POS-Based electronic invoices: Mandatory requirements for restaurants

In recent times, regulations on electronic invoices generated from cash registers (POS-based e-invoices) have been strongly implemented by the tax authorities, particularly for restaurants, eateries, cafés, and F&B chains. Many businesses remain confused, or even mistakenly believe that this is merely encouraged rather than mandatory.

From a legal and accounting - tax advisory perspective, this article helps restaurants clearly understand when implementation is mandatory, how to apply it, and the risks of non-compliance.

1. What are POS-Based electronic invoices?

POS-based electronic invoices are invoices that:

• Are issued directly at the point of sale via a cash register or POS software
• Are connected to and transmit data directly to the tax authority
• Do not require the seller’s digital signature on each invoice
• Contain a tax authority code issued in real time or near real time

This type of invoice is designed to control retail revenue and prevent tax losses, especially in sectors with high volumes of cash transactions such as restaurants and food & beverage services.

2. Which restaurants are required to apply POS-Based E-Invoices?

Under current regulations and tax management orientations, restaurants, eateries, and F&B establishments are required to apply POS-based e-invoices if they fall into the following categories:

• Selling goods or providing services directly to end consumers
• Collecting payments on-site via cash, bank transfer, or e-wallets
• Using cash registers or POS software in business operations

This includes (but is not limited to):

• Restaurants, eateries, and dining establishments
• Cafes, coffee shops, milk tea shops
• F&B chains and franchised outlets
• Food and beverage businesses with large revenues or high transaction volumes

In practice, tax authorities are prioritizing inspections and conversion requirements for this sector.

3. How should restaurants issue invoices?

When applying POS-based electronic invoices, restaurants should note that:

• Every sales transaction must be invoiced
• Invoices must be issued at the time of payment
• Invoice data must be transmitted to the tax authority in the prescribed format
• Retail customers are not required to provide personal or tax information

This is fundamentally different from the previous practice of issuing invoices only upon customer request.

4. Common mistakes made by restaurants

Based on our advisory experience, common mistakes include:

• Issuing invoices only when customers request them
• Splitting revenue: issuing invoices for part of the revenue only
• Using POS systems that are not connected to the e-invoice system
• Continuing to use “standard” e-invoices instead of POS-based e-invoices

These errors pose significant risks when tax authorities reconcile revenue data, cash flows, and tax filings.

5. Risks of Non-Compliance

Restaurants that fail to apply or incorrectly apply POS-based e-invoices may face:

• Administrative penalties for invoice violations
• Back taxes on VAT and corporate income tax due to underreported revenue
• Classification as a high-risk taxpayer subject to frequent audits and inspections
• Negative impacts on business operations and brand reputation

For restaurant chains, these risks may extend across multiple outlets and tax periods.

6. What should restaurants prepare for proper implementation?

To ensure compliance and minimize risks, restaurants should:

• Review their business model and payment processes
• Assess whether their POS system supports e-invoice integration
• Register for POS-based e-invoice application with the tax authority
• Synchronize sales, accounting, and tax data
• Train cashiers and operational managers on proper invoice issuance procedures

7. Recommendations from legal and accounting advisors

We recommend that restaurants:

• Do not wait until being required by tax authorities to implement
• Do not treat this merely as a “software issue,” but as a mandatory tax obligation
• Proactively consult accounting and tax advisors to select solutions suitable for their business scale and model

POS-based electronic invoices are no longer a trend, but are becoming a mandatory requirement for restaurants and the food & beverage service sector. Proper and timely implementation not only ensures legal compliance, but also helps businesses:

• Improve revenue transparency
• Reduce risks of tax reassessment and penalties
• Standardize operational and financial management

For restaurants, compliance with POS-based e-invoices is not a cost, but an investment in stability and sustainable growth.

Related reading: How foreigners must comply with fire safety regulations when operating a restaurant in Vietnam.