Submitting the Explanatory Notes to the Financial Statements is a mandatory procedure accompanying the corporate income tax return that accountants need to complete by the deadline in 2026. Understanding the electronic submission process of the tax authority not only saves businesses time but also ensures transparency in presenting accounting policies, especially when changes in accounting currency occur. Circular 99/2025/TT-BTC.
In practice, many businesses choose to use specialized solutions such as professional tax accounting services To ensure that the settlement documents and appendices, including the Notes to the Financial Statements, are prepared and submitted in accordance with the regulations of the tax authorities.
Overview of submitting Notes to the Financial Statements
The explanatory notes to the financial statements play a crucial role in explaining and supplementing the information presented in a company's financial reporting system. More than just a supporting document, they provide a basis for regulatory authorities to better understand accounting policies, financial fluctuations, and events occurring during the period.
To ensure the accuracy of records before submission, many businesses now proactively review data through... Financial reporting services To minimize errors in the process of preparing and submitting reports.
Legal nature
The explanatory notes are a component of the financial reporting system, functioning to provide detailed explanations of the items presented in the Balance Sheet and Income Statement.
Role for the tax authorities
Through this document, the tax authorities can assess the accounting methods applied by the business, events occurring after the end of the fiscal year, as well as any related potential financial obligations or commitments.
Eligibility and submission deadline
All operating businesses must submit the Explanatory Notes to Financial Statements along with the corporate income tax (CIT) settlement documents within 90 days from the end of the fiscal year, usually before March 31st of each year.
The connection with the tax return system.
The explanatory notes to the financial statements are an appendix to the tax return form 03/TNDN. Upon completion and submission of the explanatory notes to the financial statements, the tax authority's system will recognize the tax return as complete, facilitating data verification and inspection.
How to submit the Explanatory Notes to the Financial Statements via the Public Service portal (detailed instructions)
To submit the Explanatory Notes to the Financial Statements through the tax authority's electronic system, accountants need to prepare in advance the following conditions: a valid digital signature, the financial statement data file, and a completed tax return.
Below is a detailed procedure to help accountants perform this task quickly and minimize system errors.
Step 1: Log in to the General Department of Taxation's Public Services system.
The first step to submitting the Explanatory Notes to the Financial Statements is to access the Tax Department's public service portal at the following address: https://dichvucong.gdt.gov.vn
This is a centralized administrative procedure processing system that the General Department of Taxation will widely implement from 2025 and continue to apply in 2026.
Taxpayers use their business tax identification number and password to log into the system. After successful access, they need to check that the digital signature device (USB Token) is connected to the computer and that the electronic signature software is ready to use.
Step 2: Prepare and submit the corporate income tax return.
After logging in, the accountant accesses the "Submit Tax Return" function and selects form 03/TNDN issued under Circular 80/2021/TT-BTC to finalize corporate income tax.
The implementation process includes two common methods:
- Online declaration: Taxpayers directly enter financial information on the form displayed on the system.
- Upload XML file: Accountants export data from accounting software or HTKK software and upload it to the system.
After completing the data, the taxpayer clicks "Sign Document," enters the Token PIN to confirm the declaration. This is an important preparatory step before submitting the Explanatory Notes to the Financial Statements in the attached Appendix.
Step 3: Attach the Financial Statement Notes and complete the process.
After signing and submitting form 03/TNDN, the system will display an interface allowing you to upload additional documents.
To complete the submission of the Notes to the Financial Statements, taxpayers should follow these steps:
- Access the Attach Documents section.
- Find the Notes to the Financial Statements section.
- Click Select file and upload file from computer
The file formats accepted by the system typically include:
- PDF: This is the recommended format because it helps minimize display errors and ensures data integrity.
- Excel: Some businesses use this format when they want to present detailed tables for easy inspection by tax authorities.
After uploading the file, the accountant needs to electronically sign the appendix one more time. If this signing step is skipped, the submission of the Financial Statement Notes will be marked as incomplete by the system.
How to submit the Explanatory Notes to the Financial Statements via HTKK and the Electronic Tax System.
In addition to submitting the Explanatory Statement of Financial Statements through the HTKK software in conjunction with the eTax electronic tax system, many businesses still choose to submit the Statement through the Public Service Portal.
In the latest version of the HTKK software, accountants need to select the correct option:
- Fiscal year
- Accounting system applied
After completing the report, select the "Export XML" function to create a standard data file.
Procedure for submitting appendices on the system thuedientu.gdt.gov.vn as follows:
- Log in to the eTax system using your business administrator account.
- Select the Tax Filing option.
- Access the Declaration Lookup feature.
- Find the submitted corporate income tax return.
- In the "Submit Appendix" column, upload the explanatory file and electronically sign it.
After the digital signature step is completed, the system will acknowledge that the Financial Statement Explanatory Notes have been successfully submitted.
Note: The average exchange rate is determined by averaging the buying and selling transfer rates of the commercial bank where the business regularly conducts transactions. The method for determining the exchange rate should be clearly stated in the financial statement notes.
Instructions for submitting the Explanatory Notes to the Financial Statements for the Report on Conversion to Vietnamese Dong
For FDI enterprises or entities using foreign currency as their accounting currency, the submission of the Notes to the Financial Statements must include an explanation of the conversion of the Financial Statements to Vietnamese Dong.
According to Circular 99/2025/TT-BTC, businesses must comply with the principle of exchange rate conversion to ensure the consistency of financial data.
The exchange rate difference arising from the conversion will be recorded under the "Exchange Rate Differences in Equity" item. At the same time, the enterprise must clearly state in the Notes to the Financial Statements the impact of this conversion on its financial position and business performance.
Mistakes to avoid when submitting the Notes to the Financial Statements
To ensure that the submission is accepted by the tax authorities on the first attempt, accountants need to carefully check for the following common errors in submitting the Notes to the Financial Statements:
- Incorrect attachment format: The system often rejects compressed files or files with inappropriate formats such as .zip or .rar.
- Forgetting to digitally sign the appendix: This is the most common mistake that causes the submission of the Financial Statement Notes to be considered incomplete, even though the main tax return has been successfully submitted.
- Discrepancies: The total assets, profit, or equity figures in the Notes to the Financial Statements must match the figures in the Balance Sheet and Income Statement.
- Late submission of appendices: Even if the tax return is submitted on time, if the explanatory notes are submitted late, the business may still be subject to administrative penalties. Decree 125/2020/ND-CP.
Conclude
Properly submitting the Notes to the Financial Statements not only helps businesses comply with accounting and tax regulations but is also a crucial step in reviewing the entire financial data system before finalizing the tax settlement documents.
With the new regulations of Circular 99/2025/TT-BTC coming into effect, clearly presenting accounting policies, currency units, and exchange rate conversion methods will help make a company's financial statements more transparent and reliable to regulatory authorities.
Contact information MAN – Master Accountant Network
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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 Regarding the Submission of the Financial Statement Notes for March 2026
Is submitting the Notes to the Financial Statements mandatory?
Yes. According to regulations on corporate accounting, the Notes to the Financial Statements are an integral part of the annual financial statements. Therefore, when settling corporate income tax, businesses are required to submit this document. Failure to submit the Notes to the Financial Statements along with the tax settlement dossier may result in the dossier being considered incomplete, and the business risks administrative penalties according to tax procedures.
Is a separate digital signature required for the Notes to the Financial Statements?
Yes. When submitting the Explanatory Notes to the Financial Statements, businesses must digitally sign the appendix file after uploading it to the system. Many accountants only digitally sign the 03/TNDN declaration form and forget to sign the Explanatory Notes Appendix. In this case, the system will still recognize the declaration as submitted, but the appendix will be considered invalid.
What is the deadline for submitting the Notes to the Financial Statements?
The deadline for submitting the Notes to the Financial Statements is the same as the deadline for submitting the annual financial statements and corporate income tax return. According to current regulations, businesses must complete the submission of the Notes to the Financial Statements within 90 days of the end of the fiscal year, usually around March 31st.
Do small businesses applying Circular 133 have to submit Notes to Financial Statements?
Yes. Businesses applying the accounting regime under Circular 133 are still required to prepare and submit the Notes to the Financial Statements. The content of the notes may be presented more simply than for businesses applying Circular 200, but when submitting the Notes to the Financial Statements, businesses must still include this document with their annual financial statements.
