Vietnam Accounting Compliance Guide for Foreign-Invested Enterprises: Circular 99/2025/TT-BTC

Vietnam’s Circular 99/2025/TT-BTC, in effect since 1 January 2026, gives enterprises greater flexibility over their accounting systems but also places more responsibility on management to document accounting policies, maintain effective internal controls, and substantiate professional judgements. Foreign-invested enterprises should review their implementation before completing their first financial year under the new regime.

Vietnam Circular 99 compliance: Key takeaways

• Circular No. 99/2025/TT-BTC (“Circular 99”) applies to financial years beginning on or after 1 January 2026. Companies with non-calendar financial years adopt the rules from the beginning of their first financial year starting on or after that date.
• Enterprises may customise specified accounting documents, books, and accounts, but changes must comply with accounting law and, where required, be supported by formal internal accounting regulations or equivalent documentation.
• Implementation extends beyond the finance department. It may require changes to enterprise resource planning (ERP) systems, approval workflows, account mappings, group-reporting packages, and financial-statement disclosures.
• Foreign-invested enterprises should distinguish Vietnam statutory accounting requirements from group reporting under International Financial Reporting Standards (IFRS). Circular 99 moves aspects of the Vietnamese regime closer to international practice but does not make the two frameworks equivalent.
• A documented gap assessment and mock financial close can help identify errors before statutory reporting and audit deadlines.

Background

On 27 October 2025, Vietnam’s Ministry of Finance issued Circular No. 99/2025/TT-BTC, replacing the principal enterprise accounting regime under Circular No. 200/2014/TT-BTC and related amending regulations.

The new circular took effect on 1 January 2026 and applies to financial years beginning on or after that date. It governs accounting source documents, accounts, accounting books, and the preparation and presentation of financial statements. Tax liabilities, invoices, and tax declarations remain subject to the relevant tax legislation rather than being determined by Circular 99.

Flexibility and implementation risk

Circular 99 gives companies greater scope to design accounting processes around their operations while requiring them to explain, approve, and consistently apply their choices. For foreign-invested enterprises, this creates an opportunity to improve alignment between the Vietnam subsidiary and the parent company, but it also raises the risk of control, documentation, and reporting gaps if implementation is treated as a technical bookkeeping exercise.

When does Circular 99 apply to a company?

Circular 99 applies from the beginning of the first financial year commencing on or after 1 January 2026. The date therefore depends on the company’s registered financial year.

The Ministry of Finance has confirmed that a company operating a July–June financial year applies Circular 99 from 1 July 2026 rather than changing accounting regimes midway through the financial year.

This distinction is important for companies with non-calendar reporting periods. Management should confirm the correct transition date, preserve a clear record of the accounting regime applied to each period, and ensure comparative information is prepared on the appropriate basis.

What should companies review under Circular 99?

1. Internal accounting regulations and controls

Circular 99 gives companies more autonomy, but that autonomy must operate within a documented governance framework. Enterprises are responsible for establishing internal rules and controls covering the initiation, execution, recording, approval, and review of economic and financial transactions.

The framework should clearly define:

• The authority and responsibilities of each department and employee involved in transactions;
• The separation of transaction initiation, approval, recording, payment, and review functions;
• The supporting documents required for different transaction types;
• The process for changing accounting policies, accounts, documents, or books;
• Access rights and approval workflows within accounting software; and
• The retention, retrieval, security, and correction of accounting data.

Companies that customise prescribed accounting documents, books, or accounts should establish whether the changes must be recorded in an internal accounting regulation or equivalent document. These policies should explain the reason for each modification, how it complies with Vietnam’s accounting rules, and who approved it.

For regional groups, the local policy should also identify where group instructions apply and where Vietnam’s statutory requirements take precedence.

2. Chart of accounts and opening balances

Circular 99 revises the prescribed chart of accounts. It removes certain accounts, introduces new ones, and renames or restructures others. Examples identified in professional guidance include the removal of accounts 161, 441, 611, and 631 and the introduction of accounts for biological assets, dividends payable, and global minimum tax top-up tax.

Enterprises may supplement accounts or amend specified account names, codes, structures, and contents to suit their operations and management needs. However, modifications must preserve the economic substance of transactions, avoid duplication, comply with applicable accounting principles, and support the correct presentation of financial-statement items.

Before year-end, finance teams should verify that:

• Retired or revised accounts have been mapped to the appropriate new accounts;
• Opening balances were transferred completely and accurately;
• Custom subaccounts reconcile with the statutory financial statements;
• Manual journals introduced during transition are supported and approved;
• The local chart of accounts maps correctly to the parent company’s group-reporting structure; and
• Mapping changes are reflected consistently in budgets, management reports, tax reconciliations, and consolidation packages.

A mapping table showing the former account, new account, effective date, rationale, approval, and financial-statement destination can provide a clear audit trail.

3. Accounting software and ERP configuration

Circular 99 implementation may require changes across accounting software, ERP platforms, expense systems, e-invoicing interfaces, banking feeds, consolidation tools, and group-reporting applications.

Accounting systems must protect the integrity, accuracy, confidentiality, traceability, and accessibility of financial data. Companies should therefore test whether:

• Revised account codes and reporting mappings have been configured correctly;
• Voucher and book formats contain the required information;
• User permissions correspond to authorised roles and segregation-of-duty rules;
• Changes and corrections are recorded in a chronological audit log;
• Interfaces with e-invoicing, tax, banking, inventory, and payroll systems reconcile;
• Statutory reports can be produced in the prescribed format;
• Electronic records and signatures can be authenticated and retrieved; and
• The system can be updated when accounting or tax requirements change.

Companies should retain evidence of system changes, user-acceptance testing, reconciliations, and management approval. Where spreadsheets or manual workarounds remain necessary, the related access, review, and version controls should also be documented.

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4. Functional currency and foreign exchange policies

Enterprises may use the Vietnamese dong or an eligible foreign currency as their functional accounting currency where the selected currency reflects the primary economic environment of their operations.

Foreign-invested enterprises should assess:

• Which currency principally influences sales prices, receipts, labour, materials, and other major costs;
• Which currency is used to raise and retain financing;
• Whether the conclusion is supported by the company’s actual transaction profile;
• Whether the exchange-rate source and methodology are documented and consistently applied; and
• Whether statutory financial statements are properly translated into Vietnamese dong.

A functional currency may be changed only at the beginning of a financial year and when a significant change in the company’s operations or management environment justifies it. The reasons for the change and its financial effects must be appropriately disclosed.

Companies should not assume that accounting exchange rate policies automatically govern invoices or tax declarations. The Ministry of Finance has clarified that invoicing and tax declarations for foreign currency transactions remain subject to tax law.

For a detailed explanation, see Vietnam Briefing’s guide to functional currency under Circular 99.

5. Transaction-specific accounting policies

Circular 99 introduces or clarifies accounting treatment for several areas that may require new policies, judgements, or system configurations.

These assessments should be supported by contracts, calculations, valuation evidence, management conclusions, and approval records. Where a transaction is not expressly addressed, its economic nature should be assessed against the Accounting Law, implementing regulations, Vietnamese Accounting Standards, and the principles of Circular 99.

6. Financial statement presentation and disclosures

Circular 99 replaces the “Balance Sheet” title with “Statement of Financial Position” and prescribes the annual financial statement package, including:

• The Statement of Financial Position;
• The Profit and Loss Statement;
• The Statement of Cash Flows; and
• Notes to the Financial Statements.

Enterprises must use the prescribed statement templates. Additional captions may be introduced where appropriate, but companies should not treat the greater flexibility available for accounts and books as permission to redesign mandatory financial statements without regard to the circular.

Year-end procedures should address:

• Classification of assets and liabilities as current or non-current;
• Consistent comparative information;
• Significant accounting policies and changes in those policies;
• Material assumptions and sources of estimation uncertainty;
• Restricted cash and other significant financial-statement items;
• Biological assets and business cooperation contracts, where relevant;
• Dividends payable and issued bonds;
• Global minimum tax exposures;
• Acquisitions or disposals of subsidiaries;
• Intercompany transactions and consolidation methods; and
• Management’s going-concern assessment.

Annual financial statements generally remain due within 90 days after the end of the financial year, subject to any sector-specific or other applicable requirements. If published financial statements have been independently audited, the audit report should accompany them.

7. Consolidation and group reporting

Foreign-invested enterprises commonly maintain one set of records for Vietnam statutory reporting and a separate reporting package for consolidation by an overseas parent. Circular 99 may make some aspects of this process easier, particularly where a company customises its account structure to improve group mapping. It does not eliminate differences between Vietnamese accounting requirements and IFRS or another parent-company framework.

Before submitting a reporting package to headquarters, the Vietnam entity should confirm that:

• Subsidiary, branch, and dependent-unit balances have been reconciled;
• Intercompany sales, purchases, loans, interest, dividends, and balances agree between counterparties;
• Consolidation eliminations are complete and supported;
• Statutory-to-group adjustments are separately identified;
• Foreign currency translation is consistent across reporting systems; and
• Responsibilities for statutory reporting, group adjustments, consolidation, and review are clearly assigned.

Circular 99 reflects a more principles-oriented approach and brings aspects of Vietnamese reporting closer to IFRS. Nevertheless, material differences remain, including in areas such as expected credit losses, derivatives, lease accounting, fair value measurement, and financial-risk disclosures. Companies should therefore maintain a formal VAS-to-IFRS or VAS-to-group-GAAP reconciliation where applicable.

Circular 99 audit-readiness checklist

Companies preparing their first financial statements under Circular 99 should maintain a central implementation and audit file containing, as applicable:

• The approved internal accounting regulations;
• The revised chart of accounts and account-mapping schedule;
• A Circular 99 gap assessment and implementation plan;
• Opening-balance and comparative-information reconciliations;
• ERP configuration, testing, and approval records;
• Functional-currency assessment and exchange-rate policy;
• Accounting position papers for significant or unusual transactions;
• Key estimates, impairment calculations, and valuation evidence;
• Related-party and intercompany reconciliations;
• Consolidation and elimination schedules;
• Statutory-to-group reporting reconciliations;
• Draft financial statements and a disclosure checklist;
• Transition journals and their supporting calculations; and
• Records of finance-team training and management review.

Changes in accounting policies arising from Circular 99 should follow the transition provisions in the circular. Where Circular 99 does not prescribe specific transitional treatment, enterprises should consider the requirements of Vietnamese Accounting Standard 29 on changes in accounting policies, accounting estimates, and errors.