On October 27, 2025, the Minister of Finance issued Circular No. 99/2025/TT-BTC guiding the corporate accounting regime (“Circular 99”), which fully replaces Circular 200/2014/TT-BTC (“Circular 200”) and applies to fiscal years beginning on or after January 1, 2026. Circular 99 marks an important shift in the corporate accounting regulatory framework. Below, ATA highlights several notable and important new points of Circular 99 that business owners and accounting departments need to update and pay attention to:
1. Increasing autonomy for enterprises in choosing the accounting currency unit, selecting methods, and implementing accounting books and financial statements
Circular 99 inherits the principles of choosing and determining the accounting currency unit from Circular 200, including key factors relating to revenue/expenses and additional factors regarding capital mobilization/accumulation. However, Circular 99 allows enterprises to proactively choose their accounting currency unit and take full responsibility without having to notify the directly managed tax authority as previously required.
Circular 200 stipulated that enterprises wishing to amend or supplement the chart of accounts to suit their operations and internal management requirements must “request the Ministry of Finance’s approval.” In contrast, Circular 99 removes this requirement. Specifically, enterprises are permitted to change the name, code, structure, and content reflected in the accounts listed in Appendix II of Circular 99. Amendments must ensure that:
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All transactions arising are fully classified and systematized.
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No overlap occurs between accounting objects.
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Current accounting principles are complied with.
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The amendments do not change or affect indicators or information presented in the financial statements.
Importantly, when amending or adding accounting accounts, enterprises are responsible for:
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Issuing an Accounting Account Opening Regulation (or equivalent document) as the basis for implementation.
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The Regulation must specify the reasons and details of the amendments, and the enterprise assumes full legal responsibility for the changes made.
If no amendments are made, the enterprise continues to apply the chart of accounts as guided in Appendix II of Circular 99.
In addition, for transactions not yet guided in Circular 99, enterprises shall base their accounting treatment on the substance of the transaction, the Law on Accounting, Vietnamese Accounting Standards, and guidance principles under Circular 200.
It is clear that Circular 99 provides a proactive mechanism by guiding specific methods that allow enterprises to make autonomous decisions while simultaneously increasing their responsibilities. This is a significant change reflecting a trend toward granting enterprises more autonomy in organizing their accounting systems while tightening accountability and ensuring consistency in financial reporting.
2. Additional principles for preparing financial statements when changing the accounting currency unit
Under Circular 99, the principles for preparing financial statements when changing the accounting currency unit are as follows:
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In the first accounting period after the change, enterprises convert the balances of items on the accounting books and the Statement of Financial Position into the new accounting currency unit using the average transfer-buy/sell exchange rate (the average of the bank’s transfer-buy rate and transfer-sell rate) of the commercial bank where the enterprise has frequent transactions (meaning the bank with which the enterprise has higher transaction frequency or value) on the date of the currency unit change.
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For comparative information (prior-period column) in the Statement of Profit or Loss and the Statement of Cash Flows, the enterprise applies the average transfer-buy/sell exchange rate of the commercial bank where it has frequent transactions for the period immediately preceding the change.
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The enterprise must disclose in the Notes to the Financial Statements the reasons for changing the accounting currency unit and any resulting impact on the financial statements.
3. Major changes in the preparation of financial statements
From January 1, 2026, the corporate financial statement system will include:
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Statement of Financial Position
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Statement of Profit or Loss
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Statement of Cash Flows
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Notes to the Financial Statements
The change in name from “Balance Sheet” under Circular 200 to “Statement of Financial Position,” in our view, is appropriate, as it better reflects the report’s content relating to the enterprise’s assets and liabilities.
Additionally, for the asset section of the Statement of Financial Position, Circular 99 introduces the category of biological assets, including crops and livestock, applicable to enterprises in the agricultural sector. Previously, these were not recognized as a separate asset category but were typically measured as production costs and recorded as work-in-progress.
4. Requirements for enterprises to strengthen internal management and internal control over finance and accounting
a. Requirement to establish internal governance regulations and internal control systems
Circular 200 mainly focused on bookkeeping and preparing financial statements. However, Circular 99 expands its scope to include requirements on corporate governance, internal control, and accounting autonomy. One of the significant changes is the requirement for enterprises to establish internal governance regulations and internal control systems—something not specified in Circular 200.
Accordingly, enterprises are responsible for creating internal governance regulations (or equivalent documents) and establishing internal control systems. The objective is to clearly define the rights, obligations, and responsibilities of each department and individual involved in creating, executing, managing, and controlling economic transactions.
This regulation enhances transparency, ensures accounting and financial activities are strictly monitored, and aligns with the requirements of the Law on Enterprises and related legislation. It is considered an important step towards improving corporate governance standards, especially for large enterprises or those with foreign elements.
b. Requirement to issue internal accounting regulations
Circular 99 clearly states that enterprises must issue Internal Accounting Regulations (or equivalent documents) in the following four situations:
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When designing or amending accounting voucher templates;
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When amending the name, code, structure, or accounting content of accounts;
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When designing or adjusting accounting ledger templates;
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When adding new indicators in the financial statements.
Previously, under Circular 200, these changes could only be made with written approval from the Ministry of Finance. Under Circular 99, enterprises must proactively develop and issue internal governance regulations. When making any of the above-mentioned changes, enterprises must issue Internal Accounting Regulations (or equivalent documents) detailing the necessity of changes and serving as the basis for accounting and auditing. Enterprises bear full legal responsibility for the changes. Clearly, enterprises are granted greater autonomy, but along with it comes increased responsibility to establish clear, transparent, consistent, and well-controlled internal regulations.
5. Subsidiary units are dependent units of the enterprise and are not required to prepare separate financial statements
Previously, Circular 200 required that “dependent units without legal status must prepare their own financial statements consistent with the parent unit’s reporting period to serve consolidation and for State management inspection.”
However, Circular 99 allows enterprises to decide whether to delegate the preparation of separate financial statements to their dependent units. This reduces administrative and reporting burdens.
In addition, Circular 99 clarifies that dependent units are those defined as dependent units under the Law on Enterprises (branches, representative offices, business locations) and completely eliminates the concept of dependent units with legal status (such as subsidiaries, joint ventures, associates, or legally independent units established/acquired through share purchase/contribution). Accordingly, how enterprises monitor and account for financial data of dependent units in books and financial statements will change fundamentally.
Circular 99 is effective from January 1, 2026, and applies to fiscal years beginning on or after January 1, 2026. Small and medium-sized enterprises, non-public units, and other accounting units may choose to apply Circular 99 if suitable.
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