Cash Register Invoice Errors That Do Not Affect Tax Code or Amounts: Which Correction Rule Applies Under Circular 91/2026/TT-BTC?
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Based on:91/2026/TT-BTC - Ministry of Finance
This explanation was generated by AI and checked by an automated AI review, not by a human expert. It is not legal, tax or accounting advice and may contain errors. Check the official document before you rely on it.
A taxpayer asked the Ministry of Finance how to handle an e-invoice generated from a cash register when it contains errors in the buyer's name, address, amount in words, or other content, but NOT in the tax code, invoice amount, tax rate, tax amount, or goods listed. The question was whether such errors could be corrected under point (a), Clause 1, Article 10 of Circular 91/2026/TT-BTC - which only requires notifying the buyer and the tax authority via Form 04/SS-HDDT, with no need to reissue the invoice - given that point (c) of the same clause separately requires cash-register e-invoices with errors to be replaced with a new invoice. In its reply, the tax authority quoted the legal basis in full: Circular 91/2026/TT-BTC (effective July 1, 2026), Decree 254/2026/ND-CP, and Law on Tax Administration 108/2025/QH15 governing e-invoices and e-documents, and restated points (a) and (c) of Clause 1 and point c.2 of Clause 5 of Article 10 (which covers assets requiring registered ownership: if goods already registered under the buyer's name are returned, the buyer - not the seller - issues the return invoice). However, the reply did NOT give a direct yes/no answer to the taxpayer's specific scenario; it only instructed the taxpayer to "apply the regulations based on the actual circumstances of the business." In practice, it is worth noting that point (c) of Clause 1 specifically singles out cash-register e-invoices (and invoices for assets subject to ownership registration) as requiring a replacement invoice for any error, unlike the general rule in point (a), except for the goods-return case under point c.2 of Clause 5. Because the tax authority's answer was non-committal, businesses and household businesses using cash-register invoices should exercise caution and contact their managing tax office directly for specific guidance before acting.
The Question
Under Clause 1, Article 10 of Circular 91/2026/TT-BTC (effective July 1, 2026):
- Point (a): If an issued e-invoice contains errors in content such as name, address, amount in words, or other details, but NOT in the tax code, the invoice amount, the tax rate, the tax amount, or the goods listed, the seller only needs to notify the buyer that the invoice was issued incorrectly - no reissuance is required. The seller notifies the tax authority using Form 04/SS-HDDT (Appendix III of the Circular).
- Point (c): If the erroneous e-invoice is a cash-register e-invoice, or an e-invoice for the sale of goods that are assets subject to registered ownership/use rights, the seller must issue a replacement invoice for the erroneous one, except for the case under point c.2, Clause 5, Article 10.
The taxpayer asked: if a cash-register invoice has errors in content such as name, address, amount in words, or other details - but not in tax code, invoice amount, tax rate, tax amount, or goods - can it be handled under point (a) of Clause 1 (notify only, no reissuance required)?
The Tax Authority's Reply
Based on Circular 91/2026/TT-BTC of the Ministry of Finance implementing certain provisions of the Law on Tax Administration, and Decree 254/2026/ND-CP of the Government detailing certain provisions and measures to organize and guide implementation of Law on Tax Administration No. 108/2025/QH15 regarding e-invoices and e-documents:
Clause 1, Article 10 on handling erroneous issued e-invoices states:
"Article 10. Handling of issued e-invoices
- Where an issued e-invoice is found to be erroneous (including e-invoices assigned a tax authority code, and code-free e-invoices whose data has been transmitted to the tax authority), the seller shall handle it as follows:
a) Where the error concerns invoice content such as name, address, amount in words, or other content, but NOT the tax code, the invoice amount, the tax rate, the tax amount, or the goods listed on the invoice, the seller notifies the buyer that the invoice was issued incorrectly and does not need to reissue the invoice. The seller notifies the tax authority of the erroneous e-invoice using Form 04/SS-HDDT, Appendix III of this Circular;
...
c) Where the erroneous e-invoice is a cash-register e-invoice, or an e-invoice for the sale of goods that are assets subject to registered ownership/use rights, the seller shall issue a replacement invoice for the erroneous one, except for the case specified at point c.2, Clause 5 of this Article;"
Point (c), Clause 5, Article 10 on handling issued e-invoices in certain cases states:
"c.2) Where the goods are assets subject to registered use/ownership rights under law, and the asset has already been registered in the buyer's name, then upon returning the goods in a manner consistent with applicable law, if the buyer is an e-invoice user, the buyer shall issue a return invoice to the seller;"
The tax authority's conclusion: "Based on the above regulations, the taxpayer is requested to apply the regulations in accordance with the actual circumstances of the business."
The tax authority did not give a direct "yes" or "no" answer to the specific scenario raised; it merely restated the relevant legal provisions verbatim and asked the taxpayer to self-assess.
Support Contact
For further questions, taxpayers may contact: Case officer Trinh Thi Thanh Huong, phone 0904851345, Enterprise Management Team No. 1, No. 09 Phan Chu Trinh, Hac Thanh Ward, Thanh Hoa Province. The reply was posted on August 7, 2026.
Editorial Note
The Ministry of Finance's original reply merely quoted the law without directly resolving the apparent tension between point (a) (a general rule for any e-invoice with non-material errors) and point (c) (a specific rule requiring a replacement invoice for cash-register e-invoices, regardless of error type). Because Article 10 sets out point (c) as a distinct case separate from point (a), the most cautious reading is that a cash-register invoice with an error - even a non-material one such as name or address - still falls under point (c) and requires a replacement invoice, except for the registered-asset return scenario in point c.2, Clause 5. Businesses should confirm directly with their managing tax office before acting on this.