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Vietnam Accounting & Reporting

Circular 99/2025: The New Vietnam Accounting Regulation - Part 1

David Nguyen

Author: David Nguyen

Expert Reviewed
Circular 99/2025: The New Vietnam Accounting Regulation - Part 1
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Circular 99/2025/TT-BTC takes effect January 1, 2026, replacing Circular 200/2014 as Vietnam's primary accounting regulation. Key changes include restructured chart of accounts with new Level 1 accounts, enterprise autonomy to modify accounts from Level 2 onwards without Ministry of Finance approval, and mandatory Accounting Policy Regulation documentation.

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.

AspectCircular 200Circular 99Impact
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 PrinciplePermitted enterprises to determine decentralization levelMandates consolidation and internal elimination across head office and all affiliated unitsHigh
Corporate GovernanceNo mandatory internal management requirementsMandatory internal governance regulations and control systemsHigh

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

AspectCircular 200Circular 99Impact
Functional Currency SelectionPermitted foreign currency if conditions metClarifies: foreign currency only if it primarily influences sales prices, labour costs, and raw material costsHigh
Change in Functional CurrencyAllowed with significant operational changesHighly restricted: change prohibited unless material shift occurs, effective only at new accounting year startHigh
Conversion Rate upon ChangeMethodology unclearUses average transfer exchange rate (mean of buying/selling rates) of frequently transacted commercial bankMedium
Year-End Revaluation RateCommercial bank’s buying rateAverage transfer exchange rate of regularly used commercial bankMedium

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.

AspectCircular 200Circular 99Impact
COA ModificationRequired MOF written approval for Level 1/2 changesIndependent amendment from Level 2 onwards without authorizationHigh
Internal DocumentationNo specific regulation requirementsMandatory Accounting Policy Regulation required for COA amendmentsHigh
Vouchers and LedgersTemplates as advisory guidanceTemplates (Appendices I/III) are references only; enterprises may design their ownMedium
Voucher SignaturesGeneral requirementsChief Accountant shall not sign “on behalf of” managerial positionsMedium

⚠️ 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

AspectCircular 200Circular 99Impact
Biological AssetsAccounted as TFA (Account 211)New Account 215 – dedicated Level 1 accountHigh
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 + feesExcludes purchase costs: only Fair Value paid; fees expensed immediately to financial costsMedium
Inventory ValuationThree methods (Specific ID, Weighted Average, FIFO)Adds Standard Cost as fourth methodMedium

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

AspectCircular 200Circular 99Impact
Payable DividendsWithin Account 338 (Other Payables)New Account 332 – dedicated Level 1 accountMedium
Biological Asset ProvisionN/ANew Account 2295 – Provision for Biological Asset ImpairmentMedium
Deposits/Collateral (244)Included pledges, mortgages, depositsNarrowed: only deposits or collateral; pledges/mortgages disclosed in NotesMedium
Preference SharesLiability only if mandatory repurchaseExpanded: liability if (1) mandatory repurchase, OR (2) mandatory fixed dividend regardless of results, OR (3) conversion terms rely on share market priceHigh

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.

Frequently Asked Questions

No. Under Circular 99, enterprises may independently amend or supplement the Chart of Accounts from Level 2 onwards without Ministry of Finance approval. However, the enterprise must issue an Accounting Policy Regulation documenting the modifications and accepting legal responsibility for compliance with Accounting Law Article 10 principles.

Functional currency changes are highly restricted under Circular 99. Changes are prohibited unless a material shift in operations occurs, and can only be effected at the commencement of a new accounting year. If export markets shift during 2026, the enterprise must wait until 1 January 2027 to change functional currency.

No. Circular 99 is effective 1 January 2026 and applies to financial years commencing on or after this date. The 2025 financial year remains governed by Circular 200/2014/TT-BTC. However, enterprises must execute mandatory account balance transfers on 31 December 2025 to ensure 1 January 2026 opening balances comply with the new Chart of Accounts structure.

About the Authors

David Nguyen

David Nguyen

Partner, Director, CPA

Expert in M&A Due Diligence, IFRS/VAS Conversion, and FDI Manufacturing Setup. Provides Chief Accountant services for foreign enterprises in Vietnam.

Manufacturing SetupM&A Transaction SupportIFRS/VAS ConversionChief Accountant
Olivia Zheng

Olivia Zheng

Manager of Chinese Clients Department, CPA

CPA & Licensed Tax Practitioner specializing in Tax, Audit & Advisory for Chinese-speaking enterprises in Vietnam. Expert in Internal Control and Management Accounting.

China Desk AdvisoryTax & Accounting ComplianceIFRS/VAS ConversionSystem Setup & Automation

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