The Vietnam Chamber of Commerce and Industry (VCCI) has just commented on the draft amendment to Decree 125/2020 on handling administrative violations in the field of tax and invoices, chaired by the Ministry of Finance. Accordingly, VCCI proposes not to fine business households violating some regulations on invoices.

Specifically, according to Decree 70/2025, business households/individuals with revenue of 1 billion VND/year or more must use electronic invoices from cash registers directly connected to tax authorities.

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VCCI assessed that this is a major shift in tax management, although necessary, it also poses many challenges in the implementation process.

The results of a quick survey by VCCI on 1,368 business households nationwide in June showed that 68% of households only had a preliminary understanding or were unclear about what to do, 21% did not understand the regulations at all. The most common difficulties were lack of technological skills (73%) and difficulty in changing old management habits (49%).

The above challenges, along with the specific nature of limited resources, have led to a situation where in the initial implementation phase, many business households easily violated some requirements related to invoices - especially errors in form such as: incorrect indicators, issuing invoices at the wrong time...

These are mainly unintentional errors due to unfamiliarity with the new process, lack of technological skills, not stemming from intentional violations or tax evasion.

Therefore, VCCI recommends that the drafting agency add a provision not to apply administrative sanctions to business households that violate regulations on form in the initial period, which can be considered for 2 years. Business households are responsible for correcting violations and paying the tax amount (if any) arising from these violations.

Article 24.3 of Decree 125/2020 stipulates administrative sanctions for cases of issuing invoices at the wrong time but not leading to delay in tax obligations.

According to businesses, issuing electronic invoices depends on the operation of the technology system. In many cases, this system may stop working or have errors due to objective reasons such as software errors, cyber attacks, etc. These situations may lead to issuing invoices at the wrong time, but in essence, businesses do not affect their tax obligations and the budget is not damaged.

VCCI believes that this behavior has a very low level and nature of violation. Therefore, it is recommended that the drafting agency amend the regulation to only impose a warning penalty for this behavior with the lightest fine. In addition, VCCI also recommends adding a penalty not to impose a penalty for not issuing an invoice if a penalty has been imposed for the act of falsely declaring and understating the amount of tax payable.