Which businesses are covered by Circular 200? Check now.

Circular 200/2014/TT-BTC is not merely a legal document but also a guiding principle shaping a modern accounting system in Vietnam. Completely replacing Decision 15/2006/QD-BTC, this Circular introduces a new accounting mindset: prioritizing economic substance over legal form, helping businesses move closer to international accounting standards (IFRS).

Context of Circular 200/2014/TT-BTC

Circular No. 200/2014/TT-BTC, issued by the Ministry of Finance on December 22, 2014, provides guidance on accounting for businesses. The promulgation of Circular 200 marks a major turning point in simplifying accounting administrative procedures and granting greater autonomy to businesses in designing their documentation and accounting systems.

"This circular provides guidance on accounting record keeping, preparation and presentation of financial statements, and does not apply to determining the tax obligations of enterprises to the State budget."

This confirms the clear separation between Financial Accounting (serving the purpose of providing information to investors and managers) and Tax Accounting.

Which businesses are covered by Circular 200?

According to legal regulations, not all organizations apply the same accounting system.

Businesses subject to this regulation

According to Article 2, the subjects to which this applies include:

• Businesses of all economic sectors (joint-stock companies, limited liability companies, partnerships, private enterprises).
• Small and medium-sized enterprises (SMEs) that voluntarily choose to apply Circular 200 (instead of Circular 133) must notify the tax authorities.
• Subsidiary units and branches of the enterprise.

Subjects not covered by this regulation

Besides the aforementioned businesses, Circular 200 also clearly stipulates that economic entities with unique characteristics will not be subject to the regulations of this document, specifically:

• Micro-enterprises: Apply accounting regulations according to Circular 132/2018/TT-BTC to suit their streamlined scale.
• Cooperatives and cooperative unions: Follow separate accounting guidelines (e.g., Circular 24/2017/TT-BTC).
• Specialized financial institutions: Including commercial banks, credit institutions, and branches of foreign banks (applying accounting and reporting systems as prescribed by the State Bank of Vietnam).

Key contents of Circular 200

Aimed at increasing transparency in corporate financial health, Circular 200 focuses on core pillars, from fundamental principles to specific accounting methods. Below are the most important points that every accountant needs to master:

The principle of substance over form.

This is the most important principle. Accounting must accurately reflect the economic nature of the transaction.

For example: A transaction that is in the form of a lease but is essentially an installment purchase must be accounted for as an asset of the business.

Account system

Circular 200 provides a list of 99 level 1 accounts. A new feature is that businesses are now entitled to:

• Create your own level 2 and level 3 accounts for internal administration purposes.
• Proactively opening accounting books without needing to register the form with the Ministry of Finance (according to Article 9).

Account 412 – Revaluation Differences of Assets

Account 412 plays a crucial role when a business experiences fluctuations in asset value due to objective factors or government requirements. According to Article 68, this is stipulated as follows:

"Businesses are only allowed to revalue assets and record them in account 412 when there is a decision from a competent state agency or when carrying out equitization, merger, or division of the enterprise."

Basic accounting principles:

• Increase in value: Debit Account 211 (Fixed Assets) / Credit Account 412.
• Decrease in value: Debit Account 412 / Credit Account 211.
• End-of-period processing: The balance of account 412 is processed according to the decision of the competent authority (usually transferred to charter capital after the procedures are completed).

Reference: Balance Sheet, Circular 200.

Comparison between Circular 200/2014/TT-BTC and Circular 133/2016/TT-BTC

Confusion between these two circulars is common. Below are the core differences.

Comparison table between Circular 200 and Circular 133.

Criteria	Circular 200	Circular 133
Business size	Large, listed companies.	Small and medium-sized enterprises.
Account system	Complete and detailed (99 accounts).	It's simpler, just 63 accounts.
Quarterly report	Mandatory for listed companies.	Not mandatory, just encouraged.
Currency	Strict regulations regarding the actual exchange rate.	Allow for greater flexibility in the book exchange rate.
Financial reports	Requires detailed and highly transparent explanations.	The form is simplified and easy to use.

While Circular 133 aimed to reduce the administrative burden on small businesses, focusing on practicality and ease of operation, Circular 200 served as a stricter system of standards. Circular 200 aimed for data transparency.

Benefits of operating according to Circular 200

Properly and fully applying the regulations of Circular 200 is not simply about complying with the law, but also brings strategic value that helps businesses optimize their financial management system:

• Financial transparency: Helps financial reporting become a common language for working with international financial institutions, banks, and investors.
• Optimized management: A detailed accounting system helps managers closely monitor cash flow, expenses, and profits for each business segment.
• Tax Settlement Support: Although separate from tax accounting, a solid accounting system in accordance with Circular 200 is the most important foundation for explaining and protecting data before the tax authorities.

In the roadmap for modernizing the national financial management system, 2026 marks a significant turning point when Circular 99/2025/TT-BTC officially comes into effect (completely replaces) Circular 200/2014/TT-BTCFor anyone working in accounting, mastering accounting journal entries is not only a basic professional requirement but also a core element in ensuring transparency, legal compliance, and optimizing a company's financial data. 

See details: Accounting entry table according to Circular 99.

Conclude

Through this article, we hope you have gained a clearer understanding of the subjects and scope of application of Circular 200/2014/TT-BTC. Although the new regulations may initially pose difficulties for businesses, in the long run, the application of Circular 200 will bring many practical benefits to the financial management and operation of enterprises.

To effectively implement Circular 200, businesses need thorough preparation in all aspects, from accounting personnel, accounting systems and documents to workflow processes and supporting software. Businesses should coordinate closely with relevant authorities and consultants to implement it scientifically yet flexibly based on their specific circumstances.

Contact MAN – Master Accountant Network For advice and support!

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Content is moderated by: Mr. Le Hoang Tuyen – Founder & CEO of Man, CPA Vietnam Auditor with over 30 years of experience in Accounting, Auditing and Financial Consulting.

Frequently Asked Questions regarding the application of Circular 200

Should newly established businesses choose Circular 200 or Circular 133?

If your business is large, plans to list on the stock exchange, or works extensively with foreign investors, Circular 200 is the better choice. If it's a small or medium-sized enterprise looking to simplify its accounting records to focus on core business operations, Circular 133 is a more optimal option.

Is it possible to change from Circular 200 to Circular 133 in the middle of a fiscal year?

No. Changes to accounting methods must be implemented at the beginning of the fiscal year, and the business must notify the direct tax authority in writing.

What are the penalties for businesses that violate regulations on documentation, accounting records, and reporting as stipulated in Circular 200?

The penalties are stipulated in Decree 41/2018/ND-CP. Depending on the severity of the violation, the fine can range from VND 5,000,000 to VND 50,000,000 (for organizations). Common violations such as: failure to prepare complete financial statements, incorrect application of accounting regulations, or falsification of documents and records will be severely punished.