Circular 99/2025/TT-BTC: A Turning Point in Accounting for Business Enterprises

On October 27, 2025, the Ministry of Finance issued Circular No. 99/2025/TT-BTC providing guidance on the Accounting Regime for Business Enterprises — a critical legal document that every Vietnamese enterprise must study and prepare to implement from January 1, 2026. This Circular replaces Circular 200/2014/TT-BTC, reflecting core changes and refinements to enhance the true and fair presentation and comparability of the Financial Statements (FS) in line with international standards.

Scope and Subjects of Application

Circular 99/2025/TT-BTC clearly defines:

• Scope of regulation: Guidance on accounting documents, chart of accounts, bookkeeping, preparation, and presentation of financial statements for enterprises.

• Subjects of application: All enterprises across sectors and economic types. (Credit institutions and foreign bank branches will follow the accounting regime or separate regulations issued by the State Bank of Vietnam, if applicable.)

• Professional implication: Each enterprise must determine whether it falls under the scope of this Circular (e.g., banks and insurance companies may follow separate regimes). This identification is crucial to avoid applying the wrong accounting system, which could lead to errors in vouchers, ledgers, and financial reports.

Key Highlights and Major Changes

Circular 99/2025/TT-BTC introduces significant updates compared to Circular 200/2014/TT-BTC. Below are the five major areas businesses should pay close attention to:

a) Replacement of Old Regulations and Effective Date

• Circular 99/2025 takes effect on January 1, 2026, and applies to fiscal years starting on or after that date.

• It replaces Circular 200/2014/TT-BTC and related documents such as Circulars 75/2015, 53/2016, and 195/2012, except for certain provisions on state-owned enterprise equitization.

Expert advice: Enterprises should plan the transition early — including training, revising internal policies, updating templates, and upgrading accounting software to ensure smooth adoption for the 2026 fiscal year.

b) Stronger Internal Governance and Control Requirements

Article 3 of Circular 99 emphasizes corporate governance and internal control, requiring enterprises to establish clear internal management regulations and define the rights, obligations, and responsibilities of each department.

Professional implication: This shift reflects a trend toward greater transparency, accountability, and risk management. Chief accountants and internal auditors should proactively reassess internal policies and clarify their roles and responsibilities.

c) Flexibility in Accounting Documents, Templates, and Ledgers

• Enterprises may design or modify accounting voucher and ledger templates to suit their operations and management needs.

• The number of standard ledger forms has been reduced — from 45 under Circular 200 to 42 under Circular 99.

Professional note: While more flexible, companies must issue or revise their internal accounting regulations accordingly. Adjusting forms without updating official accounting policies violates Circular 99’s requirements.

d) Accounting Currency and Foreign Currency Conversion

Circular 99 reaffirms that the official accounting currency is the Vietnamese đồng (VND). However, if an enterprise conducts most transactions in a foreign currency and meets specific criteria, it may choose a foreign currency as its accounting currency.

Recommendation: Enterprises with substantial foreign currency transactions (e.g., FDI firms, exporters/importers) should review eligibility, assess potential impacts on financial statements (exchange rate differences, conversion effects), and update financial statement disclosures accordingly.

e) Financial Statements – Additional Indicators and Expanded Disclosures

• Enterprises may add financial statement line items to better reflect business characteristics and management requirements.

• Financial statements must include comprehensive disclosures explaining the nature, substance, and risks of transactions and events. For certain items, further details on quality, influencing factors, and conditions must be provided.

Professional implication: Circular 99 reinforces the principles under VAS 21 – Presentation of Financial Statements, emphasizing the philosophy of “substance over form.”

Practical Impacts and Implementation Considerations

a) Key Impacts

• Revised chart of accounts: Enterprises must review and update account names, numbers, and structures per Appendix II of Circular 99/2025/TT-BTC.

• Accounting vouchers and ledgers: While customizable, all documentation must comply with the principles of completeness, timeliness, accuracy, and transparency and ensure traceability.

• Auditing and financial reporting: Audited financial statements must be presented in Vietnamese đồng, unless otherwise provided by law.

• Enhanced internal governance: The roles of the chief accountant, supervisory board, and internal control department are further clarified and elevated.

b) Implementation Roadmap

• Plan the internal transition:

  • Develop a timeline leading up to the 2026 fiscal year.

  • Conduct training for accounting teams, internal auditors, and management on key updates.

  • Review existing accounting software, templates, and ledgers to determine upgrade needs.

• Update internal accounting policies:

  • When modifying accounting templates or account codes, enterprises must reissue their internal accounting regulations.

  • The revised regulations must specify the rationale, responsibilities, and effective date of changes.

• Assess financial statement impacts:

  • For entities with foreign currency transactions, mergers, consolidations, or structural changes, Circular 99 provides specific guidance on preparing financial statements in these cases.

  • Example: Companies no longer meeting the going concern assumption must prepare separate financial reports (Form DNKLT) with explanatory notes.

• Testing before official implementation:

  • Before the 2026 fiscal year begins, enterprises should run pilot tests of the new system — including bookkeeping, ledgers, and trial financial statements.

  • If new transactions arise that are not explicitly covered in Circular 99, apply the Law on Accounting, Vietnamese Accounting Standards (VAS), and the general principles of Circular 99 as references.

Proactive Preparation: The Key to Leadership

Circular 99/2025/TT-BTC is not just an update — it represents a strategic advancement in the quality of corporate accounting governance. From document design and chart of accounts to financial reporting and internal control, the Circular establishes a more transparent, accountable, and modern framework.

Enterprises that act early — by training personnel, reviewing accounting processes, and adapting reporting systems — will gain a competitive advantage: more reliable financial statements, stronger risk management, and enhanced credibility with investors, banks, and regulators.

In contrast, passive compliance or delayed implementation will likely result in confusion, errors, and costly corrections when the new regime officially takes effect.

Circular 99/2025/TT-BTC marks a decisive step toward aligning Vietnamese accounting practices with international standards — ensuring that financial information better reflects the true, fair, and transparent picture of each enterprise’s operations.

Viet Australia
Viet Australia Auditing Company is an independent auditing organization licensed and established in 2007 in the Socialist Republic of Vietnam.