Effective date: 1 January 2026

Circular No. 99/2025/TT-BTC introduces a series of important amendments to Vietnam’s accounting framework, marking another step in the Ministry of Finance’s efforts to modernize financial reporting, strengthen corporate governance, and enhance the transparency and reliability of accounting information. The Circular does not merely revise technical accounting forms; rather, it reshapes how enterprises prepare, authorize, present, and manage accounting records and financial statements.

These changes will affect enterprises across sectors, particularly those with complex internal structures, foreign-invested capital, or cross-border operations. As the effective date approaches, businesses should proactively assess the implications of the Circular on their accounting systems, internal control mechanisms, and compliance practices to ensure a smooth transition.

Preparation, Signing, and Control of Accounting Documents

One of the core focuses of Circular 99 is the reinforcement of discipline in the preparation and management of accounting documents. Accounting vouchers remain the legal foundation of all accounting records, and the Circular emphasizes stricter adherence to fundamental principles governing their use.

Mandatory Documentation of All Transactions

Under Circular 99, all economic and financial transactions arising from business operations must be documented using accounting vouchers, and each transaction may only be documented once. This principle, while not entirely new, is reaffirmed to address ongoing risks related to duplicate recording, incomplete documentation, or inconsistent transaction recognition across departments.

For enterprises with decentralized accounting functions or multiple operational units, this requirement underscores the importance of standardized procedures and clear communication between departments. Transactions involving procurement, sales, asset transfers, and internal cost allocations should be clearly traceable from source documents through to accounting records and financial statements.

Delegation of Signing Authority

The Circular also clarifies that the delegation of signing authority on accounting documents must strictly comply with:

• Relevant legal regulations
• Internal management requirements
• Internal governance and authorization rules of the enterprise

This provision highlights that delegation cannot be informal or implied. Enterprises are expected to have clear, documented authorization frameworks that specify who may sign which types of accounting documents and under what conditions.

In practice, this means enterprises should review existing authorization matrices, internal regulations, and powers of attorney to ensure consistency with legal requirements. Any ambiguity in signing authority may expose enterprises to compliance risks, particularly during tax audits or inspections by competent authorities.

Restrictions on the Chief Accountant’s Authority

A notable clarification under Circular 99 is that the chief accountant (or a person authorized by the chief accountant) is not permitted to sign on behalf of the enterprise’s legal representative, director, or manager on accounting documents.

This provision reinforces the separation of duties between management and accounting functions. While the chief accountant plays a critical role in ensuring the accuracy and compliance of financial records, decision-making authority and legal responsibility remain with the enterprise’s management.

Enterprises should carefully reassess internal practices where chief accountants may have historically signed documents beyond their formal authority, particularly in small or medium-sized enterprises. Adjustments to workflows and approval processes may be necessary to align with the Circular’s requirements.

Transition from Balance Sheet to Statement of Financial Position

From 1 January 2026, the traditional Balance Sheet will be formally replaced by the Statement of Financial Position, using Form B01-DN – Financial Statements.

This change reflects Vietnam’s gradual alignment with internationally recognized accounting terminology and concepts. While the substance of the information presented remains largely unchanged, the revised format emphasizes a more structured and conceptually consistent presentation of an enterprise’s financial position.

Practical Impact on Enterprises

The transition will require enterprises to update:

• Financial statement templates
• Accounting software and reporting systems
• Internal reporting manuals and training materials

For enterprises that prepare consolidated financial statements or report to overseas parent companies, the adoption of the Statement of Financial Position may improve comparability. However, careful attention will still be required during the transition period to ensure consistency between statutory financial statements and management or group reporting.

Revised Classification of Assets and Liabilities

Circular 99 introduces clearer guidance on the classification and presentation of assets and liabilities on the Statement of Financial Position.

Current and Non-Current Presentation

Assets and liabilities must be presented as current or non-current, with items arranged in decreasing order of liquidity. This approach enhances the usefulness of financial statements by providing stakeholders with clearer insights into an enterprise’s liquidity position and short-term solvency.

While many enterprises already follow similar principles, the Circular elevates this practice to a mandatory requirement, increasing expectations around consistency and accuracy.

Areas Requiring Careful Review

Enterprises should pay close attention to the classification of:

• Long-term receivables and payables
• Advances, deposits, and prepaid expenses
• Long-term provisions and contingent liabilities

Incorrect classification may distort key financial ratios and could lead to misunderstandings regarding an enterprise’s financial health. A thorough review of account mappings and financial statement disclosures will therefore be essential ahead of implementation.

Currency Units in Accounting

Circular 99 provides more detailed guidance on the use of foreign currencies as accounting units, an area of particular relevance to foreign-invested enterprises and companies engaged in international trade.

Conditions for Using a Foreign Currency

An enterprise may use a foreign currency as its accounting unit only if it satisfies conditions relating to:

• Revenue structure
• Expense composition
• Capital mobilization

These conditions aim to ensure that the chosen accounting currency reflects the enterprise’s economic reality rather than convenience. Enterprises that do not meet these criteria must continue to use Vietnamese Dong as their accounting currency.

Change of Accounting Currency

Where a change in accounting currency is permitted, it must:

• Be implemented at the beginning of an accounting period
• Apply the average exchange rate of the bank regularly used for transactions

This requirement prevents mid-period currency changes that could complicate financial reporting and reduce comparability.

Reporting Obligations

Regardless of the accounting currency used internally, financial statements must still be submitted in Vietnamese Dong. This ensures consistency for regulatory oversight, tax administration, and statistical purposes.

Enterprises using foreign currencies should ensure that their accounting systems can support accurate currency conversion, documentation of exchange rates, and reconciliation between accounting records and statutory financial statements.

Changes to the Accounting Chart of Accounts and Global Minimum Tax

One of the most forward-looking changes introduced by Circular 99 relates to the accounting treatment of Global Minimum Tax (GMT) obligations.

Separation of Account 821

Account 821 is now divided into:

• 82111 – Current corporate income tax expense under the Corporate Income Tax Law
• 82112 – Additional corporate income tax expense under Global Minimum Tax regulations (15%)

This separation reflects Vietnam’s implementation of international tax reforms and ensures clearer identification and tracking of different tax components.

Implications for Enterprises

The revised chart of accounts allows enterprises to:

• Monitor standard CIT liabilities separately from GMT top-up tax
• Improve transparency in tax expense reporting
• Facilitate compliance with both domestic and international tax reporting requirements

Multinational enterprises, in particular, should assess whether their accounting systems and internal reporting structures are capable of supporting this distinction and whether additional controls or disclosures may be required.

Governance, Systems, and Compliance Considerations

Taken as a whole, Circular 99 has implications that extend beyond accounting entries and financial statement formats.

Strengthening Internal Controls

The stricter rules on documentation, authorization, and signing authority will likely prompt enterprises to reassess their internal control frameworks. Clear segregation of duties, well-documented approval processes, and regular internal reviews will be critical to ensuring compliance.

System and Process Readiness

Enterprises may need to update accounting software, reporting tools, and internal manuals to reflect:

• New financial statement formats
• Revised chart of accounts
• Enhanced currency management requirements

Early preparation and cross-functional coordination will be essential to avoid operational disruptions when the Circular takes effect.

Conclusion

Circular No. 99/2025/TT-BTC represents a comprehensive and meaningful reform of Vietnam’s accounting and financial reporting framework. By strengthening rules on accounting documentation, governance, financial statement presentation, currency usage, and tax accounting, the Circular supports greater transparency, consistency, and alignment with international practices.

Enterprises are strongly encouraged to begin reviewing their accounting policies, internal controls, and reporting systems well in advance of the 1 January 2026 effective date. Early preparation will help mitigate compliance risks and ensure a smooth transition under the new regulatory framework