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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.

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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Update outdated provisions from Circular 200 to reflect current business realities and digital accounting practices.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

01

Universality

Applies to all enterprises in Vietnam, including foreign-invested entities. 

02

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. 

03

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.

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Strengthened Internal Control and Governance

Enterprises must now establish clear internal governance mechanisms. Defining responsibilities and approval authority for all accounting transactions. Ensuring accounting processes comply with both enterprise law and accounting regulations. Maintaining documentation to support accountability and traceability of financial activities. 

The intent is to create a stronger control environment where data accuracy and transparency are protected by design, not just by audit. 

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Accounting Currency Rules

While Vietnamese Dong (VND) remains the default accounting currency, Circular 99 allows enterprises to use a foreign currency as their accounting currency under specific conditions. 

An enterprise may adopt a foreign currency if that currency is: 

  • Used primarily for pricing goods and services; 
  • Used for paying major costs such as raw materials or capital expenses; 
  • The currency in which the enterprise raises and settles most financing activities. 

When a foreign currency is used: 

  • The enterprise must clearly disclose the chosen currency and conversion method. 
  • All regulatory financial statements must still be translated into VND for submission to authorities. 
  • Any change in accounting currency must be justified by a significant business shift and converted using the average transaction exchange rate of the main bank on the date of change. 
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Chart of Accounts Overhaul

Circular 99 introduces a more flexible chart of accounts. Enterprises can now adjust account codes, rename accounts, or add sub-accounts to reflect their business model as long as the structure still supports required financial statement indicators. 

Notable updates include: 

  • The addition of Account 215 – Biological Assets, separating these from tangible fixed assets. 
  • The simplification or consolidation of several older accounts to reduce duplication and improve clarity. 

This flexibility allows modern accounting software to be configured more efficiently, accommodating industry-specific needs without violating compliance rules. 

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Accounting Books and Vouchers

Enterprises are now granted more autonomy to design their own voucher and bookkeeping templates. Circular 99 reduces the number of standardized book templates from 45 to 42, reflecting a focus on digital record-keeping and automation rather than manual forms. 

However, all documentation must still meet the basic requirements for authenticity, traceability, and completeness as prescribed by the Law on Accounting.

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Financial Statements

Terminology and format have been updated to better reflect global accounting practices. 

  • “Balance Sheet” is now referred to as the “Statement of Financial Position.” 
  • Enterprises are required to prepare annual financial statements. Interim (quarterly or half-year) reports are optional unless otherwise required by law. 
  • Consolidation requirements are clarified: head offices must combine financial data from all branches and subsidiaries, eliminating internal transactions to present a unified picture of the enterprise’s financial position. 
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Accounting at Branches and Subsidiaries

Circular 99 emphasizes centralized accounting under the head office. Branches are no longer required to prepare independent financial statements unless mandated by separate regulations. All internal transactions between units must be identified and eliminated during consolidation to ensure accuracy and prevent duplication of income or expenses.

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

  1. 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.
  2. Accounting rule changes: May lead to errors made by staff during data entry and transaction posting.
  3. Disclosure reporting challenges: Lack of flexibility in the software makes it hard to prepare disclosure reports.

Solutions (SunSystems)

  1. 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.
  2. Error prevention in postings: Customizable validation rules remind or prevent users from incorrect postings.
  3. Flexible reporting: SunSystems allows easy configuration and creation of customized reports to meet changing requirements.

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.

TRG can help your business stay compliant. Schedule a call with our team now

Key Changes at a Glance

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Area

Scope & Applicability

Governance & Internal Control

Accounting Currency

Chart of Accounts

Accounting Books & Vouchers

Financial Statements

Branch/Subsidiary Reporting

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Under Circular 200/2014

All enterprises, basic compliance rules

General guidance only

Primarily VND

Fixed structure

45 standard forms

“Balance Sheet”, “Profit & Loss”

Branches often report separately

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Under Circular 99/2025

All enterprises, detailed governance & control framework

Clear requirement for internal control and defined responsibilities

Option for foreign currency with strict criteria and conversion rules

Flexible, customizable; new account 215 for biological assets

Reduced to 42; more autonomy to design templates

Renamed “Statement of Financial Position”

Head office consolidation required; internal transactions eliminated

build at: 2026-01-30T08:50:36.469Z