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KEY HIGHLIGHTS OF CIRCULAR NO. 99/2025/TT-BTC REPLACING CIRCULAR NO. 200/2014/TT-BTC (EFFECTIVE FROM JANUARY 1, 2026)

1.1 Scope and Applicable Entities

  • Applicable Entities: Covers all types of enterprises, except micro-sized enterprises. Notably, the scope has been expanded to include foreign direct investment (FDI) enterprises, with the option to adopt International Financial Reporting Standards (IFRS) either fully or partially, depending on the enterprise’s needs and implementation capacity.
  • Scope: Aligned with IFRS — aiming to harmonize and unify the Vietnamese Accounting Standards (VAS 2025) with IFRS.

2.2 Accounting Account System (Article 11, Appendix II issued with the Circular)

  • Enterprise autonomy: Enterprises are allowed to design, add, or modify accounting accounts to suit their specific operations, with only a notification to the tax authority required — no longer needing approval from the Ministry of Finance as before.
  • Account structure: The accounting account system is reorganized into 9 groups, based on the nature of Assets – Liabilities – Business Results – Others.
  • New accounts introduced:
  • Account 137 – Accrued Revenue
  • Account 246 – Long-term Prepaid Expenses
  • Account 351 – Provision for Obligations
  • Renaming of accounts

2.3 Financial Statements (Article 17)            

  • Renamed financial statement components:
  • Statement of Financial Position
  • Statement of Profit or Loss
  • Statement of Cash Flows
  • Notes to the Financial Statements
  • Financial statement set for non-going concern enterprises includes the following forms: (B01-DNKLT, B02-DNKLT, B03-DNKLT, B09-DNKLT)
  • Presentation standards: The Circular requires a clear distinction between operating profit and other income, and introduces the section Other Comprehensive Income (OCI).

2.4 Reporting Currency (Article 4)

The default reporting currency is the Vietnamese đồng (VND). Enterprises may choose another currency if they meet the prescribed conditions; however, they must clearly disclose the basis for selecting a foreign currency as the accounting currency in their financial statements

2.5 Recognition, Measurement, and Presentation (Section B – Accounting Content and Methods)

Revenue Recognition

  • Enterprise obligations under each contract
  • Determination of value and allocation based on substance
  • Identification of performance obligations in sales transaction

Inventories

  • Supplemented regulation: inventories must be measured at the lower of cost and net realizable value (NRV), ensuring more accurate and prudent financial reporting

Fixed Assets

  • Enterprises may choose the fair value model
  • Clear disclosure in financial statements regarding the basis for valuation
  • Value recognition based on assessments by professional appraisal organizations

Financial Instruments and Provisions (IFRS 9 & IFRS 37)

  • Classification of financial instruments based on holding purpose: for trading or resale for profit
  • Assessment of receivables’ maturity to determine recoverability and provision for doubtful debts
  • Recognition of provisions for contingent obligations, including: Enterprise restructuring provisions, Provisions for high-risk contracts, Provisions for warranties on products, goods, and construction works

2.6 Other Notable New Points

  • Reclassification of revenue and expenses based on the nature of transactions rather than by function
  • Additional disclosure requirements regarding financial risks, foreign exchange risks, and payment risks
  • Mandatory adoption of International Financial Reporting Standards (IFRS) by listed companies and large-scale foreign-invested enterprises (FDIs) before 2030
  • Standardization of electronic accounting documents and books in accordance with the 2023 Law on Electronic Transactions
  • Issuance of an appendix for account code conversion between Circular 200 and Circular 99