Circular No. 99/2025/TT-BTC (“Circular 99”) officially took effect for financial years beginning on or after 1 January 2026, superseding Circular No. 200/2014/TT-BTC and establishing a modernized accounting framework for enterprises in Vietnam.
More than halfway through the 2026 financial year, the focus for business leaders has shifted beyond understanding “What is new under Circular 99?” The critical question now driving boardroom and finance discussions is:
“How must we adjust our accounting systems, internal control frameworks, and reporting workflows to ensure full compliance and seamless preparation for the 2026 financial statements?”
This practical challenge was the focal point of KTC’s in-depth executive training session on Circular 99 held on 15 August 2026, where CFOs, Chief Accountants, and senior finance leaders discussed the tangible impacts of transitioning to the new regime.
FROM NEW RULES TO PRACTICAL EXECUTION CHALLENGES
Circular 99 is far more than a technical update to account codes or presentation templates. It reflects a decisive alignment with International Financial Reporting Standards (IFRS), prioritizing economic substance over legal form and granting enterprises greater autonomy while demanding higher accountability.
1. Chart of Accounts & Opening Balance Transition Transitioning to Circular 99 requires more than a mechanical re-coding exercise. Existing balances carried forward from the previous regime must be mapped and classified with rigor:
- Capital contributions to non-jointly controlled Business Cooperation Contracts (BCCs) must be reclassified from Account 138 to Account 2281.
- Dividend and profit distribution obligations are now isolated into Account 332.
- Balances from specialized funds and project funds (Accounts 441, 466) are transferred directly into Other Capital (Account 4118).
Finance teams must maintain clear, audit-ready reconciliation trails supporting all opening balance adjustments and transition methods (retrospective, modified retrospective, or prospective) to prevent reporting inconsistencies.
2. Substance Over Form in Complex Transactions Circular 99 mandates that financial reporting faithfully captures the underlying economics of commercial contracts:
- Business Cooperation Contracts (BCCs): Entities must dissect contractual terms to determine joint control versus non-joint control and assess how economic returns are structured.
- Revenue Recognition: For deferred or installment sales, revenue is recognized strictly at the upfront cash equivalent price, while the financing component is amortized into financial income over time. Promotional goods tied to conditional purchases must be treated as transaction price discounts rather than selling expenses.
- Cost Recognition: Circular 99 disallows estimated cost of sales accruals for real estate completions without physical acceptance (eliminating previous Dr 632 / Cr 335 entries) and limits the accrual of major fixed asset repairs.
- Distributable Profits: Management must evaluate non-cash unrealized gains (e.g., FX revaluations, asset revaluations for capital contributions) to safeguard actual liquidity before approving dividend payouts.
3. Internal Governance & Statutory Accounting Policies While Circular 99 grants businesses the flexibility to customize chart of accounts, document templates, and branch accounting structures, this autonomy comes with statutory compliance obligations:
- Enterprises modifying standard account codes or financial statement line items must formally establish and approve a statutory Accounting Policy / Manual.
- Internal governance rules must clearly delineate authorization limits, approval hierarchies, and transaction verification controls.
Without an approved internal accounting policy, customized bookkeeping practices may face scrutiny from statutory auditors and tax authorities during compliance reviews.
4. Proactive Preparation for Enhanced Disclosures The disclosure framework under Circular 99 sets a substantially higher bar for transparency:
- The 10% Materiality Threshold: Mandatory disaggregated disclosures for material balance sheet items, borrowings, revenues, and BCC arrangements exceeding 10% of their respective categories.
- Restricted Assets: Detailed notes regarding restricted cash, pledged collateral, and encumbered assets.
- Judgments & Going Concern: Comprehensive disclosure of key accounting estimates, risk exposures, and events after the reporting period.
Leaving data extraction for these extensive notes until the year-end close risks severe reporting bottlenecks and audit delays.
FOUR IMMEDIATE ACTIONS FOR BUSINESSES
- 01 – Finalize Account Mapping & Opening Balances: Ensure every reclassified balance between Circular 200 and Circular 99 is documented with a clear audit trail.
- 02 – Review Material Contracts: Re-evaluate BCC agreements, bundled customer loyalty programs, extended warranties, and multi-component commercial contracts against new recognition criteria.
- 03 – Approve Internal Policies & Update ERP Systems: Formalize the company’s internal Accounting Manual, configure new chart of accounts (Accounts 332, 215, 2295, 6275, 82111…), and verify foreign exchange revaluation rules on accounting software.
- 04 – Prepare Data for Financial Statement Disclosures: Capture and organize the information required for disclosure — including items exceeding the 10% threshold, pledged or restricted-use assets, and significant accounting estimates — as part of the company’s quarterly internal reporting process.
KTC PERSPECTIVE: AUTONOMY DEMANDS TRANSPARENCY
From an audit and advisory standpoint, the true success of transitioning to Circular 99 is not measured by how many account codes have been updated on an ERP ledger.
The defining metric is whether the revised accounting architecture reflects true economic substance, equips executive management with reliable business intelligence, and withstands rigorous stakeholder scrutiny.
Circular 99 provides a progressive framework that bridges Vietnamese accounting with international practices. A seamless transition requires that People, Internal Controls, Data Infrastructure, and Financial Reporting operate under a cohesive, synchronized governance model.
For forward-looking enterprises, the window to ensure full compliance and reporting readiness is not at year-end – it is now.
KTC – Supporting Businesses Through the Transition to Circular 99
The implementation of Circular No. 99/2025/TT-BTC requires businesses to go beyond updating their accounting framework. It calls for a comprehensive review of the chart of accounts, opening balances, accounting policies, internal controls and financial reporting data to ensure a smooth transition from Circular 200 to Circular 99.
With expertise across audit, accounting, tax and financial advisory, KTC supports businesses in implementing the new accounting regime through:
- Circular 200–99 opening balance and account reconciliation;
- Development and update of accounting regulations and policies;
- Review of accounting policies and internal control systems;
- Chart of accounts and accounting system / ERP configuration support;
- Preparation and review of financial statements and Notes to the Financial Statements under Circular 99.
Businesses transitioning from Circular 200 to Circular 99 should begin reviewing their accounting systems and reporting processes now — helping reduce compliance risks, ease year-end pressure and ensure that financial data is ready for the 2026 financial statements.
