CIRCULAR

ON AMENDMENTS TO CIRCULARS OF THE MINISTER OF FINANCE IN THE FIELD OF ACCOUNTING AND AUDITING TO PROMOTE DECENTRALIZATION, DELEGATION OF POWERS AND THE REORGANIZATION OF THE TWO-TIER LOCAL GOVERNMENT

Pursuant to the Law on Organization of the Government dated February 18, 2025;

Pursuant to the Law on Organization of Local Government dated June 16, 2025;

Pursuant to the Law on Accounting dated November 20, 2015;

Pursuant to the Law on Independent Audit dated March 29, 2011;

Pursuant to the Law on amendments the Law on Securities, the Law on Accounting, the Law on Independent Audit, the Law on State Budget, the Law on Management and Use of Public Property, the Law on Tax Administration, the Law on Personal Income Tax, the Law on National Reserve, and the Law on Handling of Administrative Violations dated November 29, 2024;

Pursuant to Resolution No. 190/2025/QH15 dated February 19, 2025 of the National Assembly on settlement of certain issues regarding the restructuring of the state organizational apparatus;

Pursuant to Decree No. 29/2025/ND-CP dated February 24, 2025 of the Government defining the functions, tasks, powers and organizational structure of the Ministry of Finance;

At the request of the Director General of the Department of Accounting and Auditing Regulations and Supervision;

The Minister of Finance hereby promulgates a Circular on amendments to Circulars of the Minister of Finance in the field of accounting and auditing to promote decentralization, delegation of powers and the reorganization of the two-tier local government.

Article 1. Amendments to certain Articles of Circular No. 99/2018/TT-BTC dated November 1, 2018 of the Minister of Finance on guidelines for preparation of consolidated financial statements of state accounting units as superior accounting units

1. Point a, b, and c of Clause 1 Article 5 shall be amended as follows:

“a) Level-1 estimating units that are subject to the preparation and submission of consolidated financial statements to financial authorities and state treasuries as prescribed, including: Ministries, central-level sectors and equivalent organizations; Departments, agencies, and equivalent units at the province level.

b) At the end of each annual accounting period, Level-1 estimating units shall receive, prepare, and submit the reports, including:

– Receiving financial statements, consolidated financial statements, and supplementary financial information reports from subordinate accounting units; and be held accountable for verification of the reports received from subordinate accounting units.

– Preparing consolidated financial statements and supplementary financial information reports in accordance with this Circular. Reconciling data indicators in prepared reports to ensure accuracy and consistency.

In case a Level-1 estimating unit has no subordinate accounting units and has already prepared separate financial statements in accordance with the administrative and non-business accounting regime, it shall still prepare supplementary financial information reports as prescribed in this Circular.

– Submitting reports to the state treasury to serve the preparation of state financial statements.

Reports shall also be concurrently submitted to the competent financial authority at the same level for reconciliation and verification of final accounts as prescribed.

c) Level-1 estimating units shall decide on assignment of tasks to lower-level intermediate accounting units in preparing consolidated financial statements, specifically as follows:

– Central-level Level-1 estimating units may decide to organize one or multiple levels of intermediate accounting units to prepare consolidated financial statements. Local Level-1 estimating units may only organize a maximum of one level of intermediate accounting units to prepare consolidated financial statements.

– Assignment of tasks to lower-level intermediate accounting units to prepare consolidated financial statements shall be in conformity with the organizational model, management requirements of the unit, and applicable regulations. An intermediate accounting unit shall also concurrently be a superior estimating unit in case it is assigned the state budget estimate by the Level-1 estimating unit and is responsible for allocating the budget to subordinate units.”.

2. Amendments to clause 2 Article 19:

“2. In case a Level-1 estimating unit has no subordinate accounting units and has prepared financial statements in accordance with the administrative and non-business accounting regime, the supplementary financial information report shall be prepared and submitted to serve the elimination of internal transactions and provide explanations for the state financial statements when the State Treasury prepares the state financial statements.”

3. The phrase “đồng cấp” (of the same level) shall be annulled at Point d Clause 1 Article 5, Point a Clause 1 Article 6, Clause 2 Article 6, and Point c Clause 2 Article 13.

4. Appendix No. 04 “Xác định đơn vị kế toán trung gian lập báo cáo tài chính tổng hợp” (Identification of intermediate accounting units preparing consolidated financial statements) shall be annulled.

Article 2. Amendments to certain Articles of Circular No. 24/2024/TT-BTC dated April 17, 2024 of the Minister of Finance on guidelines for the administrative and non-business accounting regime

1. Amendments to point a Clause 1 of Article 2 as follows:

“a) State agencies;”.

2. Amendments to point b Clause 6 of Article 9 as follows:

“b) Recipients of annual financial statements:

– Superior accounting unit.

– Financial authority and State Treasury (according to decentralization) for accounting units having no superior accounting unit.

– Tax authority in case the unit engages in production, business, or service activities and is required to pay tax in accordance with tax laws.”.

3. Amendment to Point c, Clause 1, Article 12 as follows:

“c) Financial authorities and State Treasury shall perform and coordinate with the unit in reconciling, adjusting, providing, and data mining in relation to the receipt and use of funding, management and use of assets, and other financial activities of the accounting unit in accordance with assigned functions and tasks.”.

Article 3. Amendments to certain Articles of Circular No. 133/2016/TT-BTC dated August 26, 2016 of the Minister of Finance on guidelines for the accounting regime applicable to small- and medium-sized enterprises

1. The title of Article 10 shall be amended as follows:

“Article 10. Amendments to the accounting regime”.

2. Article 10 is amended as follows:

“1. With respect to accounting documents and accounting books:

Enterprises shall apply the system of accounting documents and accounting books prescribed in Appendix 3 and Appendix 4 enclosed with this Circular (not mandatory). To suit the characteristics of business operations and management requirements, enterprises may design or amend and supplement forms of accounting documents and accounting books compared to the forms guided in Appendix 3 and Appendix 4 enclosed with this Circular. When amended or supplemented, forms of accounting documents and accounting books of the enterprise must comply with Article 16 and Clauses 1, 2, 3, and 4 of Article 24 of the Law on Accounting, and must ensure complete, prompt, truthful, and transparent reflection to enable inspection, control, and reconciliation of the enterprise’s assets and capital sources.”

2. With respect to the system of accounting accounts

Enterprises shall apply the system of accounting accounts set forth in Appendix 1 enclosed with this Circular to record accounting books of economic transactions arising in the enterprise. In order to suit the characteristics of production and business activities and management requirements, enterprises may amend and supplement the names, codes, structures, and contents reflected in the accounting accounts guided in Appendix 1 enclosed with this Circular. Such amendments and supplements must ensure classification and systematization of arising transactions by economic content, avoid duplication of objects, comply with accounting principles prescribed by law, and must not change or affect the indicators and information presented in the financial statements.

3. With respect to financial statements

Enterprises shall apply the system of financial statements prescribed in Appendix 2 enclosed with this Circular to prepare and present the enterprise’s financial statements. In order to suit the characteristics of production and business activities and management requirements, enterprises may supplement additional indicators in the financial statements guided in Appendix 2 enclosed with this Circular. Such supplementation must comply with Clauses 1 and 2 Article 29 of the Law on Accounting and adhere to the principles of preparation and presentation of financial statements as guided in this Circular. Enterprises shall provide explanations in the financial statements for any contents supplemented compared to the forms of financial statements guided in Appendix 2 enclosed with this Circular.

4. In case an enterprise makes amendments or supplements to the forms of accounting documents, accounting books, accounting accounts or supplements additional indicators in the financial statements as prescribed in Clauses 1, 2, and 3 of this Article, the enterprise must promulgate an Accounting Regulation on the amended or supplemented contents as the basis for implementation. The Regulation must specify the necessity of such amendments and supplements and the enterprise’s accountability to the law for the amended and supplemented contents.

Where the enterprise does not make any amendments or supplements to the forms of accounting documents, accounting books, accounting accounts, or does not supplement additional indicators in the financial statements as prescribed in Clauses 1, 2, and 3 of this Article, it shall apply the system of accounting documents, accounting books, accounting accounts, and financial statements guided in Appendices 1, 2, 3, and 4 enclosed with this Circular.

5. In case an enterprise has specific characteristics which make it impossible to supplement or require amendments to the indicators of the financial statements guided in Appendix 2 enclosed with this Circular, it shall report to the Ministry of Finance for guidance on preparation and presentation of financial statements.”

Article 4. Amendments to certain Articles of Circulars of the Minister of Finance on guidelines for annual knowledge update for practicing accountants and individuals registered to practice accounting services (including Circular No. 292/2016/TT-BTC dated November 15, 2016, Circular No. 44/2019/TT-BTC dated July 19, 2019, Circular No. 39/2020/TT-BTC dated May 15, 2020, and Circular No. 23/2024/TT-BTC dated April 12, 2024)

1. Amendments to the title of Article and amendments to Article 7 of Circular No. 292/2016/TT-BTC (as amended and supplemented under Points a and b Clause 2 Article 1 of Circular No. 23/2024/TT-BTC) shall be as follows:

a) The title of Article 7 shall be amended as follows:

“Article 7. Conditions for providing knowledge update programs.”

b) Point a Clause 1 Article 7 of Circular No. 292/2016/TT-BTC shall be amended as follows:

“a) An annual knowledge update plan and program appropriate to the knowledge update contents prescribed in Clause 1 Article 4 of this Circular. The annual knowledge update program must ensure timeliness and include new policies that have a direct and significant impact on the work of accountants.”

c) Point a Clause 2.3 Article 7 of Circular No. 292/2016/TT-BTC shall be amended as follows:

“a) Having at least 10 professional staff members (including accountants and employees directly providing accounting services) at the time of notification;”.

d) Clause 3 Article 7 of Circular No. 292/2016/TT-BTC (as amended and supplemented under Points a and b Clause 2 Article 1 of Circular No. 23/2024/TT-BTC) shall be amended as follows:

“3. Where an entity wishes to offer knowledge update programs for accountants, it must send a written notification to the Department of Accounting and Auditing Regulations and Supervision under the Ministry of Finance at least 10 days prior to the commencement date of the knowledge update program, using the form provided in Appendix I enclosed with this Circular, and this notification shall only be required for the first time.

During the period of offering the knowledge update program, the entities must always maintain the conditions for offering the knowledge update program prescribed in Clauses 1 and 2 of this Article and shall be held accountable for the accuracy and truthfulness of compliance with such conditions.

Within 10 days from the date of no longer meeting the conditions or no longer having the need to offer the knowledge update program, the entities must send a written notification to the Department of Accounting and Auditing Regulations and Supervision under the Ministry of Finance, specifying the reasons and the time of ceasing to meet the conditions or the need to offer the knowledge update program. Based on the notifications of the entities, before September 1 annually, the Department of Accounting and Auditing Regulations and Supervision under the Ministry of Finance shall publish on the Ministry of Finance’s electronic portal the list of entities eligible to offer the knowledge update programs for accountants.”

2. Point c Clause 5 Article 11 of Circular No. 292/2016/TT-BTC (as amended and supplemented under Point a Clause 2 Article 1 of Circular No. 23/2024/TT-BTC) shall be amended as follows:

“c) International professional organizations in accounting and auditing shall be the entities primarily responsible for offering knowledge update courses, including cases of coordination with other professional organizations or training institutions eligible to organize knowledge update for accountants.”

3. Amendments to the title of Article and amendments to Article 15 of Circular No. 292/2016/TT-BTC (as amended and supplemented under Clause 4 Article 1 of Circular No. 44/2019/TT-BTC) shall be as follows:

a) The title of Article 15 shall be amended as follows:

“Article 15. Responsibilities of professional associations, training institutions, and accounting service enterprises offering knowledge update courses for accountants.”

b) Point c Clause 5 Article 15 of Circular No. 292/2016/TT-BTC (as amended and supplemented under Clause 4 Article 1 of Circular No. 44/2019/TT-BTC) shall be amended as follows:

“c) Reporting entities: Professional associations, training institutions, or accounting service enterprises offering knowledge update courses.”.

c) Clause 9 Article 15 of Circular No. 292/2016/TT-BTC shall be amended as follows:

“9. Fully, promptly, and accurately provide and explain information and documents upon request of competent state authorities during the organization of knowledge update for accountants.”

d) Clause 10 shall be added after Clause 9 Article 15 of Circular No. 292/2016/TT-BTC as follows:

“10. Before August 15 annually, publicly disclose on their websites the following information:

a) Conditions to be met for offering knowledge update courses for accountants as prescribed in Article 7 of this Circular;

b) Annual knowledge update plans and programs;

c) Knowledge update regulations applicable to professional associations and accounting service enterprises.”

4. Clause 1 Article 18 of Circular No. 292/2016/TT-BTC shall be amended as follows:

“1. Offering knowledge update courses for accountants to count hours for knowledge update as prescribed in Article 11 of this Circular without meeting the conditions specified in Article 7 of this Circular or without notifying the Department of Accounting and Auditing Regulations and Supervision under the Ministry of Finance regarding the organization of knowledge update for accountants.”.

5. Appendix No. 01/CNKT enclosed with Circular No. 292/2016/TT-BTC shall be replaced with Appendix I enclosed with this Circular.

6. Articles 9, 10, and 12; Point a Clause 1 Article 14; Clause 1 Article 17; Appendix No. 02/CNKT; and Appendix No. 05/CNKT of Circular No. 292/2016/TT-BTC shall be annulled.

Article 5. Amendments to certain Articles of Circulars of the Minister of Finance on guidelines for annual knowledge update for auditors registered for audit practice (including Circular No. 150/2012/TT-BTC dated September 12, 2012; Circular No. 56/2015/TT-BTC dated April 23, 2015; Circular No. 39/2020/TT-BTC dated May 15, 2020; and Circular No. 15/2024/TT-BTC dated March 6, 2024)

1. Clauses 2, 3, and 4 of Article 2 of Circular No. 150/2012/TT-BTC (as amended and supplemented under Clause 1 Article 1 of Circular No. 15/2024/TT-BTC) shall be amended as follows:

“2. Professional associations in accounting and auditing (hereinafter referred to as professional associations) shall offer knowledge update courses for auditors.

3. Training institutions shall offer knowledge update courses for auditors.

4. Audit firms shall offer knowledge update courses for their auditors.”.

2. Clause 2 Article 5 of Circular No. 150/2012/TT-BTC (as amended and supplemented under Clause 2 Article 1 of Circular No. 56/2015/TT-BTC) shall be amended as follows:

“2. Auditors who have not practiced auditing for a continuous period of 24 months or more up to the time of registration must have accumulated at least 80 hours of knowledge update within the 02 years immediately preceding the year of registration for audit practice, including at least 40 hours of knowledge update on accounting and auditing laws of Vietnam and 08 hours of knowledge update on professional ethics.”.

3. Clause 1 Article 6 of Circular No. 150/2012/TT-BTC (as amended and supplemented under Clause 1 Article 1 of Circular No. 15/2024/TT-BTC) shall be amended as follows:

“1. Auditors shall participate in courses organized by professional associations, training institutions, or audit firms, specifically as follows:

a) Courses offered by professional associations for all auditors;

b) Courses offered by training institutions for all auditors;

c) Courses offered by audit firms for their own auditors.”.

4. Amendments to the title of Article and amendments to Article 7 of Circular No. 150/2012/TT-BTC (as amended and supplemented under Clause 1 Article 1 of Circular No. 15/2024/TT-BTC) shall be as follows:

a) The title of Article 7 shall be amended as follows:

“Article 7. Conditions for providing knowledge update programs.”

b) Article 7 of Circular No. 150/2012/TT-BTC (as amended and supplemented under Clause 1 Article 1 of Circular No. 15/2024/TT-BTC) shall be amended as follows:

“1. Professional associations, training institutions, and audit firms must satisfy the following general conditions for offering knowledge update courses:

a) Having an annual knowledge update plan and program compliant with Clause 1 Article 4 of this Circular and notifying the Department of Accounting and Auditing Regulations and Supervision under the Ministry of Finance. The annual knowledge update program must ensure timeliness and include new policies directly and significantly affecting auditors’ work;

b) Having a teaching staff as prescribed in Article 8 of this Circular;

c) Having sufficient facilities to ensure training quality, including classrooms, desks, boards, teaching aids, and other training equipment (owned or rented);

d) Fully covering the contents specified in Clause 1 Article 4 of this Circular.

dd) Not having violated regulations on offering knowledge update courses for auditors as concluded by the Department of Accounting and Auditing Regulations and Supervision under the Ministry of Finance within the 03 years immediately preceding the date of notification submission to the Department of Accounting and Auditing Regulations and Supervision under the Ministry of Finance regarding satisfaction of conditions for offering knowledge update courses for auditors.”

2. Specific conditions applicable to each type of organization:

2.1. For professional associations:

In addition to the conditions specified in Clause 1 of this Article, professional associations shall also meet the following conditions:

a) Having regulations on knowledge update for auditors or general training regulations that include specific provisions on knowledge update for auditors approved by the Executive Committee (or the General Assembly);

b) Having a dedicated department in charge of offering knowledge update courses for auditors as stipulated in the Charter or established by a separate decision approved by the Executive Committee (or the General Assembly);

c) Knowledge update for auditors shall be included in the annual work program approved by the Executive Committee (or the General Assembly).

2.2. For training institutions:

In addition to the conditions specified in Clause 1 of this Article, training institutions shall also meet the following conditions:

a) Being established and operating under a decision of a competent state authority;

b) Having training disciplines at university level or higher on the contents prescribed in Point a Clause 1 Article 4 of this Circular.

2.3. For audit firms self-offering knowledge update courses:

In addition to the conditions specified in Clause 1 of this Article, audit firms shall also meet the following conditions:

a) Having at least 20 practicing auditors at the time of notification;

b) Having a dedicated training department for knowledge update within the organizational structure of the firm;

c) Having training and knowledge update regulations for auditors at each level within the firm;

d) Having allocated budget for knowledge update for auditors of the firm;

dd) Being a network firm as defined in the Code of Ethics for Professional Accountants and Auditors.

3. Notification to the Department of Accounting and Auditing Regulations and Supervision under the Ministry of Finance regarding organization of knowledge update for auditors:

a) From July 1 to July 15 annually, entities intending to offer knowledge update programs for auditors shall send a written notification to the Department of Accounting and Auditing Regulations and Supervision under the Ministry of Finance, clearly describing the conditions for offering knowledge update courses for auditors as prescribed in Clauses 1 and 2 of this Article and committing to compliance with the conditions in this Circular (using the form in Appendix II);

b) During the period of offering knowledge update courses, entities must always maintain the conditions specified in Clauses 1 and 2 of this Article. Within 10 days from the date on which they no longer satisfy the conditions or no longer have the need to offer knowledge update programs, entities shall send a written notification to the Department of Accounting and Auditing Regulations and Supervision under the Ministry of Finance, stating the reasons and the time when the conditions are no longer satisfied or when they cease to offer knowledge update programs.”.

5. Point c Clause 6 Article 11 of Circular No. 150/2012/TT-BTC (as amended and supplemented under Clause 1 Article 1 of Circular No. 15/2024/TT-BTC) shall be amended as follows:

“c. International professional organizations in accounting and auditing shall be the entities primarily responsible for offering knowledge update courses, including cases of coordination with other professional organizations or training institutions eligible to offer knowledge update programs for auditors.”.

6. Amendments to the title of Article and amendments to certain Clauses of Article 15 of Circular No. 150/2012/TT-BTC (as amended and supplemented under Clause 1 Article 1 of Circular No. 15/2024/TT-BTC) shall be as follows:

a) The title of Article 15 shall be amended as follows:

“Article 15. Responsibilities of professional associations, training institutions, and audit firms offering knowledge update courses for auditors.”.

b) Clauses 1, 7, and 11 of Article 15 of Circular No. 150/2012/TT-BTC (as amended and supplemented under Clause 1 Article 1 of Circular No. 15/2024/TT-BTC) shall be amended as follows:

“1. Offer knowledge update courses for auditors in accordance with the plans and programs notified to the Department of Accounting and Auditing Regulations and Supervision under the Ministry of Finance as prescribed in Clause 3 Article 7 of this Circular. In case of offering additional courses outside the plan or changing the content or programs of notified courses, a supplementary written notification must be submitted.

7. Fully monitor and record the attendance of all learners. Evaluate auditors’ participation in the course immediately after the course ends.

11. Fully, promptly, and accurately provide and explain information and documents upon request of competent state authorities during the offering of knowledge update courses for auditors”.

c) Clause 12 shall be added after Clause 11 of Article 15 as follows:

“12. Before August 15 annually, entities intending to offer knowledge update courses for auditors shall publish and be responsible for the disclosed information on their websites, including:

a) Conditions ensured for offering knowledge update courses for auditors as prescribed in Article 7 of this Circular;

b) Annual knowledge update plans and programs;

c) Knowledge update regulations for auditors applicable to professional associations and audit firms.”

7. Clause 2 Article 17 of Circular No. 150/2012/TT-BTC (as amended and supplemented under Clause 1 Article 1 of Circular No. 15/2024/TT-BTC) shall be amended as follows:

“2. Annually, no later than August 16, publish on the Ministry of Finance’s electronic portal the names of professional associations, training institutions, and audit firms offering knowledge update courses for auditors.”

8. Clause 1 Article 18 of Circular No. 150/2012/TT-BTC (as amended and supplemented under Clause 1 Article 1 of Circular No. 15/2024/TT-BTC) shall be amended as follows:

“1. Offering knowledge update courses for practicing auditors to count hours for knowledge update as prescribed in Article 11 of this Circular without satisfying the conditions specified in Article 7 of this Circular or having satisfied the conditions but failing to notify the Department of Accounting and Auditing Regulations and Supervision under the Ministry of Finance.”

9. Appendix No. 01/CNKT enclosed with Circular No. 150/2012/TT-BTC shall be replaced with Appendix II enclosed with this Circular.

10. Articles 9, 10, and 12; Points a and b Clause 1 Article 14; Clause 3 Article 15; Clause 1 Article 17; Appendix No. 02/CNKT; and Appendix No. 03/CNKT of Circular No. 150/2012/TT-BTC shall be annulled.

11. Appendix No. 07/CNKT of Circular No. 56/2015/TT-BTC shall be annulled.

Article 6. Annulment of the entire Circular

The entire Circular No. 70/2019/TT-BTC dated October 3, 2019 of the Minister of Finance on guidelines for commune-level budget and financial accounting regime shall be annulled.

Article 7. Entry into force

1. This Circular comes into force as of July 1, 2025.

2. In the course of implementation, in case the legislative documents referred to in this Circular are amended, supplemented, or replaced by new legislative documents, the new documents shall apply accordingly.

3. Difficulties that arise during the implementation of this Circular should be reported to the Ministry of Finance for guidance./.