require sellers to obtain prior confirmation from a specific agency, but sellers are responsible for maintaining their own accounting records and retaining documentation proving the force majeure event as a basis for explanation when requested by the tax authorities.
In the event of force majeure as stipulated in Clause 21, Article 4 of the Tax Administration Law No. 108/2025/QH15, which prevents the seller or the tax authority from creating, issuing codes, or transmitting electronic invoice data within the specified timeframe, the seller may create and send electronic invoices to the tax authority within 3 working days from the date the problem is resolved. If the electronic invoicing issue persists, will businesses be penalized?
Who is responsible when the tax authority's code issuance system malfunctions?
In cases of force majeure, is confirmation from any agency required?
In cases of force majeure, how long does the seller have to create and send an electronic invoice?
