In fact, many small businesses selling retail, food, services or online business choose to summarize revenue and then issue combined invoices at the end of the month. This method helps reduce operations, especially for households with many small transactions during the day.
However, when tax management shifts strongly to relying on electronic data and real-time comparison, issuing invoices not related to the time of transaction is becoming a major risk point. Although total revenue is not hidden, late invoice issuance can still be identified as violating invoice regulations.
Legal regulations on the time of invoice preparation
According to Article 9 of Decree 123/2020/ND-CP of the Government on invoices and documents, amended and supplemented by Decree 70/2025/ND-CP, the time for issuing invoices is determined as follows:
- For goods sales, the time of invoice is the time of transfer of ownership or right to use goods to the buyer, regardless of whether money has been collected or not.
- For service provision, the time of invoice is the time of completion of service provision; in case of collecting money before or during service provision, the time of invoice is the time of money collection.
Thus, when goods have been delivered or services have been completed on the same day or week, the obligation to make invoices has arisen at that time. Condensing these transactions to issue one invoice at the end of the month is not consistent with the principle of the time of invoice issuance according to current regulations.
General invoices are only allowed within the scope of days
The law does not completely prohibit the issuance of general invoices, but only allows it within a narrow scope. Specifically, according to point a, clause 6, Article 9 of Decree 123/2020/ND-CP (amended and supplemented by Decree No. 70/2025/ND-CP), for retail activities of goods and services arising many times a day, sellers are allowed to make general invoices at the end of the day, accompanied by a detailed list of each transaction arising in that day.
This regulation does not extend to the synthesis of transactions of many days or months. Therefore, issuing combined invoices at the end of the month for all transactions arising in the month does not fall into the cases where synthetic invoices are allowed to be issued according to legal regulations.
True revenue but still fined at the wrong time
According to Decree 125/2020/ND-CP, amended and supplemented by Decree 310/2025/ND-CP, the act of making invoices at the wrong time according to the provisions of the law on invoices is an administrative violation and may be fined with money, depending on the number of violating invoices and the nature of the act.
Not stopping there, if late invoice issuance causes revenue to be recorded incorrectly in the tax calculation period, the management agency may request to adjust tax obligations and calculate late payment fees according to Article 59 of the Law on Tax Administration.
This means that even if business households do not evade taxes and do not make a shortfall in revenue, making invoices at the wrong time can still lead to financial and legal risks.
The right amount of money is not enough, it must be at the right time.
In the current tax management context, electronic invoice data, cash flow and transaction times are closely compared. Therefore, correct revenue is only a necessary condition, while the correct invoice issuance time is a sufficient condition to comply with the law.
For business households with many small transactions, issuing invoices immediately when transactions arise or issuing summary invoices at the end of the day with a statement is a more appropriate option than consolidating invoices at the end of the month.
Changing invoice-making habits not only helps business households reduce the risk of being penalized, but is also a necessary step to adapt to modern, transparent and data-based tax management methods.
