In the roadmap for modernizing the national economy and increasing financial transparency, 2026 marks a significant milestone for the Vietnamese business community. From January 1st, 2026, the corporate accounting system will officially transform with the implementation of... Circular 99/2025/TT-BTCThis completely replaces Circular 200/2014/TT-BTC, which had been in effect for over a decade. For business owners, mastering the accounting system for private enterprises is not only a legal obligation but also key to optimizing governance and controlling tax risks.
This article will provide the most comprehensive, in-depth, and accurate look at the changes in the accounting regime for private enterprises applicable to the 2026 fiscal year.
What is the accounting system for private enterprises?
The accounting system for private enterprises is a set of regulations, principles, and methods that private enterprises must apply to:
- Note
- Handle
- Check
- Providing financial information
The accounting system for private enterprises serves internal management and tax obligations.
Legal framework applicable to the accounting regime for private enterprises.
The accounting legal system in Vietnam is constantly evolving to align with international accounting standards (IFRS). In 2026, the accounting regime for private enterprises will be governed by the following legal documents:
Accounting Law No. 88/2015/QH13
This is the highest-ranking legal document, stipulating the fundamental principles regarding the content of accounting work, the organization of the accounting system, and accounting personnel. All activities related to the collection, processing, verification, analysis, and provision of financial information by private enterprises must comply with this Law.
Circular 99/2025/TT-BTC: A revolution in the accounting system.
This is the most important document that every accountant and business owner needs to pay attention to. Circular 99 was issued to standardize accounting methods, prioritizing substance over form. For large private enterprises or those requiring high financial transparency to raise capital or obtain bank loans, applying Circular 99 is the optimal choice.
Circular 133/2016/TT-BTC is for SMEs.
For small and medium-sized private enterprises, Circular 133 remains in effect as a simplified accounting solution. However, private enterprises have the option to apply Circular 99 to standardize data, but must notify the tax authorities and maintain consistency for at least one fiscal year.
For private businesses with a stable workforce, the hire accounting services Professionalism is the solution that helps ensure accuracy and timeliness.
Key new and groundbreaking points of Circular 99/2025/TT-BTC, effective from 2026.
Entering 2026, the accounting regime for private enterprises under Circular 99 brings about many pivotal changes:
Maximum autonomy in designing documents and accounting records.
Previously, businesses had to strictly adhere to mandatory document forms. From 2026, the Ministry of Finance will allow private businesses to design their own accounting systems and records to suit their specific business characteristics, provided they ensure compliance with the seven mandatory elements of the Accounting Law (document name, date, subject, economic content, quantity, unit price, and signature).
Accounting chart of accounts approaching IFRS
Circular 99 supplements and amends many accounts to more accurately reflect the market value of assets.
- Account 215 – Biological Assets: Meets the accounting needs of private enterprises operating in the high-tech agricultural sector.
- Account 229 – Provision for asset impairment: Provides more detailed regulations on the revaluation of assets at the end of the period, helping financial statements accurately reflect the "health" of the business.
Changes to the terminology and structure of financial statements.
One of the most noticeable changes in the 2026 private enterprise accounting regulations is the renaming of the "Balance Sheet" to "Statement of Financial Position." This change is not just about the name but also emphasizes the ability to provide information about the economic resources and liquidity of the entity at a given point in time.
Mandatory accounting system for private businesses.
Regardless of which circular is applied, the accounting system for private enterprises requires a robust data storage system to facilitate inspections and tax settlements.
Accounting documents: The root of the data.
In the digital age of 2026, electronic documents will play an extremely important role. Private businesses need to take note:
- Electronic documents must have a valid digital signature.
- The archive must ensure integrity and must not be modified after publication.
- Expenses exceeding 20 million VND (including VAT) must be supported by non-cash payment documents to be considered deductible expenses.
General and detailed accounting system
Private businesses must maintain accounting records to document all economic transactions. Common types of accounting books include:
- General Journal: Records all transactions in chronological order.
- General Ledger: Systematizes transactions according to each accounting account.
- Detailed ledger: Tracks each entity in detail (customers, suppliers, warehouses, fixed assets).
Note: By 2026, manual bookkeeping will be almost completely replaced by AI-integrated accounting software. However, at the end of the fiscal year, businesses will still have to print, bind, sign, and stamp the general ledger and journal for archiving as required by regulations.
For private businesses that want to streamline their operations while ensuring full compliance, using full accounting service Reputable and experienced units like MAN – Master Accountant Network will help businesses smoothly handle all tasks, from documentation to reporting.
Procedures for preparing and submitting financial statements.
Financial statements are the final product of the accounting system for private enterprises. They serve as the basis for the State to manage taxes and for business owners to assess business performance.
Financial report categories
According to the new regulations, a complete set of financial statements for a private enterprise includes:
- Financial Statement (Form B01-DN): Reflects assets, liabilities, and equity.
- Business Performance Report (Form B02-DN): Reflects revenue, expenses, and net profit.
- Cash Flow Statement (Form B03-DN): Shows the inflow and outflow of cash during the period.
- Explanatory Notes to Financial Statements (Form B09-DN): Detailed explanation of the figures in the above reports.
Deadline and location for submitting reports
For private businesses, the deadline for submitting annual financial statements is no later than the 90th day after the end of the calendar year or fiscal year.
- Recipients: Directly managing Tax Authority, Statistics Authority, and Business Registration Authority.
- Method: Submit via the General Department of Taxation's electronic portal (Etax system).
Tax considerations related to the accounting system for private enterprises.
Accounting and taxation are two sides of the same coin. Incorrect implementation of accounting practices in private enterprises can lead to serious errors in corporate income tax returns.
Distinguish between accounting profit and taxable income.
Accountants record expenses based on the nature of the transaction, but the Tax Authority only accepts expenses that are reasonable, valid, and legal. Businesses need to pay particular attention to the expenses that are not deductible in 2026:
- Non-cash payment threshold: Entering 2026, regulations regarding cash payment limits will undergo significant changes. Purchase invoices valued at 5 million VND or more will be required to be paid via bank transfer to be eligible for VAT deduction and included as deductible expenses when settling corporate income tax. Private businesses, which typically use cash, should pay particular attention to this change to avoid having expenses disallowed en masse.
- Salary expenses: Lack of employment contracts, insufficient documentation for social insurance contributions as per new regulations, or payment of salaries exceeding the prescribed amount in cash (depending on specific guidelines for each period).
- Depreciation expense: Using fixed assets not for production or business activities, or exceeding the depreciation period stipulated in Circular 45/2013/TT-BTC (as amended and supplemented).
To effectively manage these risks, the role of the head of the accounting department is extremely important. Businesses can consider the following options: hire chief accountant Experienced in overseeing and taking ultimate responsibility for the accuracy of tax data.
Manage electronic invoices from the cash register.
From 2026, most private retail and food service businesses will be required to implement electronic invoices generated from cash registers connected to the tax authorities. Revenue accounting must accurately match this invoice data to avoid the risk of tax assessment.
Comparison of Circular 200 and Circular 99/2025/ND-CP
To help readers quickly grasp the changes in accounting regulations for private enterprises, here is a summary comparison table:
| Comparative characteristics | Circular 200/2024/TT-BTC (old) | Circular 99/2025/TT-BTC |
| Document flexibility | The form is rigid and has limited revision options. | Complete autonomy in designing according to specific requirements. |
| Name of the balance sheet | Balance sheet | Financial statement |
| Cash payment limit | The 20 million threshold | Payments of 5 million VND or more must be made via bank transfer. |
| Biological Assets Account | Not clear | Specialized Account 215 |
| Accounting priority | Value both form and substance. | Absolute priority is given to the economic aspect. |
The comparison table above shows a clear shift from the compliance-oriented, formalistic accounting model of Circular 200/2014/TT-BTC to a modern, flexible accounting model that accurately reflects the economic nature of the situation, as stipulated in Circular 99/2025/TT-BTC. These changes not only help private enterprises improve financial transparency but also create a solid foundation for governance, tax risk control, and expanded access to capital in this new phase of development.
See details: Balance sheet according to Circular 99.
Benefits of applying the accounting regime according to Circular 99/2025/TT-BTC
The shift to Circular 99 is not only about complying with new regulations but also brings many strategic advantages to private enterprises from 2026 onwards.
Accurately reflecting the financial health of a business.
Circular 99 applies the principle of substance over form, helping to:
- Accurately recognize the economic value of the transaction.
- Limit the practice of "beautifying accounting records" for illustrative purposes only.
This makes the financial statements more reliable for:
- Business owner
- Bank
- Investors
Increase access to capital and attract investment.
An accounting system that closely follows international standards (IFRS) helps to:
- Transparent financial data
- Easier to get loan approval from the bank.
- Gain an advantage when raising capital or forming partnerships.
This is especially important for businesses that are expanding.
Flexibility in internal management
Businesses are entitled to:
- Design your own documents
- Customize the accounting system.
Help:
- Suitable for the specific industry
- Optimizing operational processes
- Reduce administrative costs.
Proactively manage tax risks.
Circular 99 helps businesses:
- Standardizing accounting and tax data.
- Minimize discrepancies between accounting and final accounts.
Minimize:
- Expenses excluded
- Subject to back taxes
- Inspection risk.
Supporting digital transformation in accounting.
The new mode encourages:
- Using electronic documents
- Integrating accounting software and AI.
Benefit:
- Automated recording
- Reduce manual errors.
- Speed up report generation.
Enhancing corporate governance capabilities
Accounting data according to Circular 99 helps:
- Real-time business performance analysis
- Make faster and more accurate decisions.
Implementing Circular 99/2025/TT-BTC is not just a change in accounting techniques, but a shift from compliance accounting to management accounting and value creation.
Private businesses that adopt this early will have a distinct advantage in terms of financial transparency and risk control.
Conclusion and recommendations
It is clear that the application of the private enterprise accounting regime under Circular 99/2025/TT-BTC is not simply a change in regulations, but a significant shift in how businesses manage their finances. From making documentation more flexible and closer to international standards to tightening requirements for cash flow transparency, all aim at a common goal: improving the quality of financial information and minimizing tax risks.
In this context, private businesses that proactively update and standardize their accounting and financial processes and adapt to new regulations will have a clear advantage in operations, cost control, and access to capital. Conversely, slow adaptation can lead to data discrepancies, disallowed expenses, or unnecessary legal risks.
This is the right time for businesses to:
- Review the entire current accounting system.
- Standardize payment processes, especially cashless payments.
- Upgrade the software and train the accounting team.
If a private business does not yet have an accounting system, consulting with professional accounting and tax firms will be a safe and budget-friendly solution. For any questions regarding new policies and regulations, please feel free to contact us. Contact MAN – Master Accountant Network For in-depth support and advice.
Contact information MAN – Master Accountant Network
- Address: No. 19A, Street 43, Tan Thuan Ward, Ho Chi Minh City
- Mobile/Zalo: 0903 963 163 – 0903 428 622
- Email: man@man.net.vn
Content production by: Mr. Le Hoang Tuyen – Founder & CEO MAN – Master Accountant Network, Vietnamese CPA Auditor with over 30 years of experience in Accounting, Auditing and Financial Consulting.
Frequently Asked Questions about the Accounting System for Private Enterprises
From January 1, 2026, businesses can choose to apply either Circular 99/2025/TT-BTC or Circular 133/2016/TT-BTC, depending on their size. However, Circular 99 is recommended for businesses that want financial transparency, access to capital, and long-term development. The choice must be notified to the tax authorities and applied consistently throughout the fiscal year.
The regulation reduces the cash payment threshold to 5 million VND to control cash flow, limit tax evasion, and increase transaction transparency. Businesses must use cashless payment methods to have their expenses considered reasonable and eligible for VAT deductions, avoiding the risk of expenses being disallowed during tax settlement.
Cash payments exceeding 5 million VND are not subject to direct penalties, but will be disallowed as deductible expenses for corporate income tax purposes and will not be eligible for VAT deduction. This increases the actual tax liability and can significantly impact the company's profits.
Small private enterprises can still apply Circular 133/2016/TT-BTC to simplify accounting. However, if they plan to expand, borrow capital, or standardize governance, switching to Circular 99/2025/TT-BTC will bring long-term benefits and increase financial transparency. Are private enterprises required to comply with Circular 99/2025/TT-BTC?
Why was the cash payment threshold lowered to 5 million VND?
Will there be a penalty for paying a bill over 5 million VND in cash?
Should small private businesses switch to Circular 99?
