On 27 October 2025, the Ministry of Finance issued Circular 99/2025/TT-BTC on the enterprise accounting regime, replacing Circular 200/2014/TT-BTC and its related amendments. The new regulation takes effect on 1 January 2026 and applies to fiscal years beginning on or after that date, introducing the most comprehensive changes to Vietnam’s accounting framework in more than a decade.
This update fundamentally changes how businesses approach accounting. For those familiar with Vietnam’s accounting rules, which have historically been detailed and checklist-driven, Circular 99 represents a clear shift. Instead of prescribing every step, the new framework empowers enterprises to manage accounting in a transparent, well-documented, and responsibly governed way. This shift from compliance by instruction to compliance by principle encourages a mindset closer to international standards (IFRS) while maintaining the foundations of Vietnamese Accounting Standards (VAS).
Circular 99 responds to a fast-evolving business environment shaped by digitalisation, complex multi-entity structures, and growing foreign investment. Its objectives are to:
- Modernise Vietnam’s accounting regime after more than a decade of incremental updates.
- Align more closely with international standards (IFRS), supporting a principle-based approach.
- Promote digitalisation and accountability, empowering businesses to customise their systems.
For CEOs, business owners, and finance leaders, this will influence how finance teams operate, how risks are managed, and how financial results are communicated to investors and regulators.
What’s different under Circular 99?
Here are the key changes and why they matter for your business.
Internal governance is now your responsibility
Circular 99 requires businesses to take ownership of their internal accounting governance by establishing clear internal rules and control procedures, instead of relying on rigid templates as in prior regulations.
This means:
- Clearly defining who approves, records, and reviews transactions, and how responsibilities are segregated.
- Clearly defining the powers, obligations, and responsibilities of each department or individual involved in economic transactions.
- Documenting these rules thoroughly, as regulators may review your internal policies when issues arise.
Accounting now intersects with risk management, compliance, and decision-making. Clear policies, accountability, and proper documentation are essential to ensure operational and financial transparency.
Investors can choose the (functional) accounting currency
The default currency remains the Vietnamese dong (VND). However, enterprises primarily operating in foreign currencies for receipts, payments, pricing, or costs, may designate a foreign currency as their functional currency. Key considerations include:
- The currency that mainly influences selling prices and settlements.
- The currency that mainly affects labour, raw materials, and other major costs.
If a foreign currency is chosen, financial statements must still be converted to VND for statutory reporting, using the average transfer exchange rate of the commercial bank where the enterprise regularly transacts at the end of the accounting period. Companies must also disclose in the notes:
- The reason for selecting or changing the functional currency.
- The conversion method applied.
- The impact on financial results.
Once chosen, the currency can only change at the start of a new accounting year, and only if there is a significant operational shift.
This flexibility particularly benefits exporters and multinationals, however it also introduces dual reporting and exchange-rate disclosure, and potential retroactive adjustments. Clear documentation of the rationale for currency choice is necessary to support audit and regulatory reviews.
Consolidation for groups
Enterprises with subsidiaries, dependent units, or affiliated units are now required to prepare consolidated financial statements and eliminate internal transactions. While previous rules required consolidation for parent–subsidiary groups, Circular 99 extends this requirement to dependent and affiliated units, providing clearer guidance on the consolidation process.
This strengthens transparency and consistency in group reporting. Businesses must ensure their accounting systems support consolidation, map intercompany transactions, and document methodologies in internal regulations.
Greater flexibility in accounting systems and documentation (chart of accounts, vouchers, and books)
Circular 99 gives enterprises more control over how they design and manage their accounting documentation and systems, compared with the rigid structure under Circular 200.
- Chart of Accounts: Based on Appendix II of Circular 99, enterprises may amend or supplement account titles, numbers, and structures, provided they do not alter the substance of the financial statements. Any such amendments must be supported by issued internal accounting regulations as the basis for implementation.
- Accounting documents and books: Enterprises may design their own forms of vouchers, e-vouchers, and accounting books suited to their operations, as long as they retain the basic required contents and ensure authenticity, verifiability, and traceability. This flexibility allows closer alignment between accounting practices and real business operations, but it also requires enterprises to update ERP systems, strengthen internal controls, formally issue internal accounting regulations on revised and supplemented contents as a basis for implementation, and maintain proper documentation proactively, rather than waiting for standard templates.
- Digitalisation in Accounting: Circular 99 reinforces the move toward digital accounting. Electronic vouchers, books, and digital signatures, already allowed under prior regulations, are now formally recognised within the accounting framework. This means businesses can maintain and approve records in electronic form, without printing, provided authenticity and traceability are ensured. Digital signatures, issued through licensed certification authorities in Vietnam, can fully replace handwritten signatures for accounting purposes.
Financial statements and disclosures
Circular 99 standardizes the names of financial statements (e.g., ‘Balance Sheet’ → ‘Statement of Financial Position) and requires applying the retroactive principle when changes are made to the functional currency.
The Circular keeps the standard financial statement set (Statement of Financial Position, Statement of Profit and Loss (P&L); Cash Flow Statement, etc.) but places stronger emphasis on the notes to the financial statements.
Key new disclosure areas include:
- Basis for selecting accounting policy (basis of preparation, currency, revenue recognition principles, expense classification (by nature or function)).
- Impacts of currency changes.
- Internal transactions and risk exposures.
- Consolidation methods for multi-entity groups.
- For enterprises with special characteristics (mergers/splits/restructuring) the Circular provides more detailed guidance.
Transparency is the new expectation, it’s no longer just about numbers, but the story behind them. Investors, lenders, regulators, and other stakeholders will expect detailed disclosures on internal transactions, currency impacts, and consolidation methods.
Key actions for Circular 99 readiness
To address the new rules effectively and protect the integrity of your financial reporting, we recommend focusing on the following areas.
| 1. Assess and plan. Start with a gap analysis: compare your existing accounting regime (Chart of Accounts, vouchers, books, internal control, and reporting) with Circular 99’s requirements. From there, update your accounting policy manual to document key decisions on accounting currency, internal governance, branch reporting, and voucher formats. |
| 2. Redesign your accounting system. Update and align your Chart of Accounts, voucher templates, and ERP mapping to reflect your business structure. Ensure any new accounts, codes, or formats are properly tested and aligned with regulatory requirements. |
| 3. Strengthen governance and capacity. Define who does what in transaction approval, recording, and reporting. Document internal control mechanisms and ensure they’re clearly communicated. Invest in training so finance, internal audit, and IT teams understand the new responsibilities and system impacts. |
| 4. Upgrade reporting and test transition. Revise your financial statement templates and disclosures to reflect new guidance including internal transactions, currency impacts, consolidation methods, and risk exposures. Before the first fiscal year under Circular 99, conduct a mock closing with updated templates, opening balances, and disclosures to surface any issues early. |
| 5. Implement consolidation & multi-entity reporting (if you operate multiple entities) If your business has subsidiaries or branches, implement a full consolidation process, including elimination of internal transactions. |
| 6. Manage accounting currency transition (if adopting a foreign functional currency) For businesses choosing a foreign functional currency, determine the appropriate currency and apply conversion principles for opening balances and comparative figures. |
| 7. Engage early and stay informed. Coordinate your approach with auditors or advisors to align interpretations and avoid surprises at audit time. Keep monitoring further guidance from the Ministry of Finance as Circular 99 forms part of an evolving regime moving toward IFRS and digitalisation. |
Mai Vu
Director, Accounting & Tax
Vieter Vietnam
How we can help your business through Circular 99
Navigating Vietnam’s new accounting rules can be complex, but expert guidance makes all the difference. Our team at Vieter Vietnam can help your business:
- Ensure compliance while optimising your accounting and reporting processes.
- Strengthen internal governance, controls, and financial transparency.
- Implement efficient systems aligned with Circular 99 and international best practices.
Our team is ready to assist you in protecting your business, adapting to regulatory changes, and unlocking the full value of accurate, reliable financial reporting.
Mai Vu – Director, Accounting & Tax – mai.vu@Vieter.com
Le Anh Vu – Senior Manager, Accounting & Tax – anh.vu@Vieter.com
Kevin Lam – Partner – k.lam@Vieter.com
Rizwan Khan – Managing Partner – r.khan@Vieter.com