
Circular 99 - VAS
The Ministry of Finance has officially issued Circular 99/2025/TT-BTC, introducing a new accounting regime for enterprises in Vietnam. Effective January 1, 2026, this circular replaces Circular 200/2014/TT-BTC, marking the most comprehensive update to the Vietnamese Accounting System (VAS) in over a decade. Circular 99 modernizes how businesses record, report, and manage their financial information. It aims to simplify accounting processes, strengthen internal control, and make financial statements more transparent and consistent across sectors.

Overview of Circular 99/2025/TT-BTC
Circular 99 was issued on October 27, 2025, by the Ministry of Finance. It serves as the new accounting framework for guiding enterprises in preparing and presenting their financial statements.
Circular 99 applies to all types of enterprises, regardless of ownership or business line, and provides detailed guidance on accounting vouchers, bookkeeping systems, financial statement preparation, and internal management requirements.
Main objectives of Circular 99
Modernization
Update outdated provisions from Circular 200 to reflect current business realities and digital accounting practices.
Consistency
Align Vietnam’s enterprise accounting regime with the principles established under the Vietnamese Accounting Standards (VAS).
Transparency
Strengthen the reliability of financial data through enhanced internal control and governance.
Simplification
Reduce unnecessary reporting complexity, allowing enterprises to focus on core financial management activities.
Scope of Application
Universality
Applies to all enterprises in Vietnam, including foreign-invested entities.
Specialization
Credit institutions and foreign bank branches continue to follow specific accounting guidance under the State Bank but may align with parts of Circular 99 for internal consistency.
Flexibility
Enterprises operating in foreign currency are permitted to use it as their accounting currency if they meet defined criteria.
Major Updates Introduced by Circular 99
Circular 99 is not a minor revision, it redefines several core aspects of how accounting is organized and executed in Vietnamese enterprises.
Relationship with the Vietnamese Accounting Standards (VAS)
Circular 99 operates within the framework of Vietnamese Accounting Standards (VAS) it does not replace them. While VAS provides the principles and measurement standards, Circular 99 defines how enterprises must apply those principles in practice.
This means Circular 99 is essentially the implementation guide for VAS:
- It translates VAS concepts into concrete actions such as which accounts to use, how to record transactions, and how to present results.
- The updates under Circular 99 ensure consistency with existing VAS rules while improving clarity, terminology, and application in modern accounting environments.
- The new regime simplifies compliance by aligning accounting forms, statements, and data structures with VAS principles on recognition, valuation, and presentation.
In other words, enterprises remain VAS-compliant by following Circular 99, but will now do so through a more structured, transparent, and technology-friendly system.
TT99 Pain Points and Solution
Pain Points
- Chart of accounts transition issues:
- Difficulty in creating a new chart of accounts that can properly correspond to the old system.
- Need to reconcile balances and reports between the old and new systems during the initial operation period.
- Accounting rule changes: May lead to errors made by staff during data entry and transaction posting.
- Disclosure reporting challenges: Lack of flexibility in the software makes it hard to prepare disclosure reports.
Solutions (SunSystems)
- Smoother chart of accounts transition:
- Dual recording under TT200 and TT99 within the same system.
- Maintain both standards simultaneously yet separately for accurate transition.
- Experienced implementation team (e.g., Decision 15 → TT200) ensures faster adaptation and support.
- Error prevention in postings: Customizable validation rules remind or prevent users from incorrect postings.
- Flexible reporting: SunSystems allows easy configuration and creation of customized reports to meet changing requirements.
Frequently Asked Questions
Businesses often hesitate to adopt a new accounting system due to major concerns like:
- Disrupting established data flow
- Causing confusion or errors within the existing account structure
TRG’s VAS 99 offers a flexible solution that enables businesses to ensure compliance with current and future regulatory standards through a single unified platform, effectively eliminating compliance concerns.
TRG has created a 6-step checklist to help businesses assess and prepare for the transition to Circular 99. The checklist includes planning, account mapping, personnel training.
The actual implementation timeframe depends largely on the organisation’s data volume, typically ranging from 5 to 7 business days.
SunSystems stands out for its flexible customisation capabilities, enabling it to closely align with each organisation’s unique requirements. TRG’s VAS 99 solution is also built on this adaptable concept.
TRG has a successful track record of advising on and implementing tailored business solutions across various sectors, from Insurance, Financial Services, to Logistics, Hospitality, and more.
Centralised management of the Chart of Accounts (COA) is achievable using Infor SunSystems and TRG’s VAS 99 solution. This will be implemented through COA Mapping to guarantee that all subsidiary transactions comply with Circular 99.
TRG proactively monitors Circular 99 updates. This approach allows us to develop standardised and customisable reporting templates, a key factor in optimising both project duration and costs for clients.



