Circular 99: Vietnam Accounting Guide for 2026
Vietnam's Circular 99/2025/TT-BTC introduces a new enterprise accounting regime for financial years beginning on or after January 1, 2026. It replaces most of Circular 200/2014/TT-BTC and gives companies more flexibility to adapt accounting documents, books, and account structures to their operations. That flexibility comes with a clear condition: management must be able to explain its choices, document internal controls, apply policies consistently, and produce compliant financial statements.
For a foreign-invested or foreign-owned company in Vietnam, the change is broader than an update to account codes. Circular 99 may affect local bookkeeping, group reporting, functional currency decisions, approval workflows, software configuration, data retention, and audit preparation. Companies should therefore treat implementation as a coordinated finance, management, and IT project within their wider Vietnam tax compliance framework.
Quick Answer
Circular 99 applies to financial years beginning on or after January 1, 2026. It replaces most of Circular 200 and governs accounting documents, accounts, books, and the preparation and presentation of financial statements. Businesses may customize certain accounting tools, but material changes must remain legally compliant, preserve accurate reporting, and be supported by internal accounting regulations or equivalent documentation. Companies should review their chart of accounts, opening balances, accounting policies, ERP configuration, internal controls, and financial-statement templates before their first close under the new regime.
Key Takeaways
Circular 99 applies from the start of a company's first financial year beginning on or after January 1, 2026.
The regime applies broadly to enterprises across sectors, while credit institutions and foreign bank branches follow accounting guidance issued by the State Bank of Vietnam.
Companies receive more flexibility over specified accounting documents, books, and accounts, but must document and control any changes.
Accounting rules do not automatically determine tax, invoice, or tax-declaration treatment; those matters remain governed by tax legislation.
Foreign-invested enterprises should test both Vietnam statutory reporting and parent-company reporting before year-end.
Annual financial statements must generally be submitted to the competent authorities no later than 90 days after the end of the annual accounting period.
What Is Circular 99?
Circular 99/2025/TT-BTC was issued by Vietnam's Ministry of Finance on October 27, 2025 to guide the enterprise accounting regime. It covers accounting source documents, accounts, book recording, and the preparation and presentation of financial statements. It took effect on January 1, 2026 and applies to financial years beginning on or after that date.
The circular replaces Circular 200/2014/TT-BTC, Circular 75/2015/TT-BTC, and Circular 53/2016/TT-BTC, subject to limited transitional exceptions identified in Circular 99. Businesses should not assume that every former account, policy, or template can continue unchanged. Each entity should compare its existing accounting framework with the new circular and the applicable appendices.
One important boundary is often missed: Circular 99 is an accounting regime, not a complete tax rulebook. The circular itself states that enterprise tax obligations remain subject to tax legislation. A method used to recognize or translate a transaction for accounting purposes may therefore differ from the rule that applies to invoices or tax declarations.
When Does Circular 99 Apply?
The transition date depends on the beginning of the company's financial year. A business should not ordinarily change accounting regimes midway through an existing financial year.
Registered financial year | First financial year under Circular 99 |
January 1 to December 31 | January 1, 2026 |
April 1 to March 31 | April 1, 2026 |
July 1 to June 30 | July 1, 2026 |
October 1 to September 30 | October 1, 2026 |
Insert Image 1: Circular 99 Application Timeline here.
The Ministry of Finance has specifically confirmed that a company with a July-to-June financial year applies Circular 99 from July 1, 2026 for bookkeeping and financial-statement purposes. Invoicing and tax declarations for foreign-currency transactions continue to follow tax law. This distinction is particularly important for regional groups whose Vietnam entities do not use the calendar year.
Newly established enterprises should open their accounting books from their establishment date. A business completing company registration in Vietnam for foreigners during 2026 should therefore confirm the applicable accounting regime as part of its initial finance setup rather than waiting for its first reporting deadline.
Who Must Comply With Circular 99?
Circular 99 applies to enterprises across sectors and economic components. This includes Vietnamese companies and foreign-invested enterprises operating through locally established legal entities. Credit institutions and foreign bank branches are treated separately and apply the accounting regime or accounting regulations issued by the State Bank of Vietnam.
Responsibility does not sit only with the chief accountant. Management is responsible for establishing internal governance rules and controls that define the rights, duties, and responsibilities of the people involved in initiating, approving, recording, paying, and reviewing transactions. Finance, tax, procurement, sales, HR, IT, and operational teams may all be affected when a process creates accounting data or supporting evidence.
Circular 99 Changes Businesses Should Review
Internal Accounting Regulations and Controls
Circular 99 expressly connects accounting with corporate governance and internal control. Each enterprise must establish internal governance regulations or equivalent documents and organize controls that clearly allocate responsibility for economic transactions. A compliant framework should show who may initiate a transaction, what evidence is required, who approves it, who records it, and who performs an independent review.
This requirement becomes more important when a company changes a prescribed document, book, or account. The internal regulation should explain why the change is necessary, how it complies with Vietnamese accounting law, which person approved it, when it becomes effective, and how the company will apply it consistently. Informal practice or an undocumented spreadsheet mapping is unlikely to provide a strong audit trail. This gap highlights why poor accounting documentation practices in Vietnam quickly turn into a major tax exposure during audits.
Chart of Accounts and Opening Balances
Circular 99 provides a revised chart of accounts while allowing businesses to modify or supplement specified account names, codes, structures, and contents where operationally necessary. Any modification must reflect the economic substance of transactions, avoid duplicated accounting objects, comply with accounting principles, and preserve the information required in statutory financial statements.
Before the first reporting period, the finance team should create a formal mapping from the old chart to the new one. The mapping should identify each former account, its destination under Circular 99, the effective date, the reason for the treatment, the approving person, and the related financial-statement line. Opening balances, comparative data, budgets, tax reconciliations, and consolidation packages should all use the same approved mapping.
The transitional provisions also contain specific treatments for existing balances and changes in accounting policies. Depending on the issue, a company may need a retrospective, simplified retrospective, or non-retrospective method. Material transition journals should be supported by calculations and reviewed before they are posted.
Accounting Documents and Books
Companies may design additional accounting-document templates or amend prescribed templates when required by their operations and management needs. The revised document must still contain complete, timely, accurate, transparent, verifiable, and controllable information. Where a template is amended, the enterprise must issue an accounting regulation or equivalent document explaining the change and accepting responsibility for it.
Similar flexibility applies to accounting-book forms. The practical benefit is that businesses can design records around their processes, but they must maintain consistency between source documents, books, subledgers, the general ledger, and financial statements. Document retention, correction procedures, version control, electronic signatures, and access rights should be included in the review.
Functional Currency and Foreign Exchange
Vietnamese dong remains the standard accounting currency. An enterprise that primarily receives and pays in a foreign currency may select an eligible foreign currency as its functional accounting currency when the choice reflects the primary economic environment in which it operates. Relevant factors include the currency that principally influences sales prices, labor and material costs, financing, and retained operating receipts.
The decision must be based on the company's actual transaction profile and supported by a written assessment. Once selected, the functional currency should not change unless a substantial change in management or business operations materially alters the underlying circumstances. A change may only take effect at the beginning of a new accounting year.
Even where a company keeps its books in a foreign currency, legally valid financial statements submitted or disclosed in Vietnam must generally be presented in Vietnamese dong. The company must also document its translation method and disclose the effects of conversion. Finance teams should keep the accounting exchange-rate policy separate from invoice and tax-declaration rules, which remain governed by tax law.
Financial Statements and Disclosures
The annual financial-statement package under Circular 99 includes the Statement of Financial Position, Statement of Profit or Loss, Cash Flow Statement, and Notes to the Financial Statements. Companies must use the prescribed system of financial statements. They may add items when necessary to reflect their operations, but additions must comply with accounting law and be explained in the notes.
Financial information must faithfully reflect the entity's position and performance and must be complete, neutral, free from error, relevant, material, verifiable, timely, understandable, consistent, and comparable. The notes should clearly explain significant accounting policies, material estimates, changes in policy, foreign-currency effects, unusual transactions, going-concern matters, and other information necessary to understand the statements.
Annual financial statements must be submitted to the competent authorities no later than 90 days after the end of the annual accounting period. Parent companies may set earlier internal deadlines for subsidiaries so that group consolidation can be completed on time. Foreign-invested companies should work backward from both deadlines when planning the close.
Accounting Software and ERP Readiness
Circular 99 implementation may require more than changing a report template. Account codes, financial-statement mappings, approval workflows, user permissions, audit logs, electronic records, and interfaces with invoicing, tax, banking, inventory, and payroll systems may all require review. Businesses using a global ERP must also ensure that local statutory outputs can be produced without weakening the integrity of the group system.
Finance and IT should test whether revised accounts map to the correct statutory lines, opening balances migrated completely, role permissions reflect approved responsibilities, changes remain traceable, and connected systems reconcile. Any manual Excel workaround should have controlled access, clear ownership, review evidence, and version management.
The safest approach is to complete user-acceptance testing and a mock financial close before the first statutory deadline. Test results, reconciliations, configuration changes, and management approvals should be retained as part of the implementation file.
Vietnam Statutory Reporting and Group Reporting
Foreign-invested enterprises often maintain Vietnamese statutory records while also reporting to an overseas parent under IFRS or another group framework. Circular 99 provides more room to align account structures, but it does not make Vietnamese Accounting Standards identical to IFRS.
The Vietnam entity should maintain a controlled reconciliation between statutory accounts and group reporting. Intercompany balances, loans, interest, dividends, purchases, sales, translation adjustments, and consolidation eliminations should agree between counterparties. Local statutory treatments and group adjustments should remain separately identifiable so that reviewers can trace each final figure back to the underlying transaction.
Circular 99 Compliance Checklist for 2026
Review area | Required action | Evidence to retain |
Applicability | Confirm the first financial year governed by Circular 99 | Management memo and registered financial-year details |
Governance | Update internal accounting rules and responsibility assignments | Approved policies, authority matrix, and process descriptions |
Accounts | Map old accounts to the Circular 99 structure | Account-mapping schedule and approval record |
Transition | Reconcile opening balances and determine the correct transition method | Reconciliations, calculations, and transition journals |
Currency | Reassess functional currency and exchange-rate methodology | Functional-currency assessment and exchange-rate policy |
Systems | Configure and test accounting software, ERP, and interfaces | Change logs, test scripts, results, and user approvals |
Reporting | Update statutory templates and disclosure checklists | Draft statements and completed disclosure checklist |
Group reporting | Reconcile VAS records to IFRS or group GAAP | Statutory-to-group reconciliation and consolidation schedules |
People | Train finance staff and relevant process owners | Training materials and attendance records |
Readiness | Run a mock close before the reporting deadline | Mock close output, issue log, and remediation plan |
Insert Image 3: Circular 99 Compliance Checklist here.
Common Circular 99 Implementation Risks
Treating the change as an account-code exercise. A revised chart of accounts will not solve gaps in approval responsibilities, supporting documents, software permissions, disclosures, or group reporting. The implementation plan should cover the complete accounting process.
Customizing without documentation. Circular 99 permits flexibility, but unexplained changes create risk. Every material modification should have a legal and operational rationale, a clear owner, an approval record, and a consistent effective date.
Applying accounting rules to tax automatically. The accounting treatment of a transaction does not necessarily determine the applicable invoice, tax-declaration, or tax-payment treatment. Finance and tax teams should document differences and reconcile them.
Waiting until year-end to test reports. Incorrect mappings and missing disclosures are more difficult to resolve during a live close. A mock close provides time to correct configurations, opening balances, and supporting files.
Losing traceability between local and group reports. Multiple spreadsheets and undocumented adjustments can separate the final group figures from the Vietnam ledger. A controlled reconciliation should link statutory records, adjustments, and consolidation outputs.
What Foreign-Invested Companies Should Do Now
First, confirm the applicable transition date and assign an implementation owner. Second, complete a gap assessment covering policies, accounts, records, software, financial statements, tax reconciliations, and group reporting. Third, prioritize changes that affect opening balances, system configuration, or statutory outputs because they require testing before the reporting period closes.
Companies should then approve the updated accounting regulations, complete account mapping, train relevant staff, and run a mock close. The final implementation file should allow an auditor or reviewer to understand what changed, why it changed, who approved it, how the company tested it, and how the results flow into the financial statements.
VINEX can support foreign investors with accounting and tax services in Vietnam, post-establishment compliance, and the coordination of company records with local reporting obligations. Early review reduces the risk of discovering policy, system, or documentation gaps close to a statutory deadline.
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