The Chief Accountant is the head of an enterprise’s accounting apparatus per Accounting Law 88/2015/QH13 (effective January 1, 2017), responsible for organizing accounting work, advising on accounting system design, checking compliance of transactions, and co-signing financial documents in accordance with law. 

Most enterprises must appoint a qualified Chief Accountant per Decree 174/2016/ND-CP, with exemptions only for micro-enterprises (annual revenue < VND 3 billion, employees < 10 per Decree 39/2018/ND-CP). Newly established enterprises have 12 months to appoint a qualified Chief Accountant, with penalties ranging from VND 5-30 million for non-compliance.

Legal definition and authority under Vietnamese law

A Chief Accountant is the head of an enterprise’s accounting apparatus who organizes and directs all accounting activities. This person bears direct responsibility to the enterprise director for accounting quality and regulatory compliance.

Vietnamese law distinguishes between two positions:

  • Chief Accountant: Senior position requiring advanced certification with full organizational oversight authority
  • Person in charge of accounting: Lower position for micro-enterprises or temporary appointments without strategic management authority

Primary authorities include:

  • Complete authority over accounting system design and modification
  • Legal power to reject non-compliant financial transactions and documentation
  • Direct supervision of accounting personnel including recruitment and evaluation
  • Mandatory review and approval of all financial reports before regulatory submission

The Chief Accountant maintains independent decision-making capacity with legal protection against undue management interference. This authority extends to refusing directives that violate accounting regulations.

Qualification requirements

Education and certification

Candidates must possess either: (1) bachelor’s degree in Accounting, Finance, or Economics, or (2) college associate degree with professional certification validating financial reporting expertise.

Vietnam’s Ministry of Finance may recognize foreign accounting degrees and professional certifications in accordance with its current regulations on qualification recognition and Chief Accountant standards under Decree 174/2016/ND-CP, but enterprises should verify specific recognition procedures and documents with the Ministry or competent authorities before relying on them.

The key requirement is that the person appointed as Chief Accountant must meet the professional standards and Chief Accountant training or certification conditions prescribed by Decree 174/2016/ND-CP and relevant Ministry of Finance regulations, including compliance with applicable continuing professional development obligations.

Foreign national eligibility

Foreign nationals may serve as Chief Accountant if they satisfy all professional standards and legal conditions prescribed by Vietnamese law, including Chief Accountant qualification requirements and applicable work permit and labor regulations; in practice, they must be able to ensure that accounting records and reports are prepared and signed in compliance with Vietnamese language and regulatory requirements.

Common FDI structure: Expatriate CFO/Finance Director handles group reporting while Vietnamese Chief Accountant manages statutory compliance. The Chief Accountant role cannot be eliminated even when foreign CFO is present.

Chief Accountant responsibilities

The Chief Accountant fulfills critical functions across operational management, regulatory compliance, and financial advisory within enterprises.

Core responsibilities

Accounting Operations Management:

  • Designing and implementing accounting systems and workflow procedures
  • Supervising accounting personnel and establishing performance metrics
  • Coordinating cross-departmental collaboration for data integrity

Regulatory Compliance:

Financial Advisory: While Accounting Law 88/2015/QH13 defines compliance and reporting duties, in practice many FDI enterprises involve Chief Accountants in strategic planning due to their financial oversight responsibilities.

For FDI enterprises, responsibilities include transfer pricing documentation (Decree 132/2020/ND-CP), related-party transaction disclosures, and foreign exchange management compliance (Circular 06/2019/TT-NHNN).

Appointment requirements

Mandatory appointment

Yes, most Vietnamese enterprises that are required to organize an accounting apparatus must appoint a Chief Accountant per Accounting Law 88/2015/QH13 and Decree 174/2016/ND-CP, although in certain cases the law allows a “person in charge of accounting” instead of a Chief Accountant, particularly for smaller or newly established entities consistent with Decree 39/2018/ND-CP and related guidance. In practice, despite companies are micro-enterprises, the bank normally ask to provide Chief Accountant’s information, especially FDI companies.

Grace period for new enterprises

Newly established enterprises that are required to have a Chief Accountant may arrange a “person in charge of accounting” or hire Chief Accountant services for a maximum of 12 months under Decree 174/2016/ND-CP, Article 20, after which they must appoint a qualified Chief Accountant. During this period, they may temporarily appoint a person in charge of accounting or hire chief accountant services. After 12 months, enterprises must appoint a qualified Chief Accountant.

Penalties for non-compliance

Enterprises violating Chief Accountant appointment regulations face administrative penalties under Decree 41/2018/ND-CP (effective July 5, 2018):

  • VND 5-10 million: Procedural violations (failure to transfer work, announce changes). VND 5M for first-time failures, VND 10M for repeated violations
  • VND 10-20 million: Appointing unqualified accountants or failing to organize accounting apparatus
  • VND 20-30 million: Appointing Chief Accountants who do not meet all standards

Additional remedial measure: enterprises must appoint qualified Chief Accountant within specified timeframe. Legal responsibility extends to enterprise directors and legal representatives who authorize non-compliant appointments.

Tax and other state authorities may identify violations of Chief Accountant appointment rules during inspections and can apply administrative sanctions under the applicable decree on accounting sanctions; foreign-invested enterprises should ensure that a qualified Chief Accountant is duly appointed even where an expatriate CFO is in place.

Outsourcing Chief Accountant services

Enterprises can outsource Chief Accountant functions from qualified accounting service providers rather than hiring employees.

When outsourcing, enterprises must:

  • Execute written service contracts with provider specifying scope of services
  • Provide accurate and complete financial information to service provider
  • Understand that ultimate legal responsibility for accounting remains with enterprise legal representative, not outsourced provider. However, service providers bear contractual and professional liability for accuracy and quality of accounting information and data per contract terms, and outsourced Chief Accountants personally assume identical legal responsibilities as in-house Chief Accountants for documents they sign and work performed.

Common outsourcing arrangements include:

  • Hiring qualified accounting firms to provide Chief Accountant services
  • Part-time Chief Accountant arrangements for smaller enterprises
  • Temporary services during 12-month grace period for newly established enterprises (Decree 174/2016/ND-CP, Article 20)

Critical Note: Outsourced Chief Accountants must still meet all qualification requirements including Vietnamese Chief Accountant Certificate from Ministry of Finance. Service providers must hold a Certificate of Eligibility (Accounting Certificate), licensed by the Ministry of Finance, for providing accounting services issued in accordance with the Accounting Law and guiding decrees.

Disclaimer: This article provides general information about Vietnamese Chief Accountant regulations and does not constitute legal or professional advice. Enterprises should consult qualified accounting professionals and legal advisors for their specific circumstances.

Content current as of: January 2026. Vietnamese regulations are subject to change. Always verify current requirements with official government sources or professional advisors.

Frequently asked questions

What is the average salary range for chief accountants in different enterprises?

Answer: 

Chief accountant salaries vary greatly based on regional differences and company size. Salary benchmarks typically range from $60,000 to $150,000 annually in most markets, with larger enterprises and metropolitan areas offering higher compensation packages reflecting increased responsibilities.

Answer:

The Chief Accountant focuses primarily on accounting operations, compliance, and financial reporting, while the Finance Director holds a higher strategic position overseeing broader financial planning, investment decisions, and corporate financial strategy, demonstrating clear hierarchy differences and scope variation

Answer:

Professional pathways illuminate advancement like stepping stones across water. CPA, CMA, and ACCA certifications enable senior leadership roles. Professional development through continuing education strengthens technical expertise, regulatory knowledge, and strategic capabilities essential for ascending corporate finance hierarchies.

Answer:

Enterprises should replace their chief accountant when ethical lapses occur, professional competence deteriorates, or regulatory compliance failures arise. Additionally, planned successions through succession planning guarantee smooth leadership changes during retirement, promotions, or strategic organizational restructuring needs.