The requirements for opening an accounting services company have completely changed since July 1, 2026, when the Government officially removed this profession from the List of Conditional Investment and Business Sectors. Many old documents and articles still list the conditions according to the 2015 Accounting Law, which is no longer applicable today. This article provides an accurate update on the latest legal basis, what businesses must still meet, and the risks to be aware of before establishing an accounting services company.
Why is the question of requirements for opening an accounting services company causing controversy in 2026?
If you search for the requirements to open an accounting services company online right now, you'll likely encounter two conflicting sets of information:
- One side insists that there must be at least two practicing accountants contributing capital, the legal representative must be a practicing accountant, and they must obtain a Certificate of Eligibility to conduct accounting services;
- The other side claims that all those conditions have been abolished. Both were once true, differing only in the timeframe.
Prior to July 1, 2026, accounting services were a conditional business sector, detailed in Articles 58 to 65 of the Accounting Law No. 88/2015/QH13. However, from July 1, 2026, the Government issued two consecutive resolutions implementing drastic reforms to the accounting sector. Resolution 66.17/2026/NQ-CP and Resolution 66.18/2026/NQ-CPThis renders the entire old framework of conditions temporarily ineffective. This is why the requirements for opening an accounting services company have become an unusually high-searched keyword in 2026: professionals need to know exactly what they still need to do, and newcomers wanting to start a business need to know how much shorter the path has become.
Three groups of people need to thoroughly understand this content:
- Accountant,
- The auditor is considering starting his own business.
- Existing accounting service businesses need to know whether their old business registration certificate is still valid; and clients hiring accounting services need to understand the legal context to choose a suitable partner.
Legal basis for determining the conditions for opening an accounting service company today
To accurately answer the question of the requirements for opening an accounting services company, three documents need to be considered side-by-side in the correct chronological order of their issuance.
Accounting Law 2015: Traditional Framework of Conditions
For many years, this was the only basis. The Accounting Law No. 88/2015/QH13 stipulated that a limited liability company with two or more members wishing to conduct accounting services must have at least two contributing members who are practicing accountants, the legal representative, director, or general director must be a practicing accountant, and must be granted a Certificate of Eligibility to Conduct Accounting Services.
Partnerships and sole proprietorships have similar requirements regarding the number of practicing accountants.
Individuals wishing to practice the profession must possess an accountant certificate or auditor certificate, register their practice, and participate in annual professional development.
This legal framework remains intact in the written law, but its implementation has been suspended, and this is the key point that causes many people to be confused.
Resolution 66.17/2026/NQ-CP: Removing accounting services from the list of conditional business sectors.
On May 15, 2026, the Government issued Resolution 66.17/2026/NQ-CP on reducing and amending conditional investment and business sectors, effective from July 1, 2026. According to this Resolution, the number of conditional investment and business sectors decreased from 198 to 142, and "accounting services" officially disappeared from the list of conditional investment and business sectors stipulated in the Investment Law.
From a legal standpoint, this is the most significant turning point: When a business is no longer a conditional business activity, the business is no longer obligated to meet and prove the prerequisites before operating.
Resolution 66.18/2026/NQ-CP and Official Letter 773/QLKT-DN: List of official regulations temporarily suspended from application.
Simultaneously, Resolution 66.18/2026/NQ-CP dated May 18, 2026, on decentralization, reduction, and simplification of administrative procedures and business conditions, specifically lists in Section B, Appendix I.7 (accounting field) the regulations that are no longer implemented. On May 22, 2026, the Department of Accounting and Auditing Management and Supervision (Ministry of Finance) issued Official Letter 773/QLKT-DN providing detailed guidance and clearly confirming:
Failure to comply with regulations on the conditions for granting, application documents, time limits for granting, re-granting, and fees for granting and re-granting Certificates of Eligibility for Accounting Services Business as stipulated in Articles 60, 61, 62, 63, and 64 of the 2015 Accounting Law; failure to implement the granting, revocation, and management of Certificates of Registration for Accounting Services Practice as stipulated in Article 58; failure to implement regulations on accounting service business households as stipulated in Article 65; and failure to stipulate annual knowledge updates for practicing accountants.
Both Resolutions are effective from July 1, 2026 to February 28, 2027. This is a transitional period, awaiting the official promulgation of the amended Accounting Law and the Independent Auditing Law.
So what are the remaining requirements for opening an accounting services company today?
From July 1, 2026 to February 28, 2027, the requirements for opening an accounting service company in Vietnam will almost revert to the level of a regular business sector. This means that businesses only need to register under the Enterprise Law, no longer having to meet specialized industry requirements as before, and will be subject to post-audit supervision instead of pre-audit supervision..
No longer required: Certificate of eligibility to conduct accounting services.
Previously, this was a mandatory "sub-license," incurring costs and waiting times. Currently, the procedures for issuing and renewing this certificate under Articles 60-64 of the 2015 Accounting Law are no longer implemented. Businesses can provide accounting services immediately after completing business registration, without needing to wait for additional specialized licensing steps.
There is no longer a requirement for practicing accountants to contribute capital or act as legal representatives.
According to Resolution 66.18/2026/NQ-CP, the regulations on accounting service businesses in Clauses 1, 2, 3 and points a, b of Clause 4, Article 59 of the 2015 Accounting Law, which require a minimum of two contributing members to be practicing accountants, and that the legal representative, director, or general director must also be a practicing accountant, are no longer in effect. The regulation on the capital contribution ratio of organizational members in Article 26 of Decree 174/2016/ND-CP is also among those temporarily suspended.
A certified public accountant (CPI) certificate is no longer required as a prerequisite.
This change has the most far-reaching impact on individuals in the profession. The regulations regarding accountant certificates in Article 57 of the 2015 Accounting Law (amended and supplemented by Law No. 108/2025/QH15) and the registration for practicing accounting services in Article 58 are no longer in effect. This means individuals are no longer required to possess an accountant certificate or register their practice to provide accounting services through a company. This direction was also agreed upon by the Standing Committee of the National Assembly's Economic and Financial Committee when commenting on the draft amendments to the Accounting Law and the Independent Auditing Law, which did not stipulate an accountant certificate as a condition for providing accounting services, aiming to simplify business conditions.
The fundamental requirements must still be met according to the Enterprise Law.
The conditions for opening an accounting services company do not mean there are no conditions at all. Businesses must still fully comply with the general conditions of the Enterprise Law, choose a suitable business type (limited liability company, joint-stock company, partnership, private enterprise), have a valid registered business line, have a registered office, declared charter capital that meets the general requirements for civil capacity.
Furthermore, the regulations regarding individuals prohibited from practicing accounting under Article 52 of the 2015 Accounting Law—including minors, individuals prohibited from practicing accounting by court judgments, and immediate relatives of the head of the accounting unit within the same unit—remain in effect because these are regulations concerning professional ethics and conflicts of interest, and are not included in the list of those to be repealed.
If businesses are still unsure about how to determine the appropriate type and capital structure in the context of transitional regulations, they can refer to our services. accounting consulting services to be reviewed on a case-by-case basis.
The process of opening an accounting services company during the post-audit phase.
Below is a 5-step process for establishing an accounting services company during the post-audit phase:
- Step 1 – Choose the type of business: With the removal of restrictions on the capital contribution ratio of practicing accountants, businesses can choose more flexible forms than before: single-member limited liability companies, multi-member limited liability companies, joint-stock companies, partnerships, or private enterprises, depending on their capital raising and management strategies.
- Step 2 – Prepare the business registration documents: The application process follows the standard procedures of the Enterprise Law: Application for business registration, company charter, list of founding members or shareholders, personal legal documents of the legal representative and contributing members.
- Step 3 – Registering the business line for accounting services: Declare the correct business code for accounting and auditing services when registering your business at the Department of Planning and Investment (or the corresponding business registration authority under the current two-tiered government model).
- Step 4 – Build internal professional capacity, even if it's no longer required on paper: This is the most easily overlooked step when legal requirements are relaxed. The removal of accounting certification or professional registration requirements does not mean that service quality is no longer subject to scrutiny; post-inspection mechanisms mean that risk shifts from "before operation" to "during and after operation." Businesses should proactively maintain a team of genuinely qualified professionals to avoid professional liability risks during future audits and inspections.
- Step 5 – Operation and self-assessment of post-inspection: SAfter receiving the Business Registration Certificate, the company can immediately provide accounting services. State management agencies will shift from periodic pre-audit inspections of accounting services to post-audits and inspections when signs of violations are detected or according to specialized inspection plans.
What happens if a company already has a Certificate of Eligibility to conduct accounting services before July 1, 2026?
This is a practical question for many operating businesses. According to the guidelines below... Official Document 773/QLKT-DNCertificates of eligibility to conduct accounting services and certificates of registration for practicing accounting services issued by the Ministry of Finance before July 1, 2026, that have not yet expired or reached their expiration date, shall continue to be applied and used in accordance with the law until their expiration date.
In other words, businesses are not required to return valid certificates, but they also don't need to worry if their certificates are about to expire between July 1, 2026 and February 28, 2027, because the renewal procedure under the old process has been temporarily suspended.
Legal risks to be aware of during the transition period to February 28, 2027
The requirements for opening an accounting services company during this period are easy, but they come with risks that businesses need to carefully consider before deciding when to establish one:
- First, this is a transitional phase, not a permanent state: Resolutions 66.17/2026/NQ-CP and 66.18/2026/NQ-CP are effective until February 28, 2027, pending the official approval of the amended Accounting Law and the Independent Auditing Law by the National Assembly. Although the current discussion trend leans towards maintaining the abolition of business conditions and not requiring accountant certificates as a condition for providing services, This is still a draft; the final content may be adjusted before issuance.
- Secondly, post-audit mechanisms do not mean lax management: The abolition of pre-audit requirements shifts the pressure for compliance to the operational phase. Businesses lacking genuine expertise, when serious errors in their clients' accounting records are discovered during post-audits, will still face corresponding, or even more severe, legal and reputational consequences.
- Thirdly, information gaps make it easy for incompetent entities to emerge in the market: As barriers to entry in the industry have significantly decreased, clients hiring accounting services need to more carefully assess the actual capabilities of their partners, rather than relying solely on licenses as before.
Conclude
The conditions for opening an accounting services company in 2026 have undergone a major transformation, shifting from a conditional business sector with numerous requirements regarding certifications, capital contribution ratios, and sub-licenses, to a mechanism of almost free market entry, supervised through post-audit.
From July 1, 2026 to February 28, 2027, businesses will no longer be required to meet the specialized conditions in Articles 58-65 of the 2015 Accounting Law to open an accounting service company. This is a transitional period awaiting the official amendment of the Law, not a permanent state, and the reduction of pre-audit requirements does not diminish legal liability when providing services; that liability simply shifts from before to after.
If your business is considering the right time and model to establish an accounting services company, or needs to reassess its operational capabilities before stricter post-audit policies become in place, the experts at MAN – Master Accountant Network are ready to work with you to review the most suitable option in compliance with current regulations.
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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 the requirements for opening an accounting services company.
Is a certified accountant still required to open an accounting services company?
No. According to Resolution 66.18/2026/NQ-CP and Official Letter 773/QLKT-DN, the regulations on accountant certificates in Article 57 of the 2015 Accounting Law and registration for accounting services in Article 58 are no longer in effect, from July 1, 2026 to February 28, 2027.
Is it still necessary to apply for a Certificate of Eligibility to conduct accounting services?
No. The regulations regarding the conditions for issuance, required documents, time limits for issuance and re-issuance of this Certificate in Articles 60-64 of the 2015 Accounting Law have been temporarily suspended from July 1, 2026.
Do accounting service companies that were granted a Certificate before July 1, 2026 need to reapply?
No. Certificates of eligibility to conduct accounting services and Certificates of professional registration issued before July 1, 2026, that have not yet expired will continue to be used until their expiration date.
How does the post-audit mechanism in the accounting services sector work?
Instead of checking conditions before granting licenses as before, state management agencies will inspect and audit businesses during and after their operation, and handle violations related to service quality or accounting compliance according to regulations.
What types of businesses are currently permitted to provide accounting services?
Since the regulations on the capital contribution ratio of practicing accountants under Article 59 of the 2015 Accounting Law have been removed, businesses can flexibly choose from various forms under the Enterprise Law: limited liability companies, joint-stock companies, partnerships, and sole proprietorships.
