On 27/10/2025, the Ministry of Finance of Vietnam officially issued Circular 99/2025/TT-BTC ("Circular 99"), which will fully replace Circular 200/2014/TT-BTC, which shall take effect for fiscal years beginning on or after 01/01/2026.
This is not just a periodic update, but a strategic pivot designed to reshape the Vietnamese Accounting Standards (VAS). It simultaneously addresses two major objectives: (1) enhancing integration with International Financial Reporting Standards (IFRS) and (2) resolving practical challenges that have persisted over the past decade.
Circular 99 introduces substantive changes focused on global economic trends and Vietnamese market realities.
1. International Integration: Responding to Global Minimum Tax (Pillar Two)
This is the most pressing and topical update. Circular 99 has officially added Account 82112 - "Additional Corporate Income Tax (CIT) Expense under Global Minimum Tax Regulations." This addition provides a clear legal basis for multinational corporations, foreign-invested enterprises (FDI), and Vietnamese companies with outbound investments to accurately account for the supplementary tax under the OECD's Pillar Two. This ends the previous uncertainty in recognizing this significant expense.
2. Solving a Practical Gap: First-Time Recognition of Biological Assets
Circular 99 introduces Account 215 - "Biological Assets," a long-awaited change, especially for businesses in specialized sectors. Enterprises in agriculture, forestry, and fishery (e.g., rubber plantations, livestock farming) now have a formal basis to recognize and track their biological assets appropriately. This is a major step forward in reflecting the true asset value of this industry group, moving closer to alignment with IAS 41 (Agriculture).
3. Enhancing Corporate Autonomy, Emphasizing Internal Control
A significant shift in management philosophy, Circular 99 grants greater autonomy to enterprises, but this is paired with higher demands on their control systems.
- Empowerment: Businesses are now permitted to design and modify their own accounting vouchers (e.g., payment/receipt vouchers, inventory forms) and ledger formats, provided they maintain all core elements required by the Law on Accounting. This replaces the mandatory adherence to rigid templates under Circular 200.
- Increased Responsibility: In return for this flexibility, the Circular emphasizes the company's role in building, maintaining, and supervising an effective internal control system (ICS) to ensure the fairness and reasonableness of its financial information.
4. Enhancing Reporting Transparency and Foreign Exchange (FX) Transactions
Circular 99 provides clearer, sharper guidance on handling FX-related elements.
- "Statement of Financial Position": The "Balance Sheet" (Bảng Cân đối Kế toán) is officially renamed the "Statement of Financial Position," clearly signaling integration with IFRS language and methodology.
- FS Conversion: The document provides more detailed and clearer guidance on the method for converting financial statements prepared in a foreign currency to Vietnamese Dong (VND) for submission to state authorities, ensuring consistency and transparency.
What Should Businesses Do Now?
The 01/01/2026, effective date is fast approaching, and the transition from Circular 200 to Circular 99 requires careful preparation. We recommend businesses take the following steps:
- Training and Updates: Assign accountants to attend expert-led training sessions to fully understand the nature and key differences between the two circulars.
- System Review and Upgrade: Work with ERP and accounting software providers to ensure they update the chart of accounts (e.g., Acc. 215, Acc. 82112), report templates, and new recognition methods. Test the compatibility of current systems with the new requirements.
- Develop Policies and Internal Controls: Leverage the new autonomy to review and redesign voucher and ledger systems to best fit the company's operating model. In parallel, internal control policies must be built or reinforced to manage this new flexibility.
- Plan Balance Transition: Create a detailed plan for the conversion of closing balances as of 2025 (under Circular 200) to the opening balances for 2026 (under Circular 99), ensuring the continuity and accuracy of accounting information.
Circular 99 is a major reform, presenting both opportunities and challenges. Businesses that proactively prepare will gain a significant advantage in optimizing operations and enhancing transparency.
To begin your research, you can download the full text of Circular 99/2025/TT-BTC at the link below: