On 27 October 2025, the Ministry of Finance (MOF) issued Circular No. 99/2025/TT-BTC providing guidelines for business accounting regime (“Circular 99”), officially replacing the long-standing Circular No. 200/2014/TT-BTC (“Circular 200”) and other related circulars. Circular 99 takes effect from 1 January 2026 and applies to fiscal years beginning on or after such a date. Circular 99 focuses on financial management, risk control, and international integration to align with the Vietnam Accounting Standards (VAS), oriented towards the International Financial Reporting Standards (IFRS) with the key points as follows:
- Chart of Accounts (CoA)
Instead of requiring enterprises to follow the detailed CoA as regulated by the MOF as in Circular 200, Circular 99 provides the increased flexibility for enterprises by allowing enterprises to customize the CoA to suit their needs. Further, regarding the accounts, Circular 99 abolishes some of the accounts set out in Circular 200 and adds new accounts to be in line with the standard of IFRS, i.e., Acc. 215 – Biological Assets, Acc. 2295 – Provision for Impairment of Biological Assets, and Acc. 1383 – Special Consumption Tax (SCT) of imported goods.
- Accounting Currency, and Financial Statements
Under Circular 99, enterprises are given the right to self-design accounting vouchers, provided that they are truthful, verifiable, and transparent, and are issued via internal accounting regulations. Circular 99 also provides more flexible rules on accounting currency, but any change must be made at the beginning of a fiscal year using the average transfer exchange rate of the bank regularly used. Financial statements must still be submitted in VND. To align with the IFRS, the “Balance Sheet” is officially renamed the “Statement of Financial Position”. Explanatory notes are substantially expanded, requiring clear disclosure based on determining the accounting currency, the impact of exchange rate fluctuations, consolidation elements, and financial risks.
- Scope of Application
Circular 99 adds credit institutions to its scope of application for their non-specific banking operations (e.g., fixed assets, inventory), although specific banking operations remain under State Bank of Vietnam guidance.
- Dependent Units
Circular 99 allows flexible decentralization between the parent company and dependent units. Parent companies may choose to recognize capital allocated to dependent units as liabilities or equity, and also decide whether or not to record revenue and cost of goods sold for internal transfers. At the same time, dependent units may choose whether or not to prepare separate financial statements, provided the enterprise ensures full data consolidation.
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Please do not hesitate to contact Dr. Oliver Massmann at [email protected] if you have any questions. Dr. Oliver Massmann is the General Director of Duane Morris Vietnam LLC.
