Circular 99/2025/TT-BTC replaces Circular 200/2014 as Vietnam’s primary accounting regulation, effective January 1, 2026. The most significant shift: enterprises now have autonomous control over their Chart of Accounts from Level 2 onwards — without Ministry of Finance pre-approval — but must document all modifications in a mandatory Accounting Policy Regulation. For FDI enterprises running SAP, Oracle, or MISA, this means updating ERP configurations, account mappings, and internal policies before year-end 2025.
Executive Key Takeaways
- Effective Date: Circular 99/2025/TT-BTC takes effect 1 January 2026, replacing Circular 200/2014.
- Mandatory Consolidation: Enterprise Financial Statements must integrate head office and all affiliated units, eliminating all internal transactions.
- COA Autonomy: Enterprises may independently amend Chart of Accounts from Level 2 onwards without MOF approval, provided they issue an Accounting Policy Regulation.
- New Biological Assets Account: Account 215 separates biological assets from Tangible Fixed Assets.
- Non-Going-Concern Reporting: Enterprises facing dissolution or bankruptcy within 12 months must use the DNKLT template set.
This circular replaces Circular 200/2014/TT-BTC and accelerates Vietnam’s convergence with IFRS. For detailed line-by-line account comparisons, see Part 2.
1. Terminology and Organisational Scope
Circular 99 standardizes nomenclature and expands regulatory expectations for corporate structure and internal controls.
| Aspect | Circular 200 | Circular 99 | Impact |
|---|---|---|---|
| Financial Statement Name | ”Bảng cân đối kế toán” (Balance Sheet) | “Báo cáo tình hình tài chính” (Statement of Financial Position) | Low |
| Affiliated Units | ”đơn vị hạch toán phụ thuộc” (dependent accounting unit) | “đơn vị trực thuộc” (affiliated unit) | Low |
| Reporting Principle | Permitted enterprises to determine decentralization level | Mandates consolidation and internal elimination across head office and all affiliated units | High |
| Corporate Governance | No mandatory internal management requirements | Mandatory internal governance regulations and control systems | High |
Internal transactions requiring elimination include: inter-unit sales, inter-unit loans and interest, inter-unit asset transfers, and management fee allocations. Failure to eliminate overstates both revenue and expenses—creating tax audit exposure. Understanding chief accountant responsibilities is essential for implementing these consolidation requirements.
2. Currency Unit and Exchange Rate
| Aspect | Circular 200 | Circular 99 | Impact |
|---|---|---|---|
| Functional Currency Selection | Permitted foreign currency if conditions met | Clarifies: foreign currency only if it primarily influences sales prices, labour costs, and raw material costs | High |
| Change in Functional Currency | Allowed with significant operational changes | Highly restricted: change prohibited unless material shift occurs, effective only at new accounting year start | High |
| Conversion Rate upon Change | Methodology unclear | Uses average transfer exchange rate (mean of buying/selling rates) of frequently transacted commercial bank | Medium |
| Year-End Revaluation Rate | Commercial bank’s buying rate | Average transfer exchange rate of regularly used commercial bank | Medium |
In practice, tax authorities expect foreign currency to represent at least 70% of sales revenue or operating costs. The methodology must be documented in the Accounting Policy Regulation. Mid-year functional currency changes are prohibited — if export markets shift during 2026, the enterprise must wait until 1 January 2027.
For FDI enterprises using USD or other foreign currencies as their primary transaction currency, this clarification reduces ambiguity. FDI companies should confirm their functional currency choice with the appointed auditor before the first 2026 reporting period.
3. Accounting System, Vouchers, and Chart of Accounts
Circular 99 grants responsible autonomy for accounting system customization.
| Aspect | Circular 200 | Circular 99 | Impact |
|---|---|---|---|
| COA Modification | Required MOF written approval for Level 1/2 changes | Independent amendment from Level 2 onwards without authorization | High |
| Internal Documentation | No specific regulation requirements | Mandatory Accounting Policy Regulation required for COA amendments | High |
| Vouchers and Ledgers | Templates as advisory guidance | Templates (Appendices I/III) are references only; enterprises may design their own | Medium |
| Voucher Signatures | General requirements | Chief Accountant shall not sign “on behalf of” managerial positions | Medium |
⚠️ COA Autonomy Limits: While MOF pre-approval is eliminated, the enterprise’s Accounting Policy Regulation must demonstrate compliance with Accounting Law Article 10. Tax authorities can challenge non-compliant account structures during audits.
4. Changes to Asset Accounting Principles
| Aspect | Circular 200 | Circular 99 | Impact |
|---|---|---|---|
| Biological Assets | Accounted as TFA (Account 211) | New Account 215 – dedicated Level 1 account | High |
| Deferred Expenses (242) | “Chi phí trả trước” (Prepaid expenses) | “Chi phí chờ phân bổ” (Expenses Awaiting Allocation) | Low |
| Trading Securities (121) | Cost included purchase price + fees | Excludes purchase costs: only Fair Value paid; fees expensed immediately to financial costs | Medium |
| Inventory Valuation | Three methods (Specific ID, Weighted Average, FIFO) | Adds Standard Cost as fourth method | Medium |
Agricultural and aquaculture FDI companies must separate biological assets from tangible fixed assets by 1 January 2026. Continued use of Account 211 for biological assets will be flagged as non-compliance. For manufacturing FDI companies, the new Standard Cost inventory method under Circular 99 may simplify month-end valuation if the enterprise’s ERP already uses standard costing for group reporting.
5. Liabilities, Equity, and Preference Share Classification
| Aspect | Circular 200 | Circular 99 | Impact |
|---|---|---|---|
| Payable Dividends | Within Account 338 (Other Payables) | New Account 332 – dedicated Level 1 account | Medium |
| Biological Asset Provision | N/A | New Account 2295 – Provision for Biological Asset Impairment | Medium |
| Deposits/Collateral (244) | Included pledges, mortgages, deposits | Narrowed: only deposits or collateral; pledges/mortgages disclosed in Notes | Medium |
| Preference Shares | Liability only if mandatory repurchase | Expanded: liability if (1) mandatory repurchase, OR (2) mandatory fixed dividend regardless of results, OR (3) conversion terms rely on share market price | High |
JSC companies with preference shares guaranteeing fixed dividends must reclassify them as financial liabilities — this affects debt-to-equity ratios and potentially triggers loan covenant reviews. FDI enterprises structured as joint-stock companies with Vietnamese partners should review charter documents for preference share clauses that may now require liability reclassification. The new dedicated Account 332 for payable dividends also simplifies profit repatriation tracking.
6. Non-Going Concern Reporting and Business Combinations
Non-Going Concern (Article 15): Enterprises facing dissolution, bankruptcy, or cessation within 12 months must use the DNKLT template set. Assets are measured at the lower of carrying amount and net realizable/recoverable value. The Statement of Financial Position must not distinguish between current and non-current items.
Business Combinations (Mergers/Divisions): The receiving enterprise records assets and liabilities as amounts arising during the period—opening balances remain unchanged. Internal transactions must be eliminated before preparing merger-period statements. Goodwill is recognized per VAS 11 for combinations not under common control.
7. Transitional Provisions and Implementation Roadmap
Mandatory Account Balance Transfers (31 December 2025):
- Account 441 (Capital construction investment sources) and 466 (Fixed Asset Forming Fund) → Account 4118 (Other capital)
- Dividends payable within Account 338 → new Account 332 (Payable Dividends and Profits)
- Account 138 (Non-controlled Business Cooperation Contract investment) → Account 2281
- Account 2413 (extraordinary repair costs) → Account 2414 (upgrading/renovation of TFA)
Implementation Timeline:
- By 30 November 2025: Reconfigure ERP systems (SAP, Oracle) for new COA structure
- By 15 December 2025: Complete account mapping documentation for all balance transfers
- 31 December 2025: Execute account balance transfers during year-end closing
- 1 January 2026: Validate opening balances in new account structure
Voluntary accounting policy changes must apply the retrospective adjustment method. The equitization provisions from Circular 200 remain in effect until replaced.
Next Steps
For the account-by-account comparison between Circular 200 and Circular 99, see the technical deep-dive →. For the complete overview of all FDI accounting and reporting obligations, see the Accounting & Reporting Compliance hub →.
Need Circular 99 transition support? Indochina Link Vietnam’s accounting and advisory team assists FDI enterprises with COA reconfiguration, Accounting Policy Regulation drafting, internal control documentation, and transitional account mapping.
Legal Disclaimer
This article provides general information about Circular 99/2025/TT-BTC. It does not constitute legal, tax, or accounting advice.
Regulations cited are subject to amendments and implementing guidance. Readers should consult licensed accounting professionals regarding specific circumstances. Vietnam regulations change frequently — verify current requirements with qualified advisors.
