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Circular 99: What Vietnam’s New Accounting Regime Means for IFRS Alignment
The Ministry of Finance has issued Circular No. 99/2025/TT-BTC (“Circular 99”), dated October 27, 2025, updating the Vietnam accounting regime by replacing outdated provisions and granting enterprises greater flexibility and autonomy in organizing their accounting systems.
Effective from January 1, 2026, Circular 99 replaces Circular No. 200/2014/TT-BTC (“Circular 200”) and provides guidance on the enterprise accounting regime. It applies to financial years beginning on or after that date.
The circular also introduces a number of notable updates, including new rules on preparing financial statements during corporate restructuring (division, separation, consolidation, and merger), the recognition of biological assets, additional corporate income tax under global minimum tax rules, and the classification of assets and liabilities as short-term or long-term on financial statements.
See also: Vietnam Audit Compliance 2026: What FOEs Need to Know
Implementation of Vietnam’s new accounting regime
Under Article 31 of Circular 99, the new regulation takes effect on January 1, 2026, and applies to all financial years beginning on or after that date.
Circular 99 simultaneously replaces the following accounting circulars:
- Circular 200 on the corporate accounting regime (except the provisions preserved under Article 31(2) of Circular 99);
- Circular No. 75/2015/TT-BTC amending Article 128 of Circular 200;
- Circular No. 53/2016/TT-BTC amending several provisions of Circular 200; and
- Circular No. 195/2012/TT-BTC guiding accounting for investors/project owners.
With this consolidation, Vietnam’s corporate accounting system now operates under a single, unified legal framework, reducing overlap and making it easier for enterprises to reference and apply the rules.
More emphasis on corporate governance and internal control
The circular stipulates that the initiation, execution, management, and oversight of enterprises’ economic transactions must adhere to applicable laws and relevant regulatory frameworks. Accordingly, enterprises are responsible for:
- Developing internal governance policies (or equivalent documentation);
- Carrying out internal control to clearly delineate the rights, obligations, and responsibilities of departments and individuals involved in these activities; and
- Ensuring compliance with enterprise laws and relevant laws.
Flexible functional currency
According to Circular 99, businesses can use either Vietnamese Dong (VND) or another functional foreign currency for their bookkeeping. The circular explains how businesses can determine, change, and convert their functional currency.
A functional currency must reflect the transactions, events, and conditions relevant to the enterprise’s operations. An enterprise must select its functional currency for bookkeeping based on the following criteria:
- Regularly used for payments, listing selling prices of goods or services, and costs; or
- Used to raise financial resources (issuance of debt or equity instruments), or is regularly received from business activities and retained as reserves.
Once established, the functional currency should only be changed if there is a significant shift in the enterprise’s operational or managerial environment that fundamentally alters these transactions, events, and conditions. If that occurs, businesses can only implement such a change at the beginning of a new accounting year.
This provides greater flexibility for FDI enterprises, import–export companies, and logistics firms, allowing them to report financial data more accurately in their main operating currency while remaining compliant with Vietnamese regulations.
Note: Vietnam requires financial statements published or submitted to competent authorities to be presented in Vietnamese Dong (VND), unless otherwise provided by law. If an independent audit firm must audit financial statements, the audited financial statements must also be presented in VND.
Principles for accounting source documents
Enterprises may design or modify their own accounting source document templates, provided that they comply with the Accounting Law.
When templates are newly created or amended, the enterprise must issue an Internal Governance Accounting Policy (IGAP), or equivalent document, explaining the necessity of the change and confirming its compliance with the law.
All economic or financial transactions associated with the enterprise’s operations must be recorded in accounting records. Each transaction should be documented with a single accounting record.
Detailed requirements regarding documents and accounting books in previous circulars, such as ink color and the number of copies, are eliminated.
Changes to the chart of accounts
Options to prepare a chart of accounts
According to Circular 99, a company has two options when preparing the chart of accounts during the initial accounting setup, including:
- Option 1: For a simple business model, the company may adopt the standard chart of accounts in the Circular and add sub-accounts as needed for internal management; or
- Option 2: The company can adopt the parent company’s chart of accounts to consolidate its financial statements more easily, including those of the Vietnamese entity.
Customizable chart of accounts
Enterprises may modify account names, account codes, structures, and the content reflected in accounts to suit business characteristics and management requirements.
Such modifications must:
- Ensure proper classification of transactions based on their economic substance;
- Avoid duplication;
- Comply with accounting principles;
- Not alter or affect the indicators presented in financial statements; and
- Be documented in the enterprise’s IGAP.
It is noteworthy that Circular 99 only provides guidance on the content and accounting methods for certain key economic transactions. Transactions not explicitly addressed in this circular must, considering their content and nature, be recorded in accordance with the provisions of the Law on Accounting, its guiding documents, Vietnam’s Accounting Standards, and the principles outlined in this circular.
Account adjustments
Several major adjustments are introduced to Vietnam’s corporate chart of accounts. Some accounts are removed, new accounts are added, and a number are renamed:
- Several accounts are renamed to provide clearer and more internationally aligned classifications for assets, liabilities, and equity, such as updating “Finished goods” to “Products,” “Prepaid expenses” to “Deferred expenses,” and “Share premium” to “Capital surplus.”
- New accounts are added to address biological assets and global minimum tax compliance, including detailed categories for biological assets(Account 215), dividends and profit payable (Account 332), tax-related expenses (Account 6275, Account 6415), and the additional CIT under Pillar Two (Account 82112).
- A wide range of legacy accounts is removed, particularly those relating to cash subclasses, financial instruments, tools and packaging, fixed assets, and public funding. This streamlining eliminates outdated categories and reduces overlap, resulting in a more transparent and modern reporting framework.
Amendments to the financial statement
Enterprises in all industries and economic sectors must prepare complete annual financial statements as specified in Appendix IV issued with Circular 99. The preparation of interim financial statements or financial statements for other accounting periods must comply with applicable laws or the enterprise’s management requirements.
In cases where relevant laws require enterprises to prepare interim financial statements but do not specify the type, they may choose to prepare either full or condensed interim financial statements.
Annual Financial Statements
Under Circular 99, the Balance Sheet has been replaced by the Statement of Financial Position. Vietnam’s corporate financial reporting system has been updated to include a new set of statements. The required reports now include:
- Statement of Financial Position;
- Profit and Loss (P&L) Statement;
- Statement of Cash Flows; and
- Notes to the Financial Statements.
Interim Financial Statements
Full Interim Financial Statements or Condensed Interim Financial Statements comprising:
- Interim Statement of Financial Position
- Interim Profit and Loss (P&L) Statement
- Interim Cash Flow Statement
- Selected Financial Statement Notes
Meanwhile, the previous regime mandated that annual and interim financial statements adhere to the templates in Appendix 2 of Circular 200. Enterprises may omit line items with no data and renumber the remaining indicators to maintain continuity.
Circular 200 designates the balance sheet as a core component of both annual and interim financial statements. With Circular 99, this structure changes. The balance sheet will no longer appear in the financial statement system. Instead, it is replaced by the statement of financial position, aligning Vietnam’s reporting framework more closely with international accounting standards.
Financial statements and accounting books must be signed by the legal representative and the chief accountant.
Audit requirements
All FDI enterprises must have their annual financial statements audited by a Vietnamese independent audit firm. These statements, including the audited ones, must be submitted to the local authorities within 90 days after the end of the fiscal year.
In certain cases, such as for listed companies, interim financial statements are also required.
Vietnam’s new regulations on accounting software
Under the new regime, enterprises are only permitted to use accounting software that:
- Complies with accounting and tax laws, meaning the software must not alter the fundamental nature, principles, or methods of accounting or impact figures in the books or financial statements;
- Ensures accuracy and transparency – data must be traceable, and all changes logged in chronological order;
- Secures data confidentiality and prevents unauthorized modifications through robust mechanisms;
- Provides timely and complete data outputs upon request by authorities;
- Supports integration with related systems such as e-invoicing platforms and digital signatures; and
- Is capable of being updated and upgraded to reflect changes in accounting and tax regulations.
In summary, the enterprises must issue an IGAP or equivalent documents in the following circumstances if there are any changes compared to Circular 99/2025/ TT-BTC:
- When designing or modifying accounting source documents;
- When modifying account names, codes, structures, or contents of the Chart of Accounts.
- When designing or modifying accounting book templates, and
- When adding new items or indicators to financial statements.
Implications of Circular 99 for Vietnam’s IFRS roadmap
Circular 99 establishes the legal foundation for implementation beginning from financial years starting on or after January 1, 2026, as well as during the transition phase of Vietnam’s shift toward a new accounting standards system.
Looking ahead, the MoF is set to continue overhauling the accounting legal framework by revising the Accounting Law and developing a new set of Vietnamese Financial Reporting Standards (VFRS). These standards will replace the current Vietnamese Accounting Standards (VAS) and are designed to converge with and align closely with IFRS.
As this transition progresses, Vietnam’s corporate accounting regime will undergo substantive changes in both structure and underlying principles.
“As more enterprises in Vietnam consider implementing an ERP (Enterprise Resource Planning) system for accounting recognition and financial statement preparation, this is an excellent opportunity to introduce the head office’s ERP system to Vietnamese subsidiaries. This strategy reduces worries about accounting document templates and the chart of accounts in line with Vietnamese Accounting Standards. Please update the IGAP accordingly to include any necessary modifications and ensure it remains compliant with the Law on Accounting and prevailing Vietnamese standards.” – Mia Pham, Deputy Director of Corporate Accounting Services, Dezan Shira & Associates
Enterprises operating in Vietnam should begin preparing for this shift by assessing the gaps between their current accounting practices and the forthcoming VFRS/IFRS-aligned framework. This includes reviewing accounting policies, updating internal systems, and evaluating the impact on financial reporting, tax obligations, and cross-border transactions. Companies should also consider staff training, upgrading accounting software, and engaging advisors to ensure smooth compliance once the new standards come into effect.
Early preparation will help businesses avoid implementation risks and stay aligned with Vietnam’s evolving financial reporting landscape.
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Vietnam Briefing is one of five regional publications under the Asia Briefing brand. It is supported by Dezan Shira & Associates, a pan-Asia, multi-disciplinary professional services firm that assists foreign investors throughout Asia, including through offices in Hanoi, Ho Chi Minh City, and Da Nang in Vietnam. Dezan Shira & Associates also maintains offices or has alliance partners assisting foreign investors in China, Hong Kong SAR, Indonesia, Singapore, Malaysia, Mongolia, Dubai (UAE), Japan, South Korea, Nepal, The Philippines, Sri Lanka, Thailand, Italy, Germany, Bangladesh, Australia, United States, and United Kingdom and Ireland.
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