This article provides a detailed comparison of 25+ essential accounting changes between Circular 200 and Circular 99/2025/TT-BTC. CFOs, financial controllers, and accounting managers should review these changes to prepare their Chart of Accounts, IT systems, and internal policies for the transition to fiscal years beginning on or after 1 January 2026. Understanding these specific regulatory modifications is critical for ensuring compliance and maintaining robust financial governance under the new framework.

In our preceding article, we outlined the significant transition from Circular 200 to Circular 99/2025/TT-BTC, effective for annual accounting periods beginning on or after 1 January 2026. Before proceeding with the next post, here are the key takeaways from our previous post introducing Circular 99/2025/TT-BTC:

  • New Core Philosophy: The most significant change is the strategic shift from “”administrative compliance”” to “”autonomy with governance responsibility.””

  • Key Change (Autonomy): Enterprises are now granted the freedom to independently amend their Chart of Accounts (from Level 2 downwards) and customize accounting vouchers without seeking prior approval from the Ministry of Finance.

  • Key Change (Responsibility): This new autonomy comes with a mandatory new requirement. Enterprises must develop, issue, and accept full legal responsibility for their own internal Accounting Policy Regulation to document and justify their accounting systems.

  • Broader IFRS Alignment: The circular introduces numerous other technical changes to accelerate convergence with IFRS, including new accounts (like “”Biological Assets””) and new valuation principles (like expensing purchase costs for trading securities).

  • Immediate Action Required: All businesses must begin reviewing their internal controls and updating their IT/accounting software now to ensure full compliance for fiscal years beginning on or after 1 January 2026.

See more: Circular 99/2025: The New Vietnam Accounting Regulations (Part 1)

Detailed Comparison: Circular 200 vs Circular 99

The following table presents a comprehensive comparison of the essential accounting changes between the two regulatory frameworks. Each row details the specific modifications that businesses must understand and implement.

CriterionCircular 200/2014/TT-BTC (Circular 200)Circular 99/2025/TT-BTC (Circular 99)
Accounting Chart of AccountsUtilized a detailed account system, deemed rigid and rule-based. Modifying the name, code, or content of Level 1 and Level 2 accounts necessitated written approval from the Ministry of Finance (MoF).

Grants enterprises responsible autonomy (self-determination) to customize the CoA to meet internal management needs. The circular specifies only 71 mandatory Level 1 accounts. Entities must promulgate an Internal Accounting Policy justifying these changes.

Example: An enterprise can independently choose to detail the Cash Account (TK 111) using alphanumeric codes like ‘111.VND’ and ‘111.USD’, or numeric codes like ‘1111’ and ‘1112’

Trading Securities Accounting (TK 121)Historical cost incorporated the purchase price alongside associated costs, such as brokerage fees, transaction charges, and taxes.

Purchase cost treatment: The initial cost constitutes only the Fair Value of the consideration paid. Related purchase costs (brokerage, transaction charges) must be immediately recognized as financial expenses in the current period.

Example: The asset’s initial cost is strictly the Fair Value of the consideration paid. Brokerage fees and transaction charges must be immediately recognized as Financial Expense (TK 635) in the current period.

Held-to-Maturity Investments (TK 128)Reflected investments are held until their maturity date, encompassing time deposits, bonds, and loans.

Requires the establishment of an Impairment Provision (using TK 229) when objective or reasonable evidence indicates that the investment may not be fully recoverable. Entities must account completely for financial operating revenue generated from these investments, such as interest income from deposits or loans.

Example: If a corporate bond held to maturity shows objective signs that interest or principal recovery is doubtful, the entity must set up a specific provision using TK 229. Interest/dividend income is recorded in TK 515 upon confirmation of receipt.

Inventory AccountingApplied three primary methods for calculating outgoing inventory value: specific identification, weighted average, and FIFO.

Introduces the Standard Cost method as an additional permissible technique for valuing inventory. Materials or equipment reserved for a duration exceeding 12 months (or one normal operating cycle) must be presented as a long-term asset, rather than inventory, on the Statement of Financial Position. The new circular abolishes Account 611 (Purchases).

Example: Manufacturers can leverage Standard Costing for faster cost estimation and profit calculation during the period, adjusting variances to Cost of Goods Sold (COGS).

PPE and Investment Property AccountingMandated the nearly absolute application of the Historical Cost model. Accumulated depreciation was specifically reflected through Account 214.

Introduces the option to apply the Fair Value Model for Property, Plant, and Equipment (PPE) and Investment Property (IP), achieving greater alignment with IFRS.

Example 1 (Going Concern): Large entities, particularly those preparing for IFRS adoption, can elect to revalue property assets to their Fair Value.

Example 2 (Non-Going Concern): If an enterprise is determined not to be a going concern, depreciation or impairment is deducted directly from the asset’s carrying value (net amount), thereby bypassing the use of the Accumulated Depreciation Account (TK 214).

Construction in Progress Accounting (TK 241)Reflected procurement costs, construction expenditures, and major repairs related to PPE. Detailed Account 2414 addressed costs for upgrades and improvements to PPE.Adds Account 2414 – Upgrades, Improvements to PPE. This account aggregates costs related to purchasing PPE/IP, capital construction investment, upgrades, improvements, and crucially, periodic repair and maintenance expenses. Replaces relevant prior circulars including those governing specific accounting treatments.
Biological Assets AccountingLacked a dedicated account. Biological assets (such as perennial crops yielding periodic products or working livestock) were accounted for as tangible PPE (TK 211).

Introduces a new Level 1 Account: TK 215 – Biological Assets. This step clearly separates biological assets from tangible PPE. Provides specific regulations regarding the establishment of impairment provisions for biological assets via TK 2295.

Example: Agricultural enterprises must now separate the cost and lifecycle of assets like perennial fruit trees or breeding cattle (TK 215) from standard factory equipment (TK 211)

Investment Property (IP) AccountingIP held for operating leases was subject to depreciation, with the expense recognized in the period’s production or business costs.

IP held for operating leases continues to require depreciation, even during periods of rental suspension, with recognition in production or business expenses.

Example: IP held solely for capital appreciation is not depreciated but must undergo impairment testing for value decline, with losses booked to Cost of Goods Sold (TK 632). Gains or losses from the disposal of IP are presented on a net basis within the income statement.

Investments in Other Entities AccountingThe cost basis for investments liquidated or sold was determined using the moving weighted average method (specifically for trading securities).Example (BCC Transition): The outstanding balance representing capital contributions to a non-jointly controlled Business Cooperation Contract (BCC), previously detailed under TK 138 (Other Receivables), must be transferred to TK 2281 (Equity investment in other entities) upon transition to TT99.
Investment in Subsidiaries Accounting (TK 221)Prohibited the reclassification of investment in a subsidiary as trading securities unless genuine liquidation or sale resulted in the loss of control.Upholds the principle against reclassification unless control is relinquished. Revaluation differences arising from contributing non-monetary assets (Inventory, PPE, IP) to a subsidiary are recorded as an increase in Other Income (TK 711) or a decrease in Other Expense (TK 811).
Business Cooperation Contracts (BCC) AccountingInvestments or capital contributions related to non-legal entity BCCs were generally not reflected in TK 228.

Clarifies the economic treatment of non-legal entity BCCs.

Example: For BCCs where one party handles the main accounting/taxation, the transaction should be accounted for based on its true nature—either as a borrowing transaction (for the accounting party) or a lending transaction (for the other party).

Asset Impairment Provisions Accounting (TK 229)Comprised four Level 2 accounts: Provision for trading security devaluation, provision for investment impairment, provision for doubtful debts, and provision for inventory devaluation.Introduces a new Level 2 Account: TK 2295 – Biological Asset Impairment Provision. Requires that provisions for doubtful debts (TK 2293) and inventory devaluation (TK 2294) must be substantiated by reliable evidence confirming the decline in value.
Deferred Allocation Costs Accounting (TK 242)Labelled as “”Prepaid Expenses””. Presented as short-term prepaid expense on the Statement of Financial Position (Code 151).

Renamed “”Deferred Allocation Costs””. Functions to allocate costs gradually into production or business expenses over multiple periods. Goodwill generated during equitization must be recorded in TK 242 and allocated over a maximum duration of 3 years to General and Administrative Expense (TK 642).

Example: The account accumulates costs for periodic maintenance and repairs (TK 2413) which are then amortized systematically into operating expenses (e.g., TK 642).

Dividends and Profit Payable AccountingThis liability was typically detailed within Account 338 – Other Payables and Taxes.

Introduces a new Level 1 Account: 332 – Dividends and Profit Payable to standardize the formal recognition of this obligation.

Example: This standardizes the recording of the liability. Upon transition, the credit balance relating to dividends/profits previously within TK 338 must be formally transferred to TK 332.

Taxes and Other Government Payables (TK 333)Reflected the direct and indirect taxes owed to the state.

Incorporates new tax provisions: Mandates detailed accounting for supplementary corporate income tax costs arising from Global Minimum Tax (GloBE) regulations, classifying them as long-term liabilities (Code 332). It also includes guidance for TK 1383 (Special Consumption Tax on imported goods).

Example: The system now includes specific guidance for the Global Minimum Tax (GloBE), adding TK 82112 for Supplementary Corporate Income Tax Expense.

Borrowing and Finance Lease Liabilities AccountingDebt was classified as short-term or long-term based on a payment threshold of 12 months or one normal operating cycle.

Defines four specific conditions for classifying a liability as short-term, including instances where the debt is held primarily for trading purposes.

Example: A liability is classified as current if it is held primarily for trading purposes. Payables related to the working capital cycle remain current even if the settlement term exceeds 12 months.

Provisions Payable Accounting (TK 352)Required that provisions payable must fulfill the criteria established by Vietnamese Accounting Standards.Allows for pre-accrual capabilities: Permits the pre-accrual provision for costs related to repair, maintenance, and asset restoration at the conclusion of PPE lease contracts, adhering to the requirements of Vietnamese Accounting Standard No. 18 (VAS 18) – Provisions, Contingent Liabilities and Contingent Assets.
Science and Technology Development Fund (TK 356)Reflected the existing balance and the increase or decrease of the fund derived from post-tax corporate income profit, designated for science and technology activities.Maintains the fundamental structure. When the Fund is utilized to invest in or purchase PPE, the entity must simultaneously increase the initial cost of the PPE and increase TK 3562 – S&T Development Fund formed into PPE.
Owners’ Equity Accounting (TK 411)TK 4112 was designated “”Share Premium””. Preferred stock was classified as a liability if subject to mandatory repurchase at a determined date.

Renames TK 4112 to “”Capital Surplus””. The conditions for classifying preferred shares as a liability are expanded. Classification applies if the shares meet any of the following:

(i) Mandatory repurchase;

(ii) Mandatory fixed dividends irrespective of profitability; OR

(iii) Conversion rights determined by the market price.

Foreign Exchange Rate Differences Accounting (TK 413)The actual transaction rate lacked a clear definition, complicating Enterprise Resource Planning (ERP) systems. The year-end revaluation rate for foreign currency monetary assets typically defaulted to the commercial bank’s buying rate.

Standardises the process, achieving IFRS convergence.

The actual transaction rate may be defined as the average transfer buying/selling rate of the bank most frequently utilised.

Permits the application of an Approximation Rate (with a deviation tolerance of no more than +/-1%) for transactions occurring within the period.

The year-end revaluation rate must be the average transfer buying/selling rate.

Own Shares Repurchased (TK 419)Referred to as “”Treasury Stock””.Renamed “”Own Shares Repurchased””. This terminology aligns with international standards (Treasury Shares). Accounting guidance is provided for using these shares for bonuses.
Undistributed Post-Tax Profit (TK 421)Reflected the post-tax business results (profit or loss) and the status of profit distribution or loss treatment.Maintains the fundamental principles. Introduces a principle for managing differences arising from common control merger transactions (transfer to TK 4118 and gradual reversal to TK 421 over a maximum period of 10 years).
Revenue Recognition Accounting (TK 511)Revenue recognition was generally tied to the date of invoice issuance or the transfer of risk.

Promotes revenue recognition based on the transfer of control and the fulfillment of Performance Obligations, achieving similarity with IFRS 15 five-step methodology (identify contract, identify performance obligations, determine transaction price, allocate price, recognize revenue). This shift significantly influences sectors characterized by complex contractual arrangements, such as Real Estate, Construction, and Services.

Example: For real estate development or long-term service agreements, enterprises must now identify distinct performance obligations and allocate and recognize revenue as control transfers, which may result in recognition over time rather than at a single point in time.

Financial Operating Revenue (TK 515)Reflected income such as interest on deposits, loan interest, dividends, and profit shares received.Expands the scope to include gains derived from the disposal or recovery of financial investments (TK 121, 221, 222, 228), subsequent to offsetting any related impairment provisions (TK 229).
Other Income (TK 711)Recognised income generated outside the core production or business activities, including gains from the liquidation or sale of PPE.Records the revaluation increase difference when contributing non-monetary assets (Inventory, PPE) as capital to another entity. Payables for which the creditor cannot be identified, or which are definitively determined as non-payable, are now recorded as other income.
Expense AccountingSelling Expenses (TK 641) and General and Administrative (G&A) Expenses (TK 642) were predominantly presented by function on the Income Statement.Requires the classification of Selling and G&A Expenses by nature to enhance both transparency and internal management effectiveness. Abolishes Account 611 – Purchases, thereby implicitly phasing out the Periodic Inventory Method for related accounts.

Conclusion

The transition from Circular 200 to Circular 99/2025/TT-BTC represents a fundamental shift in Vietnam’s accounting regulatory framework. The three most critical changes requiring immediate attention are: (1) the mandatory development of an Internal Accounting Policy Regulation to document your customized accounting systems, (2) the adoption of IFRS-aligned revenue recognition principles based on performance obligations and control transfer, and (3) the implementation of new accounts and valuation methods including the Fair Value Model for PPE and Investment Property.

With the effective date set for fiscal years beginning on or after 1 January 2026, businesses must act now to review their Chart of Accounts, update IT systems, train accounting personnel, and establish robust internal controls under the new “”autonomy with governance responsibility”” philosophy.

ICLV’s accounting and tax advisory team can help your business navigate the Circular 99 transition. Contact us for a compliance readiness assessment and implementation roadmap tailored to your organization’s specific needs.

In our upcoming post, we will delve deeper into the specific impacts on Financial Statements, some amendments to forms, methods of preparing and presenting financial statements.

Frequently Asked Questions

1. When must we implement Circular 99 changes?

Circular 99/2025/TT-BTC is effective for annual accounting periods beginning on or after 1 January 2026. Businesses should begin preparation immediately to ensure systems, policies, and personnel are ready for the transition.

You may continue using your existing Chart of Accounts structure, but you must ensure it includes the 71 mandatory Level 1 accounts specified in Circular 99. Any customizations to Level 2 accounts and below must be documented in your Internal Accounting Policy Regulation.

Under Circular 99, all enterprises must develop and issue an Internal Accounting Policy Regulation that documents and justifies their accounting systems, including any customizations to the Chart of Accounts, accounting vouchers, and financial reporting procedures. This regulation must be maintained and updated as your accounting practices evolve.

No. Circular 99 grants enterprises responsible autonomy to modify Level 2 accounts and below without seeking prior approval from the Ministry of Finance. However, you must document these changes in your Internal Accounting Policy Regulation and accept full legal responsibility for them.

Your ERP and accounting software will require updates to accommodate new accounts (such as TK 215 for Biological Assets and TK 332 for Dividends Payable), new valuation methods (Fair Value Model for PPE/IP, Standard Cost for inventory), and revised revenue recognition principles. Begin working with your software vendor now to ensure compatibility by 2026.

About the author