The Chief Accountant (Kế toán trưởng) appointment is a statutory requirement for foreign-invested enterprises (FDI) operating in Vietnam under Accounting Law No. 88/2015/QH13 (as amended by Law No. 56/2024/QH15).
The Chief Accountant is more than an internal finance lead. The role is a statutory office with professional independence, and the holder answers personally for their own violations; the legal representative also bears direct responsibility for accounting violations. An enterprise may instead decide to hire a Chief Accountant service. The rules sit within the wider FDI accounting and reporting framework, and this guide covers appointment timelines, qualifications and personal liability.
1. Legal Framework & Appointment Timelines
Accounting leadership appointments are governed by the Accounting Law, Decree No. 174/2016/ND-CP, Circular 99/2025, and penalty enforcement under Decree No. 41/2018/ND-CP (as amended by Decree 132/2026/ND-CP).
The 12-Month Limit for a Person in Charge of Accounting
Under Decree 174, an enterprise that cannot appoint a Chief Accountant immediately may take these steps:
- First 12 Months: The enterprise may assign a Person in Charge of Accounting (Phụ trách kế toán) instead of appointing a Chief Accountant. The decree sets the 12-month cap but no start date.
- After 12 Months: The company must formally appoint a certified Chief Accountant or contract an outsourced Chief Accountant from a licensed accounting practice.
- Exemption Rule: Only micro-enterprises defined under the Law on Support for Small and Medium Enterprises are exempt from the 12-month limit. FDI enterprises above micro-enterprise thresholds must fully comply.
| Evaluation Criterion | Person in Charge of Accounting (Temporary) | Chief Accountant (Statutory) |
|---|---|---|
| Legal Basis | Accounting Law; Decree 174 | Accounting Law |
| Certification Required | Same standards as a Chief Accountant (Article 54 of the Law on Accounting) | Chief Accountant training certificate |
| Signing Authority | Signs financial statements during the 12-month term | Statutory sign-off with personal legal liability |
2. Statutory Qualifications & Credentials
A Chief Accountant must meet the academic and professional standards in the Accounting Law and the guiding decree. Decree 174 sets a university-level accounting qualification for most Vietnam-incorporated enterprises. Intermediate level suffices for enterprises with no state capital and charter capital below VND 10 billion.
Qualification Criteria Matrix
| Criterion | Standard enterprise | No state capital and charter capital below VND 10 billion |
|---|---|---|
| Accounting qualification | University level or above | Intermediate level or above |
| Experience Requirement | Minimum 2 years of accounting work | Minimum 2 years (university degree) or 3 years (intermediate or college level) |
| Mandatory Certification | Chief Accountant training certificate | Chief Accountant training certificate |
The Chief Accountant training certificate is issued by a training institution under the rules of the Ministry of Finance, not by the Ministry itself.
Prohibited Persons & Non-Concurrency Rules
Under the Accounting Law, the following individuals cannot work in accounting, including as Chief Accountant. The family-relationship and non-concurrency bars do not apply to private enterprises or single-member LLCs owned by one individual, or to other cases the Government specifies:
- Minors or individuals with impaired civil act capacity.
- Individuals under criminal prosecution, serving prison sentences, banned from accounting practice by court decisions, or with unexpunged economic crimes.
- Family Relationship Exclusions: Biological parents, adoptive parents, spouses, biological children, adopted children, and siblings of the Legal Representative, the head, Director or General Director, the deputy responsible for finance and accounting, or the Chief Accountant of the same entity.
- Non-Concurrency Rules: Individuals who manage or operate the entity, or act as warehouse keeper, cashier, or asset buyer or seller, may not work as accountants, including Chief Accountant, in the same entity.
3. Can a Foreigner Be Chief Accountant in Vietnam?
Yes. A foreign national can be Chief Accountant of a Vietnam-incorporated FDI company if they meet the same standards as a Vietnamese candidate and hold work authorization. Neither the Accounting Law nor Decree 174 sets a nationality or residence requirement for the role itself; labor and immigration rules apply separately.
That leaves four conditions to check:
- Accounting qualification: University level for most FDI companies, or intermediate level for a company with no state capital and charter capital below VND 10 billion. A foreign accounting certificate recognized by the Ministry of Finance (MOF) counts as this qualification.
- Chief Accountant training certificate: Required under Article 54 of the Accounting Law, whatever other credentials the person holds.
- Experience: At least 2 years of accounting work (university level) or 3 years (intermediate or college level).
- Work permit and residence: A valid work permit, or confirmation of exemption, under Decree 219/2025/ND-CP, plus a suitable visa or temporary residence card, as for any foreign employee (see the work permit and TRC guide).
Do ACCA or CPA Replace the Chief Accountant Certificate?
No. ACCA, CPA Australia, ICAEW and similar qualifications don’t replace the Chief Accountant training certificate; a recognized foreign certificate covers the accounting qualification only. Holders of ACCA, CPA Australia or ICAEW can also sit a Vietnamese-law exam, held in Vietnamese, to obtain a Vietnamese accountant certificate. That certificate doesn’t replace the training course either.
Training Rules Change on 1 January 2027
Until 31 December 2026, Circular 199/2011/TT-BTC governs Chief Accountant training. A foreigner holding a recognized foreign accounting certificate or degree may attend a course run for foreigners, and the training institution needs MOF’s written approval to open it. So check that approval before you enroll a foreign candidate.
From 1 January 2027, Circular 101/2026/TT-BTC replaces Circular 199. The new Circular has no separate track for foreign participants. Holders of a recognized foreign accounting certificate are exempt from the work-experience condition for enrolling, but they still complete the course, and the 2 or 3 years of experience still apply at appointment. Courses already filed with MOF under Circular 199 run to completion under the old rules, and certificates issued before 2027 that are still valid remain usable for appointment.
4. What Circular 99 Changes for the Chief Accountant
Effective January 1, 2026, Circular No. 99/2025/TT-BTC replaces Circular 200/2014/TT-BTC, with two provisions that touch the Chief Accountant’s day-to-day work.
Internal Accounting Policy Regulation
Circular 99 lets enterprises amend or add accounts to suit their operations. When they do, the enterprise must issue a formal Internal Accounting Policy Regulation (Quy chế hạch toán kế toán nội bộ) stating the need for the change and the enterprise’s responsibilities under Circular 99.
- Keeping the Regulation on file helps support customized sub-accounts during corporate tax compliance reviews.
- Key principles for inventory valuation, fixed asset depreciation schedules, and prepaid expense amortizations should be recorded in this document.
Segregation of Duties: No Signing by Authorization on Accounting Vouchers
Financial statements must carry the signatures of the preparer, the Chief Accountant, and the legal representative.
Under Circular 99/2025, the Chief Accountant may not sign accounting vouchers by authorization in the title of the enterprise’s manager, unless other laws provide otherwise (Article 10.4).
5. Personal Liability & Administrative Penalties
The Chief Accountant bears personal legal liability for financial misstatements and cannot rely on a manager’s instruction as a general defense. The protection in the Accounting Law applies only where the person records the disagreement and reports in writing as that article requires.
Corporate Administrative Penalties under Decree 41/2018/ND-CP
Under Decree 41 (as amended by Decree 132/2026/ND-CP), administrative fines for organizations are double the individual rate. The maximum fine for accounting infractions is VND 50,000,000 for individuals and VND 100,000,000 for organizations.
| Non-Compliance Infraction | Decree 41/2018 Article | Corporate Fine Amount |
|---|---|---|
| Failure to conduct accounting handover when replacing Chief Accountant | 17.1(c) | VND 10,000,000 - 20,000,000 |
| Engaging unauthorized accounting firms lacking MoF business eligibility | 17.1(a) | VND 10,000,000 - 20,000,000 |
| Signing financial statements improperly or missing Chief Accountant signature | 11.1(b) | VND 10,000,000 - 20,000,000 |
| Failure to appoint Chief Accountant after the 12-month limit | 17.2(a) | VND 20,000,000 - 40,000,000 |
| Appointing individuals barred from accounting work under the Accounting Law | 17.2(b) | VND 20,000,000 - 40,000,000 |
| Appointing or hiring an unqualified Chief Accountant lacking statutory standards | 17.3(b), (c) | VND 40,000,000 - 60,000,000 |
Criminal Liability for Accounting Fraud and Tax Evasion
Chief Accountants can face criminal prosecution under the Penal Code 2015 (amended 2017). Accounting violations with serious consequences (Penal Code Article 221) carry non-custodial reform of up to 3 years or prison terms of 1 to 5 years for damages of VND 100M to 300M, and 10 to 20 years for damages of VND 1 billion or more. Intentional tax evasion (Article 200) of VND 100M to 300M is punishable by fines up to VND 500M or 3 months to 1 year of imprisonment, and evasion of VND 1 billion or above by 2 to 7 years.
6. Outsourced Chief Accountant Services
Under the Accounting Law and the guiding decree, enterprises may retain a licensed accounting practice to perform Chief Accountant duties.
Mandatory Standards for Service Providers
An accounting service provider must satisfy two conditions:
- Corporate Eligibility: The provider must hold a Certificate of Business Eligibility for Accounting Services issued by the Ministry of Finance.
- Practitioner Qualifications: The person engaged as Chief Accountant must meet the same standards, including the Chief Accountant training certificate. The provider’s own practitioners must be registered practicing accountants.
Division of Legal Liability
- Service Provider: Assumes direct legal liability for accounting methodology, balance sheet accuracy, and statutory compliance, co-signing financial reports as Chief Accountant.
- FDI Enterprise: Retains statutory liability for the authenticity and commercial substance of the invoices and contracts it provides to the service firm. Outsourcing does not absolve the Legal Representative of corporate tax liabilities.
ICLV provides outsourced Chief Accountant services through certified CPA professionals who assume statutory signing liability.
7. Three Checks Before Month 12
To maintain compliance and protect corporate officers, run three checks:
- Track the 12-Month Limit: Set a compliance alert at month 10 of the 12-month period, to finalize the Chief Accountant appointment or sign an outsourced service agreement before the limit expires.
- Audit Professional Credentials: Verify the Chief Accountant training certificate, qualification and years of experience against the statutory standards, and confirm no family relationships with company executives.
- Update Tax and Banking Authorities: Submit tax registration adjustments within 10 working days where they are filed directly with the tax authority (Decree 252/2026/ND-CP) and update authorized bank signature mandates for your foreign investment capital account (formerly DICA).
A compliant accounting framework is the foundation of long-term stability within the broader Vietnam corporate tax compliance system. Contact ICLV’s corporate accounting advisors to set up a compliant accounting function from the start.
Regulatory Notice: Updated October 2026 based on Accounting Law No. 88/2015/QH13 (as amended by Law No. 56/2024/QH15), Decree No. 174/2016/ND-CP, Decree No. 41/2018/ND-CP (as amended by Decree 132/2026/ND-CP), Circular No. 99/2025/TT-BTC, Circular No. 199/2011/TT-BTC and Circular No. 101/2026/TT-BTC (Chief Accountant training), Decree No. 219/2025/ND-CP (work permits), Decree No. 252/2026/ND-CP and Penal Code 2015 (amended 2017).
