Circular 99/2025/TT-BTC: Key Accounting Changes for Businesses in Vietnam

Circular 99/2025/TT-BTC is considered a significant milestone in the evolution of Vietnam's enterprise accounting system, aiming to:

• Enhance flexibility
• Improve transparency
• Align more closely with international practices
• Better reflect business realities

Importantly, Circular 99 governs accounting documents, the chart of accounts, bookkeeping and the preparation of financial statements only. It does not apply to the determination of tax obligations, which continue to be governed separately by tax law. For any transaction not yet addressed by specific guidance, enterprises should refer to the substance of the transaction, the Law on Accounting, Vietnamese Accounting Standards (VAS), and the general principles of Circular 99 itself.

1. What regulations does Circular 99/2025/TT-BTC replace?

Circular 99 replaces the following regulations:

• Circular 200/2014/TT-BTC (except for provisions relating to accounting for equitisation of state-owned enterprises)
• Circular 75/2015/TT-BTC
• Circular 53/2016/TT-BTC
• Circular 195/2012/TT-BTC guiding accounting applicable to project owners/investors

The issuance of Circular 99 marks a substantial reform in the enterprise accounting system, with a focus on simplifying administrative procedures and granting enterprises greater autonomy in organising and implementing their accounting practices.

2. Scope of application

Circular 99/2025/TT-BTC provides guidance on:

• Accounting documents
• Chart of accounts
• Bookkeeping
• Financial statements, including accounting accounts and guidance on recording economic transactions in the accounting books of enterprises

Circular 99 applies to all enterprises across all sectors and economic types. Credit institutions and foreign bank branches shall apply accounting regimes or accounting regulations in accordance with the guidance of the State Bank of Vietnam.

3. What this means for businesses: more autonomy, but with real conditions attached

The key change introduced by Circular 99/2025/TT-BTC is a shift in philosophy: from an "applying standardised forms" mindset towards one where enterprises are given the autonomy to design their own accounting system and records so long as they reflect economic substance faithfully and ensure compliance with the accounting law and relevant regulations.

In practice, businesses may now:

• Rename or renumber accounts
• Change the structure or content of an account

Provided that these changes do not alter the figures or information presented on the financial statements. The trade-off for this flexibility is accountability: any enterprise that customises its chart of accounts must issue an internal Accounting Policy Regulation (Quy chế hạch toán kế toán) or equivalent documentation setting out the basis, purpose and legal responsibility for the change. Enterprises that keep the standard Circular 99 chart of accounts unchanged are not required to issue this regulation.

This same "designed by the enterprise, governed by internal policy" logic extends to accounting vouchers and ledgers:

• Circular 99 does not prescribe mandatory accounting document templates. Enterprises may refer to the templates provided in Appendix I or proactively design, revise, and supplement documents to suit their operations, provided that they comply with applicable regulations and are supported by duly issued internal policies and procedures.
• One practical tightening to note: the chief accountant or an authorised person may no longer sign "on behalf of" (thừa ủy quyền) a manager's title on accounting vouchers, except where explicitly permitted by law, a change that will require companies to review delegation-of-authority and e-signature workflows on their ERP systems.

4. Strengthening corporate governance and internal control

Circular 99/2025/TT-BTC encourages enterprises to establish internal governance regulations (or equivalent internal control documentation) to clearly define the authority and responsibilities of each department. This requirement contributes to:

• Improving transaction control efficiency
• Enhancing transparency
• Reducing operational risks
• Strengthening corporate governance systems

This is a deliberate shift in the role of the chief accountant, from a compliance-focused record-keeper to someone responsible for designing processes and controlling risk, since the enterprise now bears full responsibility for its own governance and internal control system.

5. Accounting currency and foreign exchange transactions

The Circular 99/2025/TT-BTC introduces more comprehensive guidance on:

• Selecting the accounting currency based on priority criteria (listed selling price, sales price denomination and settlement, cost denomination and settlement, and debt/equity financing)
• Foreign exchange (FX) rates applied upon a change in the accounting currency
• Accounting treatment of foreign exchange differences
• Presenting foreign currency transactions in the financial statements

Two changes here carry real bottom-line implications:

• First, enterprises are not permitted to capitalise foreign exchange differences into the value of construction in progress (this requirement has been further clarified compared to previous regulations); such differences must now be recognised directly in the income statement.
• Second, year-end FX differences on monetary items no longer pass through the intermediary account 413 before being reclassified, they are recognised directly into financial income (account 515) or financial expense (account 635) after netting gains and losses. Enterprises should also note that receivables already covered by bad-debt provisions, and advances from customers and advances to suppliers denominated in foreign currency, are not revalued at year end. The new provisions help ensure that financial statements appropriately reflect the substance of economic transactions and align with operational realities of the enterprise, but they also mean FX volatility may be reflected faster and more directly in reported profit.

6. Key accounting areas undergoing substantive change

Beyond currency and governance, several technical areas of the chart of accounts and recognition principles have shifted materially and deserve close attention from finance teams applying Circular 99/2025/TT-BTC:

Revenue recognition: Circular 99 requires enterprises to unbundle contracts containing multiple performance obligations (e.g. equipment sale bundled with a specific period maintenance service) and allocate the transaction price based on the standalone selling price of each component. Goods revenue is recognised upon transfer of control, while service revenue is deferred and recognised over the service period.

• For real estate, revenue can only be recognised once risks and rewards have transferred, the buyer has taken handover and gained control of the entire asset, not simply on a payment-schedule basis.
• Condotel/officetel-type products must have their sale, lease and financing components separated for distinct accounting treatment.
• Enterprises acting as agents (e.g. e-commerce or logistics platforms) must recognise only the net commission as revenue, not the gross transaction value, a distinction the workshop materials specifically flag as a common compliance risk.

Biological assets are recognised as a distinct asset category for the first time, split between agricultural and non-agricultural biological assets, with new accounts (2151, 2152, 2153) and a defined lifecycle for capitalising rearing/cultivation costs, commencing depreciation at maturity, and testing for impairment.

Financial investments: Transaction costs related to trading securities are recognised immediately in finance costs and shall not be capitalised into the cost of the investment; in addition, reclassification between trading securities (Account 121) and held-to-maturity investments (Account 128) is not permitted throughout the holding period.

Allowance for doubtful accounts shall be provided based on the overdue period as follows:

• 30% of the receivable value for amounts overdue from 6 months to under 1 year
• 50% for amounts overdue from 1 year to under 2 years
• 70% for amounts overdue from 2 years to under 3 years
• 100% for amounts overdue from 3 years and above

Global Minimum Tax (Pillar Two): Circular 99 introduces detailed guidance, including a new account code (TK 82112) to reflect top-up corporate income tax under the global minimum tax regime. It also requires that this expense be recognised concurrently with deferred income tax assets (TK 243) to address temporary timing differences between the period in which the obligation arises and the period of tax filing. In addition, entities are required to disclose the period in which the obligation arises, the filing period, the allocation basis of the tax obligation among constituent entities, the estimated top-up corporate income tax, and any differences between the estimated and the actual filed amounts.

Abolition of accruals for major repairs of tangible fixed assets: The practice of accruing costs for major repairs of fixed assets is abolished (except for certain asset restoration obligations under lease agreements). Periodic repair and maintenance costs are recognised based on actual expenses incurred and amortised over time, while upgrade and renovation costs that increase the asset’s economic benefits will be capitalised into the cost of the fixed asset.

7. Financial statements: greater flexibility and transparency

Circular 99/2025/TT-BTC maintains the fundamental structure of the current financial statements system while significantly increasing flexibility and transparency in the presentation of financial information. Key highlights include:

Renaming of the "Balance Sheet" to "Statement of Financial Position"

Under Circular 99, the term "Balance Sheet" is replaced with "Statement of Financial Position", better reflecting the nature of assets, liabilities and the enterprise's financial position.

New regulations on financial statements line items

Circular 99 grants enterprises greater flexibility in presenting financial information. Specifically:

• Line items with no data are not required to be presented
• However, line item codes must remain unchanged to ensure consistency
• Numbering may only be adjusted sequentially within each section

Enterprises are also permitted to introduce additional line items relevant to their operational characteristics and management requirements, provided that accounting principles are complied with and that the additions are clearly disclosed in the financial statements. Where additional line items are introduced, enterprises must issue accounting policies (or equivalent internal documentation) as the basis for application, setting out the purpose, necessity and related legal responsibilities. Reporting to the Ministry of Finance is only required where an enterprise's specific circumstances prevent it from adding line items in the ordinary way, or where it wishes to change the name or content of an existing standard line item, not simply because it has added supplementary line items under its own internal policy.

Disclosure of audited financial statements

For enterprises subject to statutory audit requirements, disclosed financial statements must be accompanied by the relevant audit report in accordance with applicable regulations.  Financial statements disclosed without an attached audit report are deemed not to have satisfied the applicable legal disclosure requirements.

Signatories and approval date of financial statements

Circular 99 requires that financial statements be signed off by the preparer, chief accountant, and the enterprise's legal representative (replacing the previous "Director/General Director" title), and introduces the term "approval date" in place of "date of preparation", a change that requires closer coordination between the accounting, legal and management functions to ensure that the Company Charter is updated or amended to comply with the new requirements.

Deadline for submission of financial statements

Enterprises must submit their financial statements within 90 days from the end of the annual accounting period, the final deadline applicable to every type of enterprise, regardless of size or ownership structure.

8. What changes for businesses under Circular 99/2025/TT-BTC?

Circular 99/2025/TT-BTC retains the relevant strengths of the previous regulations while eliminating outdated or impractical provisions. It not only enhances flexibility and autonomy but also promotes consistency, financial transparency, corporate governance, and convergence with international accounting practices. With its positive reforms, Circular 99 provides a stronger foundation for enterprises to better adapt to the modern business environment and increasingly complex economic transactions.

In practical terms, businesses should:

How can we help?

We support businesses in reviewing the impact of Circular 99/2025/TT-BTC on their financial reporting and identifying practical gaps early.

Our audit and assurance team works alongside you to strengthen accounting policies, align reporting practices, and support compliance for the 2026 financial year.

*Disclaimer: The materials presented by Forvis Mazars Vietnam have been prepared for the purpose of providing professional updates in Vietnam. The information, analyses, and comments contained herein are intended solely as general guidance and are based on, cited from, and interpreted from official regulations and documents issued by government authorities. We recommend that clients contact Forvis Mazars Vietnam's advisory team for detailed professional advice tailored to their specific circumstances.