On October 27, 2025, the Ministry of Finance issued Circular 99/2025/TT-BTC (hereinafter referred to as Circular 99), officially superseding Circular 200/2014/TT-BTC (Circular 200) on the corporate accounting regime. The new Circular introduces many significant updates, providing detailed guidance on accounting vouchers, the chart of accounts, bookkeeping methods, and the preparation and presentation of Financial Statements (FS). Below, Crowe Vietnam summarizes and analyzes the crucial contents that management, chief accountants, and business owners must pay special attention to.
Download Circular 99/2025/TT-BTC
1. Overview of Circular 99/2025/TT-BTC
Circular 99 focuses on guiding accounting practices within enterprises, including: vouchers, accounts, books, and FS.
An important point to clarify: This Circular does not regulate the determination of tax obligations. Tax-related matters for enterprises must still strictly comply with the provisions of current tax legislation.
2. Noteworthy Changes in Circular 99/2025/TT-BTC
2.1. Expansion of Applicable Scope
A significant new point is that Circular 99 adds Credit Institutions to its scope of application. However, the Circular only applies to non-specific operations of the banking industry (e.g., accounting for inventory, fixed assets, liabilities). Specific banking operations must still adhere to the separate regulations of the State Bank of Vietnam.
2.2. Strengthening Governance and Internal Control
Article 3 of Circular 99 emphasizes the enterprise’s responsibility to comply with the law when executing and controlling economic transactions.
The Circular requires enterprises to develop their own internal governance regulations and organize an effective internal control system.
- These regulations must clearly define the authority and responsibility of each department and individual involved in transactions.
- Notably, enterprises are granted the authority to independently establish regulations on the authority and responsibilities of the accounting department to suit their scale and operational characteristics.
This provision increases autonomy, helping enterprises design a practical control system suited to their needs rather than applying rigid rules, thereby reducing the burden on the accounting department.
2.3. Regulations on the Currency in Accounting
a. Selection of accounting currency
The default currency for bookkeeping and FS preparation is the Vietnamese Dong (VND).
However, Circular 99 allows enterprises to select a foreign currency as their accounting currency if they meet the conditions in Article 31 and their main collections and payments are in that currency.
To determine the appropriate currency, enterprises need to consider the main factors:
- The currency that primarily influences the sales price of goods and services (usually the currency of quotation and settlement).
- The currency that primarily influences costs (labor, raw materials, other expenses).
If still undetermined, enterprises should consider additional factors:
- The currency used for raising capital (issuing debt or equity instruments).
- The currency generated from operating activities and accumulated.
Note: Enterprises are not permitted to change their accounting currency after selection, except in cases of significant changes in management and business operations.
b. Exchange rates
Circular 99 provides more flexibility in applying exchange rates, resolving the complexity of Circular 200 (which stipulated many different buy/sell rates).
- Actual transaction rate (for intra-period transactions): Enterprises may choose to use the average transfer exchange rate (buy-sell) of the bank they frequently transact with, or an approximate rate (provided the variance is no more than +/-1% from the average rate).
- Conversion rate (when changing the accounting currency): Must use the average transfer exchange rate of the frequently used bank on the date of the change.
2.4. Simplification of Accounting at Dependent Units (Branches)
Circular 99 strongly decentralizes decision-making power to the enterprise (head office) in organizing the accounting apparatus and work for dependent units (branches).
- No mandatory separate FS for branches: The head office and dependent units are not required to prepare separate financial statements, unless required by other laws.
- Principle of combined FS: The enterprise is responsible for combining the financial information of both the head office and branches into its FS. This report must eliminate all internal transactions between units.
- Flexible recognition of internal revenue: Enterprises can self-determine whether dependent units recognize revenue from the internal transfer of products and services, regardless of the document type used (invoice or internal voucher).
2.5. Increased Autonomy over Vouchers and Books
Circular 99 promotes enterprise autonomy in line with the spirit of the Law on Accounting.
- Self-design of forms: Enterprises are permitted to build and design their own voucher and accounting book templates to fit their business characteristics and specific management needs.
- Simplified voucher signing rules: The preparation and signing of vouchers will comply with the general provisions of the Law on Accounting. The new Circular has removed detailed, rigid regulations (such as ink type, writing method) that existed previously.
2.6. Increased Flexibility of the Chart of Accounts (CoA)
a. Granting enterprises the right to customize the CoA
This is one of the most significant changes. Circular 99 transfers the authority to detail the CoA from the Ministry of Finance to the enterprise.
- Enterprises are proactively allowed to open additional detailed accounts (Level 2, Level 3) to serve internal management requirements, instead of being bound by mandatory Level 2 accounts as before.
- When amending or supplementing the CoA, enterprises must issue an Internal Accounting Policy, (or Internal Accounting Regulations) explaining the rationale and bearing legal responsibility for these changes.
b. Addition and abolition of certain accounts
Circular 99 updates the CoA to reflect the true nature of transactions, especially in agriculture and taxation.
Added Accounts:
- Acc. 215 – Biological Assets: Separates biological assets (crops, livestock) from Acc. 211 (Tangible Fixed Assets) for separate monitoring.
- Acc. 2295 – Provision for Impairment of Biological Assets: Used to make provisions for biological assets. The additional provision amount is recognized in the Cost of Goods Sold (Acc. 632).
- Acc. 1383 – Special Consumption Tax (SCT) of imported goods: Guides the accounting for SCT on imported goods (e.g., gasoline).
Abolished/Changed Accounts:
- Abolished Acc. 1562 (Cost of purchasing goods): Circular 99 allows for flexible handling. If purchasing costs are minor and related to many items, enterprises can recognize them directly in the Cost of Goods Sold (Acc. 632).
- Abolished Acc. 611 (Purchases): This account was used for the periodic inventory method.
2.7. Other Noteworthy Provisions
- Revenue Recognition: Places a stronger emphasis on compliance with the revenue recognition principle based on performance obligations.
- Promotional Goods: When issuing promotional goods, record Debit (Expense) / Credit 3331 (VAT payable), in alignment with Circular 133.
- Inventory Costing Method: Allows enterprises to apply different costing methods for different types of materials and goods, instead of being required to apply a single method for all.
- Standard Cost Method: Circular 99 adds guidance on applying this method in calculating production costs. This helps enterprises obtain immediate costs, supporting rapid profit/loss calculation. The variance between standard and actual cost will be adjusted to COGS or inventory.
- Changes to Appendices: Updates 4 appendices, including voucher templates, the CoA, accounting book templates (reduced from 45 to 42 forms), and FS templates.
2.8. Updates to Financial Statements (FS)
- Report Name Change: The “Balance Sheet” is officially renamed the “Statement of Financial Position”. Other reports (Income Statement, Cash Flow Statement, Notes) retain their names. (Note: The new template differs from that of Circular 200).
- Reporting Period: Annual FS are mandatory. Interim FS (quarterly, semi-annual) are not mandatory under the accounting regime but must comply with requirements of other relevant laws (such as the Law on Securities).
- FS of a company with branches: The company’s FS must include the information of its dependent units (branches) and must perform internal eliminations. The concept of separate aggregated/combined financial statements no longer exists as before.
- Retrospective Adjustment: Only material errors require retrospective adjustment of the FS.
- Events after the reporting period: Events arising after the end of the annual accounting period are not permitted to alter the prepared FS.
- FS Presentation: Enterprises can customize accounting accounts, but when presenting the FS, they must comply with the exact indicators in the Circular. Enterprises are allowed to add indicators but not to modify the prescribed ones.
3. Effectiveness of Circular 99/2025/TT-BTC
Circular 99/2025/TT-BTC shall take effect from January 01, 2026, and shall apply to financial years beginning on or after January 01, 2026. Furthermore, from the date this Circular takes effect, the following Circulars shall be superseded:
- Circular 200/2014/TT-BTC guiding the Corporate Accounting Regime (except for the case stipulated in Clause 2, Article 31 of Circular 99/2025/TT-BTC);
- Circular 75/2015/TT-BTC amending and supplementing Article 128 of Circular 200/2014/TT-BTC;
- Circular 53/2016/TT-BTC amending and supplementing a number of Articles of Circular 200/2014/TT-BTC;
- Circular 195/2012/TT-BTC guiding accounting applicable to project owners.
