Vietnam’s Accounting Overhaul: Preparing for Circular 99/2025/TT-BTC Effective 1 January 2026

Vietnam’s accounting landscape is entering a decisive period of transformation. With the release of Circular 99/2025/TT-BTC, the Ministry of Finance has introduced the most substantial update to the national accounting regime since Circular 200 was issued over a decade ago. The new framework, effective 1 January 2026, reshapes how enterprises organise financial information, manage internal controls, prepare documentation, and present financial statements.

Circular 99 goes far beyond a technical revision, representing a structural shift toward a principles-based, governance-focused approach. This grants enterprises greater flexibility in designing accounting systems, while imposing higher expectations around accountability, documentation, and transparency.

For foreign-invested enterprises in particular, the implications are wide-ranging: from changes to the Chart of Accounts and functional currency decisions, to redesigned accounting vouchers, new internal control requirements, and revised rules for multi-unit operations.

Our free publication, and this article, provides a overview of the reforms and guidance on what organisations should consider as they prepare for the 2026 transition.

A New Direction for Vietnam’s Accounting Framework

For many years, Vietnamese accounting regulations (most notably Circular 200) have prioritised uniformity and evidence-based compliance. While this approach created consistency, it also constrained businesses operating across diverse sectors, geographies, and structures.

Circular 99 is a clear departure from this model. Instead of prescribing rigid templates and processes, the new regime:

• Empowers enterprises to design documents, accounting books, and internal forms.
• Allows adjustments to the Chart of Accounts to reflect operational realities.
• Emphasises internal control systems and documented governance as core compliance obligations.
• Introduces flexibility in currency selection, multi-unit accounting, and account structures.

This shift aligns Vietnam more closely with modern international accounting principles and recognises the evolving needs of enterprises operating in increasingly complex environments.

Key Regulatory Changes Introduced by Circular 99

1. Updated Accounting Templates and Appendices

Circular 99 introduces a fully revised set of appendices governing accounting vouchers, ledger formats, financial statement templates, and the Chart of Accounts.

Enterprises may adapt or redesign documentation but must issue formal internal regulations explaining and approving these changes.

2. Strengthened Internal Control Requirements

Enterprises must now implement:

• • Documented governance regulations
  • A formal internal control system
  • Clear delegation of responsibilities and financial authority

Lack of documented internal controls may expose an enterprise to compliance risks during inspections.

3. Flexible Chart of Accounts

Enterprises may modify account names, codes, and structures to suit operational needs, provided financial statement indicators are preserved.

New accounts, such as those related to biological assets, taxes, and global minimum tax, are now included.

4. Functional Currency Determination

VND remains the default, but enterprises may apply a foreign functional currency if:

• • Revenues and costs are predominantly denominated in that currency, or
  • Secondary factors (financing, reserve holdings, operational realities) indicate foreign currency alignment

Financial statements must still be converted to VND for statutory reporting.

5. Accounting for Dependent Units

Parent enterprises have discretion to determine how their branches and dependent units:

• • Recognise internal transactions
  • Apply accounting policies
  • Prepare internal financial statements

However, consolidated statutory reporting must include all dependent units.

6. Updated Rules for Foreign Exchange Differences

Circular 99 provides detailed guidance on:

• • Exchange rates to apply for transactions
  • Permitted revaluation methods
  • Year-end conversion requirements
  • Treatment and disclosure of resulting differences

7. Revised Financial Statement Presentation Principles

While enterprises may expand disclosures or add detail, prescribed line items cannot be removed or abbreviated. Additional items require a formal internal policy.

Actions For Enterprises

With the 2026 implementation date approaching, organisations should begin planning immediately. Key actions include:

1. Conduct a Gap Assessment

Review existing accounting systems, documentation, internal controls, and reporting workflows against the requirements of Circular 99.

2. Redesign Internal Controls and Governance

Prepare internal governance regulations, update approval workflows, and formalise responsibilities for all financial and accounting functions.

3. Update Accounting Documentation

Design new templates for vouchers, books, and reports where needed, supported by a formally issued internal Accounting Regulation.

4. Review and Adjust the Chart of Accounts

Update account structures to align with enterprise operations while ensuring financial statement indicators remain compliant.

5. Assess Functional Currency Eligibility

Evaluate whether a foreign currency is more appropriate, especially for enterprises with foreign-currency-dominant revenue and cost structures.

6. Align Headquarters and Dependent Units

Establish consistent policies for internal transactions, capital allocations, and financial statement consolidation.

Enterprises with multinational structures, multi-location operations, or significant foreign currency exposure should begin preparations early to avoid system disruptions and compliance difficulties.

Transitioning with Confidence

Circular 99 provides greater flexibility and modernises Vietnam’s accounting environment, but it also increases expectations for robust internal governance and disciplined, well-documented financial management.

For organisations that take early action, the transition presents an opportunity to streamline processes, strengthen reporting systems, and improve alignment with parent-company and global standards.

Alitium supports foreign-invested enterprises through every stage of this process, from assessment and system redesign to policy development, implementation, and ongoing advisory.

Next Steps

If you would like further advice on the transition to Circular 99, then please reach out to us via our contact page: https://www.alitium.com/contact/