Vietnam has implemented significant tax and accounting reforms. On 27Oct2025, the Ministry of Finance issued Circular 99/2025/TT-BTC on the enterprise accounting regime, replacing Circular 200/2014/TT-BTC and its related amendments. In general, the Circular 99 effective from 1Jan2026 aligns more closely with international standards (IFRS), supports a principle-based approach. This shift from compliance by instruction to compliance by principle encourages a mindset closer to IFRS while maintaining the foundations of Vietnamese Accounting Standards (VAS).
Below are Key Changes in the new Regulation applying to fiscal years beginning on or after 1Jan2026.
- More Flexible in Accounting Systems and Documentation
Compared with the rigid structure under Circular 200, Circular 99 gives enterprises more flexibility in how they design and manage their accounting documentation and systems. They may amend or supplement account titles, numbers, and structures, provided they do not alter the substance of the financial statements. Also enterprises may design their own forms of vouchers, e-vouchers, and accounting books suited to their operations, as long as they retain the basic required contents and ensure authenticity, verifiability, and traceability.
The amendments and self-designs must be supported by the issued internal accounting regulations of their own enterprises.
- Clearer Guidance on Consolidation Accounting
While Circular 200 required consolidation for parent–subsidiary groups, Circular 99 extends this requirement to dependent and related units. From 2026, enterprises with subsidiaries, dependent or related units are now required to prepare consolidated financial statements and eliminate internal transactions.
- Enterprises can choose functional Accounting Currency
The default currency remains Dong (VND). Enterprises primarily operating in foreign currencies for receipts, payments, pricing, or costs, may designate a foreign currency as their functional currency.
- Financial statements and disclosures
Circular 99 standardizes the names of financial statements (e.g., ‘Balance Sheet’ → ‘Statement of Financial Position) and requires applying the retroactive principle when changes are made to the functional currency. Under the new regulation, Set of Financial Statements includes Statement of Financial Position, Statement of Profit and Loss (P&L); Cash Flow Statement and emphases on the notes with new disclosure areas include:
- Basis for selecting accounting policy (basis of preparation, currency, revenue recognition principles, expense classification (by nature or function)).
- Impacts of currency changes.
- Internal transactions and risk exposures.
- Consolidation methods for multi-entity groups.
- For enterprises with special characteristics (mergers/splits/restructuring) the Circular provides more detailed guidance.
The detailed disclosures on internal transactions, currency impacts, and consolidation methods are expected to more transparency to investors, lenders, regulators, and other stakeholders.
- Internal Accounting Governance plays an important role.
Circular 99 requires businesses to take ownership of their internal accounting governance by establishing clear internal rules and control procedures, instead of relying on rigid templates formed as in Circular 200.