Official Document 5526/TNI-NVDTPC Issued on June 11, 2026, this document aims to promote compliance with accounting and tax laws and prevent the practice of maintaining two or more financial accounting systems to conceal revenue and evade taxes. The document was issued to implement Notice 394/TB-CT dated May 29, 2026, from the Tax Department, with the goal of ensuring legal safety and sustainable development in the production and business activities of taxpayers.
For the accounting community, businesses, and household businesses, this is essential information to proactively prevent risks. The article below summarizes the key points of Official Letter 5526/TNI-NVDTPC in detail.
Full text of Official Letter 5526/TNI-NVDTPC
Official document 5526/TNI-NVDTPC focuses on guiding taxpayers on accounting and tax regulations and preventative measures. The content is presented in clear, organized groups of issues, from legal basis and risk identification to legal consequences and recommendations for implementation.
Legal regulations regarding accounting and taxation that need attention.
First, the Official Letter reiterates the act of tax evasion under Clause 4, Article 45 of the 2025 Tax Administration Law, which includes the act of failing to record in accounting books the revenue related to determining the amount of tax payable. This is an important legal basis for determining the responsibility of taxpayers.
The official document specifically emphasizes the requirements and principles of accounting record keeping. Regarding requirements, accounting records must fully, truthfully, promptly, and clearly reflect all economic and financial transactions that occur within a unified financial accounting system. Regarding recording principles, businesses record transactions as they occur, entering them into the books promptly and consistently according to the time of occurrence within the accounting period, regardless of whether money is received or disbursed.
Notably, Official Letter 5526/TNI-NVDTPC cites the core regulations of Accounting Law 2015Accordingly, all economic and financial transactions must be documented and recorded fully, promptly, accurately, truthfully, and in accordance with the nature of the transaction in the accounting books and financial statements. More importantly, each accounting unit shall use only one accounting system for one accounting year; the practice of maintaining two or more financial accounting systems or providing and publishing financial statements with inconsistent data within the same accounting period is strictly prohibited.
Businesses should update this further. New features of the 2025 Tax Administration Law To fully understand the changes related to tax declaration and payment obligations.
Cases that are not considered violations
One point needs clarification to avoid misunderstanding: not every instance of using multiple data systems in parallel is considered a violation. According to the Official Letter, businesses and organizations are not considered to be in violation if they use financial accounting and management accounting systems, internal reports, analytical reports, budgets, reports for the parent company, reports based on international standards, ERP, POS or BI systems, or other management modules.
The condition is that this data must be verifiable, explainable, and not used to conceal transactions, revenue, assets, liabilities, or tax obligations. Thus, the line between legality and violation lies in the purpose of use and the verifiability and transparency of the data.
Identifying risky behaviors that require prevention, according to Official Letter 5526/TNI-NVDTPC
To assist taxpayers in proactively reviewing their tax records, Circular 5526/TNI-NVDTPC lists behaviors and risk indicators that need to be prevented. Accountants and business owners should regularly compare the following indicators:
- Discrepancies between revenue, invoices, and cash flow.
- There is inconsistency in data between accounting records and tax returns.
- Revenue generated is not fully reflected in legitimate invoices and supporting documents.
- There is no guarantee of consistency between revenue recorded in the internal management software and revenue invoiced for tax declaration.
- Use multiple sales software programs simultaneously.
- Using illegal invoices to account for expenses and other prohibited practices.
Early identification of these signs helps businesses make timely adjustments, preventing errors from accumulating and becoming serious violations.
Legal consequences of violation
The official document clarifies the legal consequences of maintaining two or more financial accounting systems. If a taxpayer maintains two or more financial accounting systems to conceal revenue, evade taxes, or commit accounting, invoice, or document fraud, depending on the nature and severity of the violation, the taxpayer may be subject to the following penalties:
- Penalties for administrative violations related to taxes and accounting.
- Collect outstanding taxes and late payment penalties.
- Criminal liability will be pursued for serious violations as prescribed by law.
This is the central deterrent message that Official Letter 5526/TNI-NVDTPC aims to convey to the taxpayer community.
Benefits of complying with accounting and tax regulations
Besides issuing warnings, the document also analyzes the practical benefits of compliance. Maintaining complete, honest, and consistent accounting records and filing taxes correctly helps taxpayers minimize legal risks and the costs of handling violations; enhances credibility and financial transparency; increases access to capital and cooperation with major partners; and promotes sustainable long-term development.
The Tay Ninh Provincial Tax Department recommends that businesses review and standardize their accounting systems.
First, review and standardize the accounting system to ensure that all transactions are recorded fully and accurately. Next, use accounting software for its intended purpose. Using functions such as data creation, backup, recovery, and analysis is a legitimate business need, but these must not be exploited to create or maintain inconsistent accounting data systems to conceal tax obligations.
Taxpayers also need to ensure consistency, comparability, and accountability between accounting data, invoices, documents, and payment data in accordance with legal regulations; maintain and manage complete documentation for inspection and verification purposes when necessary; and limit the use of cash in purchase and sale transactions. They should proactively review and correct errors before tax authorities conduct inspections and build a culture of compliance within the business.
Responsibilities of service providers and tax agents
Official document 5526/TNI-NVDTPC also sets requirements for organizations providing electronic transaction services in the tax field, organizations providing electronic invoice services, and units providing accounting software.
Service providers and tax agents must ensure that their products comply with accounting standards and current legal regulations, and must not design, promote, instruct, configure, or assist users in creating or maintaining financial accounting systems with inconsistent data to conceal revenue, expenses, assets, liabilities, or tax obligations.
For tax agents and accounting and auditing service organizations, the Official Letter requires strict adherence to the principles of independence, objectivity, and honesty, prohibiting any actions that advise or assist taxpayers in creating two or more financial accounting systems to evade taxes. These organizations should advise businesses on accurately and completely recording economic transactions, synchronizing accounting data, invoices, and cash flow, and providing early warnings of potential violations.
In that context, trusting the supplier is crucial. tax accounting services Reputable firms with expertise in legal regulations, such as MAN – Master Accountant Network, will help businesses standardize their accounting records from the outset and minimize legal risks.
Regulations related to accounting records according to Circular 99/2025/TT-BTC
Besides preventing the practice of maintaining two sets of accounting records as per Official Letter 5526/TNI-NVDTPC, taxpayers also need to understand the fundamental regulations regarding accounting records. The two most important issues are the timing of opening the records and the essential contents that must be included, specifically as follows:
When should accounting books be opened?
According to Article 13 of Circular 99/2025/TT-BTC, accounting books must be opened at the beginning of the accounting year. For newly established businesses, accounting books must be opened from the date of establishment. Specifically:
- Regarding bookkeeping, businesses must base their accounting records on accounting documents in accordance with the Accounting Law and its amendments, supplements, or replacements. Accounting records must be kept promptly, clearly, and completely according to their contents; the information and data recorded in the accounting records must be accurate, truthful, and consistent with the accounting documents.
- Regarding closing the books, businesses must close their accounting books at the end of the accounting period to prepare financial statements and in other cases as prescribed by law.
What are the essential contents of an accounting ledger?
According to Clause 3, Article 24 of the 2015 Accounting Law, accounting records must contain the following main contents:
- The date, month, and year of entry, the number, and the date of the accounting document used as the basis for the entry.
- Summarize the content of the economic and financial transaction that occurred.
- The monetary value of economic and financial transactions is recorded in accounting accounts, including the beginning balance, transactions during the period, and the ending balance.
What steps should businesses take to comply with Official Letter 5526/TNI-NVDTPC?
To mitigate risks and ensure compliance with accounting regulations, businesses should implement the following solutions:
- Review the entire accounting system: Businesses need to check the accounting system currently in use, the process of recording revenue and expenses, ensure complete documentation is stored, and maintain consistency between invoices and financial reports.
- Data synchronization between departments: The Sales, Warehouse, Accounting, and Finance departments need coordinated processes to ensure that data is fully updated and consistent.
- Data access and editing control: Businesses should assign user permissions to software users, control editing history, store complete accounting data, and have a process for approving data changes.
This helps to minimize errors and increase accountability when necessary.
The role of accounting services in risk prevention, as outlined in Official Letter 5526/TNI-NVDTPC.
For many small and medium-sized businesses, maintaining a professional accounting system can be challenging due to limitations in personnel and expertise.
Use full accounting service This can help businesses:
- Control the accounting system and records.
- Standardize the document recording process.
- Ensure that financial reports accurately reflect business operations.
- Minimize errors in the tax filing process.
Specialized accounting units assist businesses in reviewing data, identifying discrepancies, and providing guidance on how to address them in accordance with regulations.
Conclude
Official document 5526/TNI-NVDTPC is an important document that helps businesses better understand the requirements for transparency in accounting and financial management. Maintaining two sets of accounting and financial records to conceal revenue or falsify information can create numerous risks related to taxes, accounting, and business operations.
Businesses need to proactively build a clear accounting system, tightly control data, and ensure that all financial reports accurately reflect actual events. This is not only a requirement for legal compliance but also a foundation for effective business management and sustainable development.
For businesses that do not have a dedicated accounting department, the following is necessary. hire accounting services This solution helps ensure accurate, consistent accounting records and proper declarations. Compliance from the outset not only helps avoid penalties but also contributes to building a transparent and sustainable financial foundation for the business.
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Responsible for production and professional content review by: Mr. Le Hoang Tuyen – Founder & CEO of MAN – Master Accountant NetworkHe is a CPA Vietnam auditor with over 30 years of in-depth experience in accounting, auditing, taxation, and corporate legal consulting.
Frequently Asked Questions about Official Letter 5526/TNI-NVDTPC
No. According to Official Letter 5526/TNI-NVDTPC, businesses using a financial accounting system along with management accounting, internal reports, analytical reports, budgets, reports serving the parent company, reports according to international standards, or ERP systems are not considered in violation, provided that this data can be verified and explained.
Taxpayers need to be aware of signs such as: Discrepancies between revenue, invoices, and cash flow; Inconsistent data between accounting records and tax returns; Revenue not fully reflected in legitimate invoices; Inconsistencies between revenue in internal management software and revenue declared on tax returns; Using multiple sales software programs simultaneously; Using illegal invoices to account for expenses.
According to the official document, household businesses and individual business owners shall implement accounting regulations in accordance with Circular 152/2025/TT-BTC. Cooperatives and cooperative unions shall implement regulations in accordance with Circular 71/2024/TT-BTC. Enterprises, however, shall apply Circular 99/2025/TT-BTC, Circular 133/2016/TT-BTC, or Circular 58/2026/TT-BTC, depending on the entity. Is it illegal for a business to use both an ERP financial accounting system and a management accounting system simultaneously?
What risk indicators should taxpayers proactively review?
Which accounting regulations govern the practices of household businesses and cooperatives?
