Foreign-invested enterprises in Vietnam face accounting and reporting obligations that go well beyond annual financial statements. VAS-compliant bookkeeping under the Accounting Law 88/2015/QH13, mandatory statutory audit, 5+ periodic government reports to different agencies, and now the transition from Circular 200/2014 to Circular 99/2025/TT-BTC — all running on overlapping deadlines that cluster around March 31 each year.
This guide maps every obligation, deadline, and compliance risk for FDI finance teams.
Vietnamese Accounting Standards (VAS)
VAS Framework & the Circular System
Vietnam’s accounting operates on two layers. The first is VAS (Chuẩn mực Kế toán Việt Nam) — 26 accounting standards issued by the Ministry of Finance between 2001 and 2005, covering principles for revenue recognition, fixed assets, financial instruments, and more. These are roughly equivalent to IFRS in function but diverge in key areas: lease treatment, fair value measurement, and consolidation rules.
The second layer is the implementing circular — the detailed guidance that tells enterprises how to apply VAS in practice. This includes the standardized chart of accounts, financial statement formats, capitalization thresholds, and bookkeeping procedures. Unlike IFRS where companies design their own chart of accounts, Vietnam prescribes specific account codes — all enterprises use Account 111 for Cash, Account 511 for Revenue, etc.
For a detailed comparison between VAS and IFRS, see our VAS-IFRS guide for FDI →.
Circular 99/2025 — The New Implementation Framework
From 2015 through 2025, Circular 200/2014/TT-BTC served as the implementing circular for VAS — governing how every enterprise in Vietnam maintained its books. From January 1, 2026, Circular 99/2025/TT-BTC replaces Circular 200 entirely — the biggest change to Vietnam’s accounting regime since 2003.
What changed: 12 new standards added, 12 existing standards revised, updated revenue recognition guidance, new financial instrument classifications, and enhanced disclosure requirements. The chart of accounts is restructured — companies must update their accounting software and retrain staff before the first 2026 reporting period.
For a detailed account-by-account comparison between Circular 200 and Circular 99, see the technical deep-dive.
Bookkeeping & Record-Keeping Requirements
Accounting software: Most FDI companies use accounting software — either Vietnam-specific platforms (MISA, FAST) or international systems (SAP, Oracle) configured for VAS compliance. The software must be capable of generating reports in the prescribed Vietnamese formats.
Document storage: Accounting documents must be retained for a minimum of 10 years under the Accounting Law 88/2015/QH13. Electronic storage is permitted under Decree 174/2016/NĐ-CP, but original signed documents — especially contracts and bank confirmations — must be preserved.
Currency: Bookkeeping in foreign currency is permitted if it’s the enterprise’s primary transaction currency, but all financial statements filed with Vietnamese authorities must be converted to VND. In practice, most FDI companies choose VND as their functional bookkeeping currency to simplify compliance, then convert back to parent company currency for group consolidation.
Language: Accounting records must be in Vietnamese. Many FDI companies maintain books in the parent company’s language through group ERP systems — this works internally, but when submitting financial statements to tax authorities or during inspections, everything must be in Vietnamese. The practical approach: maintain bilingual bookkeeping from the start, or ensure the VAS conversion output includes Vietnamese-language entries. Translating retroactively during an audit is costly and error-prone.
VAS governs the enterprise’s statutory books in Vietnam. But if the parent company reports under IFRS, the FDI subsidiary operates in two accounting worlds simultaneously — and the gap between them drives most of the reconciliation work FDI finance teams face.
IFRS Adoption in Vietnam
Roadmap: Decision 345/QĐ-BTC
Vietnam has not fully adopted IFRS. The Ministry of Finance issued Decision 345/QĐ-BTC in 2020 establishing a three-phase roadmap: preparation (2019-2021), voluntary pilot (2022-2025), and compulsory adoption from 2026 onward. The compulsory phase applies to consolidated financial statements of listed companies, large SOEs, and large unlisted public companies.
FDI subsidiaries can voluntarily apply IFRS for their statutory financial statements after notifying MoF — but this does not exempt them from VAS obligations for tax and regulatory reporting.
VFRS — The New Standards
Vietnam is developing Vietnamese Financial Reporting Standards (VFRS) to replace VAS. Unlike direct IFRS adoption, VFRS converges with IFRS while accommodating local regulatory context — similar to how China uses CAS (Chinese Accounting Standards) rather than pure IFRS. Circular 99/2025 is the first major step in this convergence, aligning VAS closer to IFRS in practice without formally adopting the full framework.
Dual Reporting for FDI
Most FDI companies operate under dual reporting: VAS-compliant statutory books for Vietnamese authorities, and IFRS-based packages for group consolidation. The key differences that create reconciliation work: revenue timing under VAS vs. IFRS 15, lease treatment (VAS has no IFRS 16 equivalent yet), and fair value measurement scope.
Finance teams should map the VAS-IFRS gaps specific to their industry and build automated conversion templates rather than performing manual adjustments each reporting period.
Compliance Requirements
Tax Compliance
Tax filings drive the most frequent compliance deadlines — VAT monthly or quarterly, CIT quarterly provisionals, and annual finalizations within 90 days. Tax compliance interacts directly with accounting: the enterprise’s VAS financial statements feed into CIT finalization, VAT input credits depend on proper invoice booking, and PIT withholding requires accurate payroll accounting.
Unlike Singapore where IRAS handles both tax and financial filings through a single portal, Vietnam splits these across multiple agencies — making the FDI reporting calendar below significantly more complex than what most regional headquarters expect.
For a complete breakdown of rates, filing deadlines, incentives, and audit risks, see our Vietnam Tax System hub →.
Financial Statement Filing
Annual financial statements must be submitted within 90 days of fiscal year-end — typically March 31 for calendar-year enterprises. Statements must be in Vietnamese and in VND. The filing goes to multiple recipients: Tax Authority, Department of Finance (formerly DPI) (Department of Finance (formerly Department of Finance (formerly DPI))), and GSO (General Statistics Office).
Late financial statement submission carries fines of VND 5-10 million (~USD 200-400) under Decree 41/2018/NĐ-CP. But the bigger risk is downstream — late financial statements delay the statutory audit, which delays CIT finalization, which blocks profit repatriation.
Statutory Audit
All foreign-invested enterprises must complete annual statutory audits regardless of revenue or employee count — a requirement that applies specifically to FDI companies, not to all domestic enterprises. The audit must be performed by a Vietnamese-licensed audit firm and completed within the 90-day filing window.
Audit reports are submitted alongside financial statements to the Tax Authority, Department of Finance (formerly DPI), and GSO. Selecting an audit firm with FDI experience is critical — auditors unfamiliar with dual-reporting structures or TP documentation often miss compliance gaps that trigger tax authority scrutiny later.
Chief Accountant
Every enterprise must appoint a chief accountant who meets Vietnamese qualification requirements — including holding a Vietnamese accounting certificate or equivalent recognized credential. Foreign nationals can serve in this role under specific conditions, but must demonstrate Vietnamese accounting knowledge.
The chief accountant bears personal legal liability for financial statement accuracy under the Accounting Law 88/2015/QH13. This personal liability exposure is why an increasing number of FDI companies outsource the chief accountant function to licensed accounting firms — transferring both the compliance burden and the liability.
FDI Reporting Obligations
Beyond accounting and tax filings, FDI enterprises must submit periodic reports to multiple government agencies. Missing these reports is one of the most common compliance failures for foreign-invested companies — partly because parent companies abroad don’t realize these obligations exist.
In Thailand or Malaysia, post-investment reporting consolidates under the BOI or MIDA respectively. Vietnam requires separate submissions to 5+ agencies — Department of Finance (formerly DPI), GSO, DOIT, SBV, DOLISA — each with different formats, systems, and deadlines. This fragmentation is the single biggest operational surprise for FDI finance teams.
Investment Implementation Reports (Department of Finance (formerly DPI))
FDI enterprises must submit investment implementation reports to Department of Finance (formerly DPI) — quarterly and annually. The legal basis: Article 72, Law on Investment 2020, and Decree 31/2021/NĐ-CP.
- Quarterly reports: By the 10th of the first month of the following quarter, via the National Investment Information System
- Annual reports: By March 31 of the following year
Reports cover capital disbursement progress, revenue, employment, and environmental compliance. Failure to submit carries fines of VND 30-50 million (~USD 1,200-2,000) per violation.
Investment Monitoring Reports (Department of Finance (formerly DPI))
Separate from implementation reports, monitoring reports under Decree 29/2021/NĐ-CP (Form A.III.2, Circular 03/2021/TT-BKHDT) are submitted semi-annually and annually by March 31. These cover financial performance, employee income, R&D expenditure, and technology utilization. Penalty for non-compliance: VND 20-30 million (~USD 800-1,200).
Statistics Reports (GSO)
Under the Statistics Law, FDI enterprises submit reports at multiple frequencies:
- Monthly: By the 12th of the following month
- Quarterly: By the 12th of the last month of the following quarter
- Annual: By March 31
Reports feed into national economic indicators. Requirements vary by enterprise size and sector.
Trading Activity Reports (DOIT)
FDI companies with trading licenses must submit annual reports to the provincial Department of Industry and Trade by January 31, under Decree 09/2018/NĐ-CP Article 40. This applies to companies conducting goods trading and related activities.
Foreign Loan Reports (SBV)
Foreign loans exceeding one year must be registered with the State Bank of Vietnam under Circular 12/2022/TT-NHNN. Even short-term deferred import payments qualify as foreign debt and require monthly SBV reporting from day one. Changes to loan terms — interest rate, maturity, repayment schedule — require re-registration. Late registration carries fines of VND 40-60 million (~USD 1,600-2,400) for organizations under Decree 340/2025/ND-CP.
Labor Reports
Labor usage reports are submitted to DOLISA (Department of Labor, Invalids, and Social Affairs), typically aligned with the March 31 annual reporting deadline. FDI companies with foreign workers must also maintain work permit compliance documentation — see our Vietnam labor law compliance guide for details.
Common Compliance Risks
The obligations above — VAS bookkeeping, statutory audit, tax filings, and 5+ agency reports — don’t fail individually. They fail as a system. Three patterns consistently cause compliance failures for FDI companies:
Deadline clustering around March 31. Financial statements, audit reports, CIT finalization, investment reports, monitoring reports, statistics reports — all converge on the same 90-day window after fiscal year-end. Companies that don’t start the process in January always face a bottleneck in March.
Report fragmentation. Five different agencies (Tax Authority, Department of Finance (formerly DPI), GSO, DOIT, DOLISA) each require separate submissions in different formats through different systems. No single portal consolidates all FDI reporting. Missing one report while completing others is common.
Language and format mismatch. FDI companies maintaining group-standard bookkeeping in foreign languages and currencies must convert to Vietnamese and VND for every filing. Companies that don’t build this conversion into their monthly close process accumulate technical debt that explodes during annual reporting season.
Need compliance calendar management? Indochina Link Vietnam provides Ministry of Finance-licensed accounting and reporting services — from monthly VAT filings through year-end financial statements and all periodic government reports across the Tax Authority, Department of Finance (formerly DPI), GSO, DOIT, and SBV.
Legal Disclaimer
This article provides general information about Vietnam accounting and reporting obligations. It does not constitute legal, tax, or accounting advice.
Regulations cited (including Accounting Law 88/2015/QH13, Circular 99/2025/TT-BTC, and related Decrees) 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.
