Guidance on Invoice Timing and State Treasury Payment Documents for Public Healthcare Units
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The Ministry of Finance responds to a question about e-invoice timing and required documentation for State Treasury payments in connection with drug procurement contracts by state-budget healthcare units. The question asks whether a seller may issue an invoice after acceptance/handover, when the purchasing unit has not yet received payment from the State Treasury. Per official guidance, the State Treasury disburses funds to budget-spending units upon receipt of the required documents under Decree No. 347/2025/ND-CP. The payment request file does NOT include invoices, acceptance records, or contracts. The State Treasury does not receive or verify these documents. Under State Budget Law No. 89/2025/QH15, the head of a budget-spending unit is responsible for ensuring lawful, efficient use of the budget and compliance with spending conditions. For specific guidance on investment project reporting procedures and forms, units should contact the competent investment registration authority directly.
Guidance on Invoice Timing and State Treasury Payment Documentation
Source: Ministry of Finance (policy Q&A) Inquiring unit: State-budget healthcare unit
The Question
Under Decree 70/2025/ND-CP (amending Decree 123/2020/ND-CP), invoices must be issued at the time of ownership/use transfer. Public healthcare units receive payment via State Treasury with its own process - can invoices be issued after the acceptance/handover date to fit the payment workflow?
Ministry of Finance Response
1. Payment documentation for State Treasury Per Articles 58(3),(4) of State Budget Law No. 89/2025/QH15 and Item 4, Article 6(3) of Decree No. 347/2025/ND-CP:
- Required documents: approved budget estimate, payment transfer voucher, advance payment request (if applicable), list of beneficiaries
- NOT required: invoices, acceptance records, contracts
- The State Treasury does not accept or verify these documents
2. Responsibility of budget-spending units
- The unit head is responsible for lawful, efficient budget use
- Must satisfy spending conditions under Article 12(2) of State Budget Law No. 89/2025/QH15
3. Investment project reporting procedures
- Contact the competent investment registration authority for specific guidance
Practical Notes
- Invoice timing must still comply with Decree 70/2025/ND-CP (at point of ownership transfer)
- State Treasury checks only financial documents, not invoices or contracts
- Healthcare units must reconcile invoices with acceptance records independently