Circular 99/2025/TT-BTC changes the Circular 200 chart in a defined set of accounts: Level 1 accounts fall from 76 to 71, Accounts 215 and 332 are new, and seven accounts are removed. This guide shows, area by area, what Circular 200/2014/TT-BTC said and what Circular 99 says now, for CFOs, chief accountants and ERP teams. Circular 99 was issued on October 27, 2025 and applies to financial years beginning on or after January 1, 2026.
Scope, timing and the year-end checklist are in the Circular 99 overview (Part 1). The wider rules sit in the accounting and reporting framework guide.
1. Accounts Removed, Added and Renamed
The table compares the Level 1 accounts of Circular 200 with Appendix II of Circular 99.
| Change | Level 1 accounts |
|---|---|
| Count | 76 under Circular 200, 71 under Circular 99 |
| Removed | 161 (non-business expenditure), 417 (enterprise restructuring support fund), 441 (capital construction investment funds), 461 (non-business funding sources), 466 (funds that formed fixed assets), 611 (Purchases), 631 (Production Costs) |
| New | 215 (Biological Assets), 332 (Dividends and Profits Payable) |
| Renamed | 112 “Bank Deposits” to “Demand Deposits”; 155 “Finished Goods” to “Products”; 158 “Bonded Warehouse Goods” to “Materials and Supplies in Bonded Warehouses”; 242 “Prepaid Expenses” to “Costs Awaiting Allocation”; 244 “Pledges, Mortgages, Deposits and Guarantees” to “Deposits and Guarantees”; 419 “Treasury Shares” to “Own Repurchased Shares” |
On transition, balances of Accounts 441 and 466 move to Account 4118 (Article 29.1). Circular 99 keeps some Circular 200 content on state-owned enterprise equitization, which includes the guidance on Account 417 (Article 31.2).
2. Chart of Accounts and Inventory Valuation
These changes affect chart hierarchies in the ERP and inventory costing for FDI manufacturers.
| Area | Circular 200/2014/TT-BTC | Circular 99/2025/TT-BTC |
|---|---|---|
| Chart of Accounts Customization | Amending or supplementing Level 1 or Level 2 accounts needed prior written Ministry of Finance approval. Further Level 2 and Level 3 accounts could be opened without approval where no sub-accounts were prescribed. | Enterprises may amend and add the name, number, structure and content of accounts (Article 11.2) if financial statement figures stay unchanged. The default chart has 71 Level 1 accounts. Enterprises must issue an Internal Accounting Policy Regulation (or equivalent document). Illustrative example: separate sub-accounts such as 111.VND and 111.USD under group ERP rules. |
| Inventory Valuation Methods | Listed three methods (specific identification, weighted average, FIFO), plus a retail price technique for retailers. | Lists five methods: specific identification, weighted average, FIFO, retail price and standard cost. Spare parts and materials held over 12 months must be classified as long-term assets. |
Manufacturers adopting standard costing review direct material and labor standards regularly and adjust them to current conditions, as Circular 99 requires.
3. Asset Accounting and Impairment Provisions
Circular 99 adds dedicated asset categories and clarifies measurement and impairment rules.
| Area | Circular 200 | Circular 99 |
|---|---|---|
| Trading Securities (TK 121) | Cost included purchase price plus brokerage fees, transaction charges, and taxes. | Measured initially at the fair value of the consideration paid. Transaction and brokerage fees are expensed immediately to Financial Expense (TK 635). |
| Held-to-Maturity Investments (TK 128) | Tracked term deposits, bonds and loans. A loss was recognized in financial expense when there was evidence of impairment, with provisioning rules spread across several accounts. | Provisions for losses go through TK 229 and are mandatory on objective evidence of default or doubt over recovery of principal or interest. |
| Fixed Asset Measurement | Historical cost, with accumulated depreciation recorded via TK 214. | Cost-based measurement continues for PPE (TK 211) and investment property (TK 217). If the going-concern assumption no longer holds, depreciation and impairment are written directly to carrying value without TK 214 or TK 229 (Article 24.7). |
| Construction in Progress (TK 241) | Circular 195/2012/TT-BTC applied to investor project management boards with separate accounting. Major repairs sat in TK 2413, and upgrades had no Level 2 account. | Replaces Circular 195/2012/TT-BTC (Article 31.1). Adds Account 2414 for upgrades and renovations; TK 2413 now covers periodic repairs and maintenance. Unfinished upgrade costs move from 2413 to 2414 on transition. |
| Biological Assets (TK 215) | No dedicated account; perennial crops and livestock were lumped into tangible PPE (TK 211). | Introduces dedicated Level 1 Account: TK 215 (Biological Assets) with provision account TK 2295, governing agro-forestry and aquaculture ventures. |
| BCC Non-Legal Entity Investments | Already had separate guidance: a business cooperation contract (BCC) without a legal entity stayed outside TK 228, and fixed-profit arrangements were treated as leases by substance. | TK 228 (2281) now takes investments in a BCC without joint control where the return depends on after-tax profit; balances in TK 138 transfer to TK 2281 on transition. The party receiving the contribution records a liability; a contributor with a profit-dependent return uses TK 2281, while a fixed-return contributor accounts for it as a lease or loan by substance. |
| Asset Impairment Provisions (TK 229) | Four Level 2 accounts: Securities (2291), Financial Investments (2292), Bad Debts (2293) and Inventory (2294), with supporting documents already required. | Adds TK 2295 (Biological Asset Impairment) and sets graduated provisioning rates (30%, 50%, 70% and 100%) by length of overdue period. |
Investment property held for capital appreciation is unchanged: neither circular depreciates it, and impairment losses go to cost of goods sold (TK 632). Circular 99 has no TK 246: TK 242 remains the only account for prepaid and deferred costs.
4. Liabilities and Equity Classification
Capital and obligation structures follow economic substance over legal form.
| Area | Circular 200 | Circular 99 |
|---|---|---|
| Dividends and Profits Payable | Grouped inside TK 3388 (Other Payables). | Separated into dedicated Level 1 Account: TK 332 (Dividends and Profit Payable). Detail balances in TK 338 move to TK 332 on transition. |
| Global Minimum Tax (TK 82112) | TK 821 had only 8211 and 8212, with no account for international supplementary taxes. | Adds Account 82112 for supplementary CIT expense under OECD Pillar Two (Decree 236/2025/ND-CP and Resolution 107/2023/QH15). |
| Short-Term Liability Classification | Already tied the split to the normal operating cycle where that cycle exceeds 12 months; the 12-month test applied only to enterprises with a cycle of 12 months or less. | Restates the split as 4 criteria (Article 20.4). Operating payables settling within a normal operating cycle remain short-term even if settlement exceeds 12 months. |
| Major Repair Accruals and Provisions (TK 352) | Allowed periodic major repairs of fixed assets to be accrued as a provision in TK 352. | An enterprise that was accruing major fixed-asset repair costs and had not yet carried out the repair when the Circular took effect stops accruing. When the repair happens, the actual cost is set against the accrued amount, and any difference is spread over the following periods (Article 30.4). TK 352 keeps provisions such as environmental restoration under VAS 18. |
| Redeemable Preferred Shares Classification | Presented as a liability where the issuer had to redeem at a fixed future date; otherwise recorded as equity. | Liability if the shares carry: (1) mandatory redemption at a set time or on specified conditions the issuer cannot refuse, (2) fixed dividends independent of results, or (3) conversion at market price. |
| Own Repurchased Shares (TK 419) | Designated as Treasury Shares. | Renamed to Own Repurchased Shares, detailing usage for employee bonus distributions in compliance with the Law on Enterprises 2020. |
| Common-Control Merger Difference (TK 4118 to 421) | Account 421 held undistributed after-tax profit. | Differences from common-control mergers are recorded in TK 4118 and amortized to TK 421 over no more than 10 years (Article 23). |
FDI joint-stock companies that issue preference shares review their charters and shareholder agreements to decide whether a hybrid instrument is presented as debt.
5. Revenue Recognition and Operating Expenses
Circular 99 keeps the risks-and-rewards principle for revenue from sales of goods (TK 511, five conditions), so the invoice date alone does not decide recognition timing. The changes sit in financial revenue (TK 515), other income (TK 711) and expense classification.
| Area | Circular 200 | Circular 99 |
|---|---|---|
| Financial Revenue (TK 515) | Gains on disposing of investments were already financial revenue, alongside interest, dividends and distributed joint venture profits. | Keeps net gains from disposing of financial investments (TK 121, 221, 222, 228) after offsetting impairment provisions (TK 229). Adds bond repurchase differences and foreign exchange revaluation gains. |
| Other Income from Written-Off Liabilities (TK 711) | Already took creditors that could not be identified, or did not claim payment, to TK 711. | Also covers debts determined not to be payable. |
| Expense Classification & Account Phase-Out | Retained Accounts 611 and 631. | Keeps functional classification (TK 632, 641, 642) and requires expenses to be tracked by element (materials, labor, depreciation, outsourced services) for the financial statement notes; nature-based presentation applies only where the business cannot present by function. Accounts 611 (Purchases) and 631 (Production Costs) no longer appear in the chart. |
6. Foreign Exchange Rates and Currency Translation
Foreign currency rules simplify exchange rate choices for groups with foreign functional currencies.
| Area | Circular 200 | Circular 99 |
|---|---|---|
| Actual Transaction Exchange Rate | Distinguished bank buying and selling rates depending on asset or liability type. | The actual rate may be the average transfer buying-selling rate of the commercial bank where regular transactions occur. |
| Approximation Exchange Rate | No approximate-rate option for transactions; an average rate could be used for report translation only within a 3% margin. | Permits an approximation rate (within +/-1% of the average transfer rate) for continuous accounting entries. |
| Year-End Monetary Balance Revaluation (TK 413) | Evaluated monetary assets at the buying rate and monetary liabilities at the selling rate. | Unified application: uses the average transfer buying-selling rate at the balance sheet date. |
| Foreign Currency Statement Translation | Already contained conversion rules for foreign-currency statements. | Keeps conversion into VND for statutory filing and adds the approximate-rate option for transactions. |
For how these rules compare with IFRS, see VAS vs IFRS differences.
7. Where to Go Next
Circular 99 applies from financial years beginning on or after January 1, 2026. The opening balance transfers, filing deadline and SME choice between Circular 133 and Circular 99 are covered in Part 1.
For overarching regulatory context, review the Accounting & Reporting Compliance guide, Chief Accountant regulations and Statutory Audit Requirements.
Indochina Link Vietnam’s advisory team provides statutory bookkeeping services and accounting services, including chart of accounts reconfiguration and Internal Accounting Policy development.
Legal Disclaimer:
This article provides general informational guidance on Circular 99 for reference purposes only and does not constitute formal legal, tax, or accounting advice. Enterprises must consult licensed accounting and audit professionals regarding their specific circumstances.
