| Criteria | Circular No. 200/2014/TT-BTC | Circular No. 99/2025/TT-BTC |
| Effectiveness | - Effective from 01 January 2015.
- Circular No. 200/2014/TT-BTC is only partially repealed upon the effectiveness of Circular No. 99/2025/TT-BTC, except for the provisions on accounting for the equitization of State-owned enterprises, which remain effective until replaced by a separate regulatory document (pursuant to Clause 2, Article 31 of Circular No. 99/2025/TT-BTC). |
- Circular No. 99/2025/TT-BTC issued on 27 November 2025, replacing Circular No. 200/2014/TT-BTC.
- Effective date: From 01 January 2026, applicable to financial years beginning on or after 01 January 2026. - The guidance on accounting for the equitization of State-owned enterprises under Circular No. 200/2014/TT-BTC shall continue to apply until replaced by new regulations. |
| Internal Governance Regulations
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Not stipulated | Enterprises are responsible for developing their own internal governance regulations (or equivalent documents) and establishing an internal control system.
Pursuant to Article 3 of Circular No. 99/2025/TT-BTC on corporate governance and internal control: “1. The establishment, execution, management, and control of an enterprise’s economic transactions must comply with applicable laws and relevant mechanisms and policies. 2. Enterprises are responsible for developing internal governance regulations (or equivalent documents) and organizing internal control in order to clearly define the rights, obligations, and responsibilities of departments and individuals involved in the establishment, execution, management, and control of economic transactions within the enterprise, ensuring compliance with enterprise law and other relevant laws.” |
| International Financial Reporting Standards (IFRS) | No provisions on the application of IFRS. | Introduces a mechanism for voluntary adoption of IFRS or “IFRS-compatible standards. |
| Change of Accounting Currency | Conversion rules: A key new and distinguishing provision concerns the exchange rate used to convert opening balances when there is a change in the accounting currency. Circular No. 99/2025/TT-BTC requires that the balances of items in the accounting books and the Statement of Financial Position be converted using the average exchange rate (or the average remittance buying and selling rate) of the commercial bank with which the enterprise regularly conducts transactions. This provision resolves long-standing debates over whether to use the buying rate, selling rate, or specific book rate for converting opening balances, thereby helping to standardize comparable data between accounting periods.
Pursuant to Point a, Clause 2, Article 5 of Circular No. 99/2025/TT-BTC “a) In the first accounting period following the change, the enterprise shall convert the balances of items in the accounting books and the Statement of Financial Position into the new accounting currency using the average remittance buying and selling exchange rate (being the arithmetic mean of the remittance buying rate and the remittance selling rate) of the commercial bank with which the enterprise regularly conducts transactions (i.e., the commercial bank with which the enterprise has a higher frequency or value of transactions compared to others) as of the date of the change in the accounting currency.” |
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| Chart of Accounts System | - 9 main categories of accounts
- Prior approval required: Any addition of Level 1 or Level 2 accounts, or any amendment (name, code, structure, content, etc.) to Level 1 or Level 2 accounts must obtain written approval from the Ministry of Finance. - Limitations: Enterprises may only open additional Level 2 or Level 3 accounts if the corresponding Level 1 account does not already prescribe Level 2 or Level 3 accounts. Legal basis: The Enterprise Chart of Accounts stipulated in Appendix I and Article 9 of Circular No. 200/2014/TT-BTC |
- The number of accounts is reduced from 76 to 71.
- Nine categories retained, but rearranged according to substance (Assets – Liabilities/Equity – Business Results – Others) - Enterprises are entitled to amend and supplement the names, codes, structures, and contents of accounts to meet management requirements. - Only required to issue an Accounting Policies/Accounting Recording Regulation (or equivalent) detailing such changes and bear legal responsibility for them. - Must comply with accounting principles and not affect the financial statements. Legal basis: Appendix II and Article 11 of Circular No. 99/2025/TT-BTC |
| Revenue Recognition Principles | - Revenue is recognized when risks and rewards are transferred and the buyer has accepted the goods/services. | - Revenue is recognized when control of goods or services is transferred to the customer, in line with IFRS 15. |
| Service Revenue | - Recognized upon completion of the service in whole or in part | - Recognized based on the stage of completion, provided that the progress can be reliably measured. |
| Revenue from Long-term Contracts | - Recognized upon completion, or based on progress if the outcome can be reliably determined | - Recognized based on performance obligations, with a requirement to identify and separate performance obligations within the contract. |
| Revenue Deductions | - The Account Group 521 continues to be used, but enterprises are required to provide detailed disclosure of each type of revenue deduction in the Notes to the Financial Statements
Legal basis: Article 14 of Circular No. 99/2025/TT-BTC |
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| Production and Business Expenses | - Expenses are recognized by nature (e.g., materials, labor, etc.) or by function | - Expenses are recognized by function (e.g., selling, administrative, R&D), with encouragement to present in accordance with IFRS |
| Corporate Income Tax (CIT) Expense | - Recognized when the tax obligation arises | - Deferred income tax is additionally required if the enterprise applies IFRS |
| Financial Expenses and Other Expenses | - Traditional classification (Accounts 635, 811) | - Retained, but with a requirement to separately present unrealized foreign exchange gains/losses. |
| Accounting Book | Pursuant to Clause 2, Article 122 of Circular No. 200/2014/TT-BTC:
“2. Enterprises may design their own accounting book forms, provided that such forms ensure transparent, complete, easy-to-check, easy-to-control, and easy-to-reconcile information on economic transactions. In cases where enterprises do not design their own accounting book forms, they may apply the accounting book forms provided in Appendix 4 to this Circular, if suitable to their management characteristics and business operations.”. |
Pursuant to Clause 2, Article 12 of Circular No. 99/2025/TT-BTC
“… When designing additional accounting book forms or amending and supplementing existing ones, enterprises are responsible for issuing Accounting Recording Regulations (or equivalent documents) covering such amendments and supplements as a basis for implementation. Such regulations must clearly state the necessity of the amendments or supplements and the enterprise’s responsibility before the law for the amended and supplemented contents…”. |
| Financial Statements
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Title: Uses the term “Balance Sheet.”
Legal basis: Article 100 of Circular No. 200/2014/TT-BTC. |
Title: Renamed to “Statement of Financial Position.”
Legal basis: Article 17 of Circular No. 99/2025/TT-BTC |
| - Enterprises may delegate to dependent units the preparation or non-preparation of separate financial statements.
- Financial statements submitted to competent authorities or disclosed publicly must always include the financial information of the head office and all dependent units. |
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| Addition of new asset and equity/liability line items, including:
- Biological assets: Introduction of new line items such as “Short-term biological assets” (Code 150) and “Long-term biological assets” (Code 230) - Global minimum tax: The Statement of Profit or Loss includes a new item for “Additional corporate income tax expense under global minimum tax regulations,” detailed from Account 82112). - Dividends and profits payable: A separate line item “Dividends and profits payable” (Code 313) is presented independently under short-term liabilities. - Treasury shares: The term “Treasury shares” is replaced with “Own shares repurchased” (Code 415) under equity. |
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| Foreign exchange conversion principle: Uses the buying/selling exchange rate of the commercial bank at the reporting date for each type of asset or liability.
Legal basis: Point a, Clause 2, Article 107 of Circular No. 200/2014/TT-BTC |
Foreign exchange conversion principle: Uses the average remittance buying and selling exchange rate (the arithmetic mean of the remittance buying and selling rates) of the commercial bank with which the enterprise regularly conducts transactions to convert asset and liability items at the end of the accounting period.
Legal basis: Point a, Clause 3, Article 6 of Circular No. 99/2025/TT-BTC. |
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| Financial statements for enterprises not meeting the going-concern assumption (i.e. enterprises in dissolution, bankruptcy, or cessation of operations):
- Items in the Statement of Financial Position are not classified into current and non-current. - Enterprises are not required to present provisions; provisions are deducted directly from the carrying amounts of assets. |
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| Amendment or supplementation of reporting line items when enterprises amend or supplement reporting items, they must issue internal accounting regulations and bear legal responsibility for the necessity of such changes.
Legal basis: Article 18 of Circular No. 99/2025/TT-BTC. |
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| Regarding the reporting submission deadline: The deadline is 30 days for private enterprises and partnerships, and 90 days for other entities.
Legal basis: Article 109 of Circular No. 200/2014/TT-BTC. |
A uniform deadline for submission of annual financial statements to the competent authorities is no later than 90 days from the end of the annual accounting period, applicable to all enterprises.
Legal basis: Article 25 of Circular No. 99/2025/TT-BTC |
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| Accounting at Dependent Units
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Enterprises (head offices) are entitled to decide on accounting practices at dependent units (dependent accounting), including:
- Whether capital allocations are recognized as liabilities or equity. - Whether to recognize or not recognize revenue and cost of goods sold for internal transfers, regardless of the form of supporting documents. Legal basis: Article 7 of Circular No. 99/2025/TT-BTC |
Reference consultation: Tax advisory legal services
