From July 1st, 2026, Article 7 of Circular 91/2026/TT-BTC stipulates five indicators to identify high-risk taxpayers during the electronic invoice registration process. These indicators focus on the representative/owner, suspicious transactions, registered address, the status of the related taxpayer, and other risk management indicators. However, the appearance of one indicator should not be interpreted as immediate rejection of the registration; the process still includes steps for explanation, additional information, or verification as per Article 6.
Basis for applying this article
- Law on Tax Administration 108/2025/QH15
- Decree 254/2026/ND-CP
- Circular 91/2026/TT-BTC
- Circular 94/2026/TT-BTC
5 criteria for identifying high-risk taxpayers when registering for electronic invoices.
Starting July 1, 2026, the tax authorities will implement an automated data reconciliation mechanism to identify high-risk cases early. Here are five specific signs:
| Criteria | Content to understand | Entity under consideration
|
|---|---|---|
| 1 | Regarding the fraudulent activities involving the buying and selling of invoices, a conclusion has been reached. | Owner/Representative |
| 2 | Included in the list of suspicious transactions. | Owner/Representative |
| 3 | The registered office address is considered a risk indicator. | Address |
| 4 | Related to other taxpayers with tax identification number status or violations of regulations. | Owner/Representative + Related Taxpayer |
| 5 | Other indicators according to the risk management mechanism and with notification. | Taxpayer |
The representative/owner involved in the fraud and trading of invoices.
This criterion does not simply assess whether a person is listed as the owner of multiple businesses. The decisive factor is that the person simultaneously holds a role in a taxpayer for which a competent state authority has concluded that the individual engaged in fraudulent activities or the buying and selling of invoices. According to Article 7, the subjects considered are the owner or representative of the registered business. It is important to note that there must be an official written "conclusion.".
The representative/owner on the list has engaged in suspicious transactions.
The second indicator relates to the list of suspicious transactions under anti-money laundering laws, not all transactions of large value or occurring frequently. This provision refers to anti-money laundering laws and applies to the owner or representative of the business.
This should not be misunderstood:
- Making large, non-automatic transfers carries risks.
- Legitimate international payment transactions are not considered risky.
- The high frequency of transactions due to industry specifics does not necessarily mean they are suspicious.
The registered address is considered to be at risk.
The registered address is identified as risky when it falls into two main categories: having no specific address within administrative boundaries; or being located in an apartment building, except for areas/apartments legally permitted for business purposes. In this case, the regulations note an exception for individual businesses.
Businesses can review:
- Is the registration address specific enough?.
- Are the address details consistent across the records?.
- If the office is located in an apartment building, is that area permitted for business use?.
The representative/owner associated with the taxpayer has a risk status or violation.
The evaluation model for this criterion is as follows:
Company A is registering
↓
Owner/Representative X
↓ (also)
Business owner/representative B
↓
B falls under the state or behavior defined in Article 7.
The cases mentioned currently include businesses that have ceased operations but have not completed the procedures for terminating their tax identification number (TIN), businesses not operating at their registered address, or businesses engaging in tax, invoice, or document violations as stipulated in Circular 94/2026/TT-BTC. This connection may lead to the registration being considered under criterion 4 if it meets the conditions of Article 7.
Other indicators according to the risk management mechanism
The fifth criterion should not be interpreted as meaning that the tax authority can freely add any indicators. Article 7 links this group to the compliance management and risk management mechanism under Circular 94/2026/TT-BTC and requires notification for taxpayers to be aware and provide explanations. Circular 94/2026/TT-BTC is the current document on compliance management and risk management in tax administration effective from July 1, 2026.
So, if any of the above signs appear, will the tax authorities immediately refuse the registration of the electronic invoice?
If a business exhibits one of these five signs, will its application for e-invoices be immediately rejected?
The appearance of a mark in Article 7 should not be interpreted as automatically leading to the refusal of electronic contract registration. Article 7 refers this case to the procedure in point c, clause 2, Article 6, which includes mechanisms for explanation, supplementary information/documents, and verification.
Verify registration information
The new process includes an automated data reconciliation step; current sources describe this step as being completed within one business day of receiving the registration. Businesses can refer to additional information on this process. Electronic invoice registration process.
Detecting signs of risk
If indications under Article 7 appear, the tax authorities will proceed to the risk assessment step as stipulated in Article 6.
Explanation/Supplementation or Verification
Circular 91 stipulates a deadline of 3 working days from the date of receiving the notification for taxpayers to provide explanations and supplementary information and documents.
The result is either accepted or rejected.
- If the explanation is accepted or verified that the business is operating at the address, the tax authority will issue an acceptance notice.
- Failure to provide an explanation, failure to provide an explanation within the specified timeframe, or inability to verify the activity at the address may result in a rejection notice stating the reasons as required by regulations.
Registration ➔ Comparison and verification of Article 7 ➔ Explanation/verification ➔ Results
What should businesses review before registering to use e-invoices?
Owners and representatives
Businesses can proactively verify whether the registration information is accurate and consistent. A key point to note is to examine the legal entities that the individual manages/owns, thereby identifying any related legal entities with unusual circumstances that the business is aware of.
Head office address
Businesses can review:
- Is the registration address specific enough?.
- Are the address details consistent across the records?.
- If the office is located in an apartment building, is that area permitted for business use?.
Related legal entities
In this case, the business needs to review to ensure it does not violate any related risks; you can refer to additional information on this topic. invoice risk indicators.
Data for explanation
Since Article 6 allows tax authorities to request clarification and additional information, businesses should ensure that legal data, addresses, and actual operations related to the registration content can be verified when necessary.
What should businesses do when they receive requests for explanation or verification?
Step 1. Read the instructions carefully.
Clearly identify which data needs to be explained, the deadline, and the content/documents requested by the tax authorities.
Step 2. Identify the information to be compared.
Focus on verifying the representative, owner, address, operational status, and related information to ensure they meet the requirements.
Step 3. Prepare data within the correct scope.
You should only prepare information and documents that are within the scope required for verification, avoiding submitting unnecessary documents.
Step 4. Meet the deadline.
In cases where regulations stipulate, businesses have 3 working days from the date of receiving the notification to provide an explanation.
Step 5. Monitor the results.
Continue monitoring the tax authority's processing results to see whether your application has been accepted or rejected according to the procedure.
Are these five criteria the complete criteria for assessing invoice risk and tax risk?
No. The five indicators in Article 7 have a specific scope of registering for the use of electronic invoices. Tax risk management and identifying risky invoices during operations have a much broader scope.
| Content | Scope
|
|---|---|
| 5 signs of Article 7 | Steps to register for e-invoices |
| Invoice risk criteria | Invoice-related activities and transactions |
| Tax risk management | Broader scope of tax compliance/risk management |
Frequently asked questions
Is it sufficient to meet just one of the five criteria to be considered under the risk assessment mechanism?
According to Article 7, yes, the appearance of any indication will cause the file to be transferred to the risk management mechanism.
Does having an office in an apartment building automatically mean a higher risk?
No. The scope and exceptions to criterion 3 must be considered correctly (such as the area permitted for business or exceptions for individual businesses).
Is it considered risky for a representative to simultaneously own and manage multiple companies?
It's not just about representing multiple businesses. Specific conditions outlined in the relevant criteria must be met.
When asked to provide an explanation, how long do taxpayers have to do so?
In the case referred to in point c, clause 2, Article 6, the deadline is 3 working days from the date of receiving the notification.
In the course of operations, businesses can apply technological solutions to manage invoice risks safely and automatically. Bizzi Bot To proactively cross-check data with partners.
Conclude
The five criteria in Article 7 of Circular 91/2026/TT-BTC help businesses identify cases that may be subject to risk assessment when registering to use electronic invoices. However, the appearance of a warning sign does not necessarily mean the application will be immediately rejected; businesses still need to proactively review legal information, representatives, addresses, related legal entities, and prepare complete and timely explanatory data.
During operations, as the number of partners and invoices increases, manual verification can make it difficult for businesses to detect anomalies early. Bizzi Bot – an invoice processing and invoice risk management solution – helps businesses centralize data, reconcile invoice and supplier information, thereby enabling the Finance and Accounting department to proactively identify risks and improve compliance control.
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