Vietnam Circular 99/2025: Major Updates to Accounting Rules from 2026

Vietnam’s accounting framework is undergoing its most significant change in more than a decade. With Circular 99/2025/TT-BTC (“Circular 99”) taking effect from 1 January 2026 and replacing Circular 200/2014/TT-BTC, every enterprise operating in Vietnam will need to update internal policies, systems, and reporting practices. The reform moves beyond technical adjustments and introduces a new approach to financial governance, reporting, and digital compliance.

Circular 99 reflects a shift in policy thinking. Instead of focusing only on bookkeeping formats and compliance procedures, the new framework is designed to support governance, transparency, and digital transformation. It modernises accounting rules to reflect the realities of global business, foreign investment, and multi-entity corporate structures.

Covering 788 pages, Circular 99 is comprehensive in breadth and guidance, and seeks to provide an experience much closer to IFRS that has long been discussed and championed in Vietnam. Although not a full IFRS approach, it moves Vietnam forward in its accounting regime and requirements. Dated and released on 27 October 2025 by the Ministry of Finance, this only gives enterprises 2 months for transition, which will provide a challenge for most.

Below are some of the more notable changes arising in Circular 99, and what they mean for businesses.

From Bookkeeping to Governance and Control

Under the previous system, the accounting function was treated primarily as a record-keeping requirement. Circular 99 expands the scope of accounting obligations to include internal governance, risk management, and accountability structures. Enterprises will now need documented internal regulations that define responsibilities, approval workflows, and accounting control mechanisms.

This reflects a broader trend that accounting is no longer only about compliance. It now plays a role in management decision-making, investor confidence, and internal accountability.

For CFOs and chief accountants, this means the role now goes beyond preparing financial statements. It requires oversight of internal processes, delegation of authority, segregation of duties, and digital auditability.

Clearer Rules on Accounting Currency

Circular 99 clarifies long-standing uncertainty on the use of foreign currency as the accounting unit. Enterprises may adopt a foreign currency only if it reflects the substance of their operations, for example, when most revenue, costs, and financing activities of a taxpayers in Vietnam are in a specific foreign currency.

Once adopted, the chosen accounting currency cannot change mid-year, and any transition requires consistency in exchange-rate treatment. Even where accounting records are kept in foreign currency, financial statements must still be prepared and filed in VND.

This clarity is especially important for:

• Foreign-invested companies with USD-based contracts
• Export-focused enterprises
• Subsidiaries of multinational groups

The new rules provide operational flexibility while protecting the State’s reporting system from fragmentation.

Flexibility for Dependent Units and Internal Transactions

Circular 99 introduces a more flexible model for accounting across multi-entity structures such as branches, dependent units, and subsidiaries. Key decisions can now be made at enterprise level, including:

• Whether parent funding is treated as capital or loans
• Whether internal transfers generate revenue and cost of goods sold
• Whether branches prepare separate financial statements

This allows enterprises to select an approach that fits their commercial reality rather than being forced into one method. However, consolidated financial statements must still present a complete and accurate financial picture.

For large domestic groups and foreign-owned enterprises, this flexibility supports more efficient tax planning, cash-flow management, and internal reporting.

Digitalisation and Self-Designed Accounting Documents

One of the most modernising features of Circular 99 is the move away from fixed templates issued by the Ministry of Finance. Enterprises now have the right to design their own vouchers, forms, and accounting documentation as long as they comply with transparency, reliability, and auditability standards.

Electronic vouchers hold the same legal weight as paper ones, provided they are properly controlled, archived, and traceable.

This creates a clear pathway for:

• Full digital accounting systems
• Paperless workflows
• Cloud-based document storage
• Integration with ERP and e-invoice platforms

Companies that adopt or upgrade digital systems now will be in a stronger compliance position in 2026 and beyond.

Revised Chart of Accounts

Circular 99 introduces a new chart of accounts (COA) with structural changes and new account codes to reflect developments in Vietnam’s business environment.

Key additions include:

• Account 215 – Biological Assets (for crops, livestock, etc.), addressing long-standing gaps for agriculture-based enterprises
• Account 8213 – Global Minimum Tax Expense, supporting Vietnam’s adoption of the Global Anti-Base Erosion (GloBE) 15% top-up tax
• Updated terminology for equity accounts to align with international standards
• More flexibility with sub-accounts and their customisation

Enterprises will need to update internal COAs, remap ERP systems, and ensure comparative figures are properly restated.

Updated Financial Statement Structure and Disclosures

The four standard financial statements remain, but the reporting model has been modernised. Notes to the financial statements are expanded and require more narrative explanation rather than only numerical schedules.

New disclosure requirements include:

• Basis for choosing accounting currency
• Translation effects from foreign currency records
• Internal transactions within consolidated groups
• Financial risk exposures (credit, liquidity, interest rate)

Separate formats are now required for non-going-concern entities, such as companies dissolving, liquidating, or undergoing restructuring, with the aim to improve transparency for creditors and investors.

Autonomy, Transparency, Integration

Circular 99 reflects a transition from rule-driven compliance to a principle-based framework. Instead of prescribing every form and procedure, it gives enterprises greater freedom (but also greater responsibility). The focus shifts to:

• Internal accountability
• Data truthfulness
• Digital traceability
• Management-level financial reporting

This positions enterprises for smoother eventual adoption of IFRS and aligns Vietnam with international reporting expectations from investors, lenders, and multinational partners.

What Enterprises Should Do Now

With less than one year before implementation, businesses should begin preparing across policy, systems, people, and reporting structures.

1. Update Accounting Policies and Governance

• • Review accounting manuals and internal authority frameworks
  • Document the chosen accounting currency and justification
  • Update internal control procedures and approval hierarchies

2. Redesign the Chart of Accounts

• • Map existing accounts to the new COA
  • Add new mandatory accounts and retire obsolete ones
  • Review how internal transactions will be recorded across entities

3. Update Document and Voucher Systems

• • Design new voucher templates, both paper and electronic
  • Issue internal policies on document flow, approval, and retention
  • Ensure systems support e-vouchers and electronic signatures

4. Strengthen Internal Controls

• • Define roles between management, accountants, and approvers
  • Establish required governance regulations
  • Review segregation of duties and audit trails

5. Prepare New Financial Statement Formats

• • Update reporting templates for quarterly and annual filings
  • Train accounting and finance teams on expanded disclosures
  • Plan consolidation and elimination entries for group structures

6. Training and Change Management

• • Provide structured training for accountants, CFOs, and directors
  • Begin early alignment with auditors and tax advisors
  • Communicate changes to foreign shareholders where relevant

7. Assess Digital Readiness

• • Check system compatibility for multi-currency, e-vouchers, COA remapping
  • Upgrade ERP or accounting software if needed
  • Review cybersecurity, backups, and digital archiving policies

Final Comments: This Change is Significant

Circular 99/2025 TT-BTC is a full reset of Vietnam’s accounting regime. Enterprises that act early, especially those investing in internal control, staff competency and digital systems, will not only be compliant and reduce associated compliance risks in Vietnam, but will also benefit from better financial management, clearer reporting to investors, and smoother integration into global markets.

For any further questions you may have, please reach out to us at vietnam@alitium.com

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This article is intended to provide an overview of recent updates and announcements. While it aims to present useful insights, it is important to note that the content shared here should not be considered as formal legal or taxation advice. For specific guidance on tax obligations or legal matters related to your business, we strongly recommend consulting with a qualified professional, such as a tax advisor or legal expert or directly reach out to us.