FDI companies in Vietnam report to seven or more agencies, and the figures must match across all of them. International investors often assume compliance means monthly VAT filings and annual CIT finalization. In practice, a foreign-invested company sits under continuous oversight from the supervisory Tax Authority, the Investment Registration Authority (the provincial Department of Finance, which incorporated the former Department of Planning and Investment (DPI) under Decree 150/2025/ND-CP, or the Industrial Zone Authority), the provincial focal agency for investment supervision and evaluation, the statistics authority, the Department of Industry and Trade (DOIT), the State Bank of Vietnam (SBV), and the Department of Home Affairs, which took over labor management from the Department of Labor, Invalids and Social Affairs under the same Decree.
The year 2026 also changes the accounting rules. The Ministry of Finance issued Circular 99/2025/TT-BTC, replacing Circular 200/2014/TT-BTC effective January 1, 2026, and Decision 345/QD-BTC sets the roadmap for International Financial Reporting Standards (IFRS) and Vietnamese Financial Reporting Standards (VFRS). FDI companies need to adjust their ERP charts of accounts, voucher workflows and internal accounting policies. A company still building its books can start with accounting setup for FDI companies.
Missing non-tax reports or leaving data inconsistent across agency databases leads to cumulative administrative fines of tens of millions of VND. This guide covers the accounting framework, the audit and reporting duties, and an annual compliance calendar. Changes to the Investment Registration Certificate (IRC) follow their own procedure.
1. Vietnamese Accounting Standards Framework and Circular 99/2025 Transition
Vietnam’s accounting rules sit in two tiers. The statutory foundation is the Law on Accounting 88/2015/QH13 (as amended by Law No. 56/2024/QH15) and 26 Vietnamese Accounting Standards (VAS) issued by the Ministry of Finance between 2001 and 2005. VAS governs asset recognition, liability measurement, revenue criteria and expense matching. The second tier is Ministry of Finance circulars, which set the default chart of accounts (adaptable under Article 11.2 of Circular 99), journalizing methods, statutory financial statement templates and voucher retention rules.
For over a decade, Circular 200 was the main corporate accounting regime. On October 27, 2025, the Ministry of Finance issued Circular 99/2025/TT-BTC, effective January 1, 2026. It applies to fiscal years beginning on or after that date; entities whose fiscal year began earlier finish that year under Circular 200.
The core technical reforms in Circular 99 are:
- Sub-account autonomy with an internal regulation: Under Article 11.2, FDI enterprises may amend or add the name, number, structure and content of accounts to fit international ERP systems (SAP, Oracle, NetSuite), provided the figures in the financial statements do not change. The company must also issue an Internal Accounting Policy Regulation (or equivalent document), which serves as audit evidence.
- A retitled Statement of Financial Position and new accounts: The balance sheet becomes the “Statement of Financial Position.” Circular 99 adds accounts for newer transactions:
- Account 215 (Biological Assets): records agricultural crops and livestock, paired with Account 2295 (Allowance for Impairment of Biological Assets).
- Account 332 (Dividends and Profits Payable): separates profit distribution liabilities from trade payables, which simplifies offshore remittance audits.
- Account 82112 (Top-up Corporate Income Tax Expense): records tax under Global Minimum Tax (GloBE / QDMTT) rules pursuant to Resolution 107/2023/QH15.
- Redeemable preferred shares: presented as liabilities rather than equity where they carry mandatory redemption, fixed mandatory dividends, or conversion at market price.
- Accounts 611 and 631: Account 611 (Purchases) and Account 631 (Production Costs) no longer appear in the chart of accounts.
- Revenue recognition: Revenue from sales of goods is recognized when the enterprise has transferred most of the risks and rewards of ownership to the buyer (guidance on Account 511), not merely when the invoice is issued.
- Currency and document retention: Entities may keep books in a foreign currency under Circular 99 if it is the primary transaction currency, but filings to state authorities must be converted into Vietnamese Dong (VND). Vouchers used directly for bookkeeping, ledgers and annual financial statements must be kept for at least 10 years, and management records for at least 5 years (Accounting Law).
Read the detailed comparison of Circular 99 and Circular 200. For outsourced ledgers and account mapping under Circular 99, see bookkeeping services.
2. IFRS and VFRS Roadmap Under Decision 345/QD-BTC
The gap between VAS and IFRS is a major hurdle for multinational groups. Decision 345/QD-BTC (March 16, 2020) sets three stages for IFRS:
- Preparation (2020-2021): statutory translations, professional training and regulatory frameworks.
- Voluntary application (2022-2025): mainly consolidated statements of large state-owned groups and listed or large public parent companies.
- Mandatory application (after 2025): the Ministry of Finance sets the scope and timing after reviewing the voluntary stage. Standard FDI enterprises still prepare statutory statements under VAS, and Circular 118/2026/TT-BTC (effective January 1, 2027) lets only members of the International Financial Centre in Vietnam adopt IFRS voluntarily.
The Ministry of Finance is also finalizing VFRS, adapting IFRS to local economic and legal conditions.
Regional comparison of accounting regimes:
| Jurisdiction | National Accounting Framework | IFRS Convergence Level | Dual-Reporting Requirement | Statutory FDI Audit Mandate |
|---|---|---|---|---|
| Vietnam | VAS under Circular 99 (VFRS in preparation) | Phased roadmap under Decision 345 | Common in practice (VAS for tax, IFRS package for parent) | Mandatory for all FDI enterprises |
| Singapore | SFRS (Singapore FRS) | Near 100% equivalence to IFRS | Non-mandatory, direct SFRS adoption | Exemptions for small companies |
| Malaysia | MFRS (Malaysian FRS) | Full compliance with IFRS framework | Direct MFRS usage for tax and filings | Mandatory for private LLCs |
| Thailand | TFRS (Thai FRS) | Segmented into PAEs and NPAEs | Voluntary for non-listed entities | Mandatory for all registered entities |
Most foreign-invested corporations in Vietnam run a dual-reporting regime: statutory VAS general ledgers serve local tax finalization and licensing authorities, while reporting packages reconcile differences for group consolidation.
Three core technical divergences between VAS and IFRS:
- Lease accounting (IFRS 16 vs VAS 06): IFRS 16 removes the operating lease distinction for lessees and requires Right-of-Use (ROU) assets and lease liabilities on the balance sheet. VAS 06 still permits straight-line operating expense treatment.
- Fair value measurement (IFRS 13): IFRS requires or permits fair value revaluation for fixed assets, investment property and financial derivatives. VAS stays on historical cost.
- Asset impairment (IAS 36): IFRS requires periodic impairment testing for goodwill and long-term assets with immediate loss recognition. VAS handles deterioration mainly through accounting provisions.
Conversion mechanics are covered in the VAS and IFRS advisory guide.
3. Statutory Financial Audit Mandate and Profit Repatriation Conditions
Every FDI company must have its annual financial statements audited by an independent audit firm licensed by the Ministry of Finance, regardless of charter capital, revenue or headcount (Law on Independent Audit 67/2011/QH12, as amended, and Decree 17/2012/ND-CP). The audited statements go to the supervisory Tax Authority through eTax within 90 days of fiscal year-end (March 31 for calendar-year entities), together with the CIT finalization dossier. Late filing is fined VND 5-20 million depending on the delay, while no filing or no mandatory audit is fined VND 40-50 million (Decree 41/2018/ND-CP; Decree 228/2025/ND-CP).
The audit report also gates offshore profit repatriation. Under Article 27.6 of Decree 252/2026/ND-CP, an investor can remit profit abroad only after the audited statements and CIT return are filed, all taxes, late-payment interest and fines due are paid, and no accumulated loss remains after loss carry-forward. Where a bank needs proof, request tax-obligation confirmation on Form 01/ĐNXN (Article 44, Circular 89/2026/TT-BTC); the tax authority replies within 10 working days. Choose and sign with the audit firm between September and November. The statutory audit guide walks through the timeline, and audit support services cover preparation.
4. Chief Accountant Requirements and Legal Liabilities
Every FDI company must appoint a qualified Chief Accountant (Accounting Law; Decree 174/2016/ND-CP). Micro-enterprises under the law on support for small and medium-sized enterprises may appoint a Person in Charge of Accounting instead. A company that cannot appoint one immediately may assign a Person in Charge of Accounting for up to 12 months or hire a licensed accounting service, and must have a Chief Accountant in place after that.
Failing to appoint a Chief Accountant is fined VND 20-40 million for an organization, and appointing an unqualified one VND 40-60 million (Article 17.2-3, Decree 41/2018/ND-CP; individual rates are half). Qualifications, personal liability and outsourcing are covered in Chief Accountant requirements in Vietnam.
5. Non-Tax Periodic Reporting Obligations to Specialized Authorities
Beyond tax returns, FDI companies file three types of investment reports plus sector reports on labor, trade and foreign exchange. Each report has its own system, deadlines and fines.
| Investment report | Period and deadline | Where to file | Fine (organization) |
|---|---|---|---|
| Investment report (project implementation report) | Quarterly: before the 10th of the first month of the next quarter. Annual: before March 31 | National Investment Information System; received by the Department of Finance or Industrial Zone Authority and the local statistics office | VND 30-50 million |
| Investment supervision and evaluation report | Quarterly: before the 10th of the first month of the next quarter. Six-month: before July 10. Annual: before February 10. Before any project adjustment | Ministry of Finance (MOF) investment supervision and evaluation system, with a digital signature | VND 20-30 million |
| Statistical reports | Set by the survey plan, when the company is selected | Statistics Office (under the MOF since March 1, 2025) and local statistics offices | VND 14-20 million for not taking part in a survey |
The investment report is filed under Decree 96/2026/ND-CP. The supervision and evaluation report is a separate obligation under Decree 19/2026/ND-CP, which replaced Decree 29/2021/ND-CP, and it’s the one companies most often miss. Fines for both sit in Article 15 of Decree 122/2021/ND-CP.
The first two reports run on two systems with two sets of forms, while their quarterly and annual cycles overlap. Prepare the shared figures (capital, revenue, headcount, taxes) once and use the same numbers in both. Who files, what goes in and how to register each system account are in the guide to FDI investment, supervision and statistical reporting, and the ICLV FDI reporting service prepares and files them.
Sector reports go to three other authorities. The Department of Home Affairs receives labor change reports (by June 5 and December 5) and, with the provincial Department of Health, the annual occupational safety and health report (by January 10). DOIT receives goods-trading reports on January 15 and July 15, plus annual reports from representative offices. SBV receives monthly foreign loan reports by the 5th and oversees the foreign investment capital account. Fines for each are listed with the dates in the calendar in Section 7.
6. Cross-Agency Data Reconciliation and Inter-Departmental Audit Pitfalls
Tax authorities in Vietnam can cross-check data held by different agencies. Discrepancies between eTax, the National Investment Information System, the national social insurance database (VSS) and SBV banking portals are common triggers for inspection queries:
| Checkpoint | Data compared | Result of a mismatch |
|---|---|---|
| 1 | Registered charter capital, Account 411 and capital account transfers | Fines for delayed capital contribution |
| 2 | CIT salary deductions, PIT withholdings and VSS enrollments | Social insurance arrears; CIT-deductible payroll disallowed |
| 3 | IRC project commercial milestone and fixed asset depreciation | Queries on the depreciation start date |
| 4 | Audited related-party notes and the transfer pricing local file | Tax assessment under Article 21, Decree 255/2026/ND-CP |
FDI enterprises should apply a “Single Source of Truth” principle: figures reported to investment authorities, statistics offices, foreign exchange portals and labor bureaus must reconcile back to the audited VAS general ledger. Risks on inter-company transactions are covered in related-party transactions and transfer pricing.
7. Standard Operating Procedures and Annual FDI Corporate Compliance Calendar
To avoid reporting bottlenecks around March 31, foreign-invested companies should run a 5-step Standard Operating Procedure (SOP):
- Monthly voucher closure: Verify 100% electronic invoice authenticity, reconcile commercial bank accounts and capital account ledgers, and settle statutory social insurance contributions.
- Monthly and quarterly inter-departmental reconciliation: Reconcile quarterly VAT and provisional CIT returns against general ledger revenue, submit quarterly investment reports through the National Investment Information System by the 10th, and file SBV foreign debt reports by the 5th.
- Q4 statutory audit engagement: Choose and sign with an accredited independent audit firm between September and November, and coordinate year-end physical inventory and fixed asset stock counts.
- Audit report completion (January - February): Provide balance confirmations, settle audit adjustments and obtain an unmodified audit report before March 15.
- Statutory filing (March): File the audited financial statements with the Tax Authority together with the CIT finalization dossier, lodge the annual investment-activity report on the National Investment Information System and, where needed, submit the tax-obligation confirmation request (Form 01/ĐNXN) ahead of any profit remittance.
Master FDI Statutory Compliance Calendar
| Statutory Deadline | Recipient Authority | Mandatory Filing / Compliance Requirement | Legal Basis & Sanctions |
|---|---|---|---|
| 5th of next month | State Bank (SBV) | Monthly Foreign Loan Borrowing & Repayment Report | Administrative fines under Decree 340/2025/ND-CP |
| 10th of next quarter | Department of Finance / IZA | Quarterly Investment Activity Report via the National Investment Information System | Fines VND 30-50M (Article 15, Decree 122/2021/ND-CP) |
| 10th of next quarter | Department of Finance / IZA and provincial supervision focal agency (MOF system) | Quarterly Investment Supervision and Evaluation Report | Fines VND 20-30M (Article 15, Decree 122/2021/ND-CP) |
| Jan 10 | Dept of Home Affairs & Health Dept | Annual Occupational Safety & Health Report | Fines VND 2-6M for late or missing reports (Article 31(2), Decree 283/2026/ND-CP; individual rate 1-3M, doubled for organizations) |
| Feb 10 | Department of Finance / IZA and provincial supervision focal agency (MOF system) | Annual Investment Supervision and Evaluation Report | Fines VND 20-30M (Article 15, Decree 122/2021/ND-CP) |
| Jul 10 | Department of Finance / IZA and provincial supervision focal agency (MOF system) | Six-Month Investment Supervision and Evaluation Report | Fines VND 20-30M (Article 15, Decree 122/2021/ND-CP) |
| Jan 15 and Jul 15 | Licensing authority (via the one-stop unit or the MOIT database) | Goods Trading Operations Report (annual and first half) | Decree 342/2026/ND-CP; license revocation after 24 consecutive months without reports |
| Annual | DOIT / licensing authority | Commercial Representative Office Annual Activity Report | Decree 07/2016/ND-CP; handled by the licensing authority under commercial law |
| Jan 31 | Tax Authority | Q4 Provisional CIT Payment (Article 24, Decree 252/2026/ND-CP) | Late payment interest of 0.03% per day applies only if the four quarterly payments total less than 80% of the final CIT liability, counted on the shortfall (Article 24.3; Law on Tax Administration 108/2025). A deadline falling on a day off moves to the next working day |
| Mar 31 | Tax Authority | Annual Corporate Income Tax (CIT) & PIT Finalization | Penalties under Law on Tax Administration |
| Mar 31 | Tax Authority | Annual Audited Financial Statements Submission (with the CIT finalization dossier) | Late filing VND 5-20M; no filing VND 40-50M (Decree 41/2018/ND-CP); no mandatory audit VND 40-50M (Decree 228/2025/ND-CP) |
| Mar 31 | Department of Finance / IZA | Annual Investment Implementation Report (National Investment Information System) | Fines VND 30-50M (Article 15, Decree 122/2021/ND-CP) |
| Per survey decision | Statistics Authority | Statistical Survey Filing (if selected) | Penalties under the administrative penalty rules for statistics |
| Jun 5 & Dec 5 | Dept of Home Affairs | Labor Change Report (six months by Jun 5, full year by Dec 5) | Fines VND 10-20M (Decree 283/2026/ND-CP, Art. 11.2(c); individual rate 5-10M, doubled for organizations) |
Indochina Link Vietnam provides licensed corporate accounting and tax compliance services, representing multinational enterprises directly before the Tax Authority, Department of Finance, statistics authority, DOIT and State Bank of Vietnam. Contact the ICLV accounting and IFRS team to review your compliance setup.
Legal Disclaimer:
This guide provides general informational guidance on accounting and reporting regulations in Vietnam and does not constitute formal legal, accounting, or tax advice. Enterprises must consult licensed professionals regarding specific regulatory compliance.
