Circular No. 99/2025/TT-BTC, which replaces Circular No. 200/2014/TT-BTC : Opportunities and challenges for Vietnamese enterprises in the era of international integration

Circular No. 99/2025/TT-BTC, which replaces Circular No. 200/2014/TT-BTC and takes effect from 1st January 2026

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Circular No. 99/2025/TT-BTC, issued by the Ministry of Finance, officially replaces Circular No. 200/2014/TT-BTC and will take effect from January 1, 2026. This marks a significant milestone in modernizing Vietnam’s accounting system, enhancing financial transparency, and harmonizing with international standards (IFRS).

The newsletter, prepared by JPA Vietnam, provides a comprehensive overview of key changes, opportunities, and challenges facing enterprises during the transition period.

Scope and Core Principles

• The Circular applies to all enterprises operating in Vietnam, including newly added subjects such as credit institutions (except for specific banking operations).

• Enterprises are now required to establish internal control and accounting governance mechanisms, demonstrating the shift from traditional financial accounting toward modern management accounting.

Key Highlights

• Functional Currency Flexibility: Enterprises may choose to use foreign currency as their accounting currency if it reflects their primary business operations, aligned with IAS 21 – The Effects of Changes in Foreign Exchange Rates.
• Internal Accounting System Redesign: Companies have the autonomy to decide whether subsidiaries prepare separate financial statements, ensuring accurate internal management reflection.
• Electronic and Digital Accounting Transformation: Enterprises can now design or customize their electronic vouchers and templates, eliminating outdated procedural constraints.
• Updated Chart of Accounts (Annex II): Includes new accounts such as Account 215 – Biological Assets, Account 2295 – Provision for Biological Asset Losses, and Account 82112 – Supplemental CIT (GloBE 15%).
• Revenue and Expense Recognition: Revenue is recognized based on performance obligations, consistent with IFRS 15; expenses can now be presented by function (sales, administration, R&D).
• Expanded Financial Statement Disclosures: The Notes to Financial Statements become mandatory, requiring five new information categories including entity profile, accounting policies, special transactions, and capital movements.

Impacts and Opportunities

• Transparency – Autonomy – Internationalization: The reform enhances reliability and comparability for FDI companies, exporters, logistics firms, and multinational groups, ensuring that financial statements reflect economic substance.

• Challenges: Enterprises must retrain accounting personnel, upgrade ERP and accounting software, and standardize internal reporting systems to ensure compliance by fiscal year 2026.

Effective Date and Replacements

• Effective January 1, 2026, Circular 99 officially replaces Circulars 200/2014/TT-BTC, 75/2015/TT-BTC, 53/2016/TT-BTC, and 195/2012/TT-BTC.

• Vietnam’s corporate accounting system will operate under a unified regulatory framework, eliminating overlaps and enhancing compliance efficiency and financial transparency.