Circular 200/2014/TT-BTC Is it still valid? This is a question many accountants and businesses are concerned about as we approach 2026. The timing... Circular 99/2025/TT-BTC Officially effective from January 1, 2026. This article provides a clear update on the replacement roadmap, indicating which parts of Circular 200/2014/TT-BTC remain in effect and the important changes businesses need to prepare for to avoid risks when transitioning to the accounting system from 2026.
Is Circular 200/2014/TT-BTC still in effect from January 1, 2026?
Circular 200 will largely cease to be in effect and will be replaced by Circular 99/2025/TT-BTC from January 1, 2026.
According to Article 31 of Circular 99/2025/TT-BTC of the Ministry of Finance, the new accounting regime for enterprises will officially come into effect and apply to fiscal years beginning on or after January 1, 2026. Specifically, Circular 99 will completely replace the following documents:
- Circular 200/2014/TT-BTC: Guidance on accounting regime for enterprises.
- Circular 75/2015/TT-BTC: Amending and supplementing Circular 200.
- Circular 53/2016/TT-BTC: Amending and supplementing Circular 200.
- Circular 195/2012/TT-BTC: Accounting guidelines applicable to project owners.
Therefore, for the 2025 financial reporting period, accounting will continue to follow Circular 200. However, from the 2026 fiscal year onwards, businesses must switch to applying the new regulatory framework in Circular 99.
The provisions of Circular 200 continue to be implemented.
Although largely replaced, Circular 200 has not completely disappeared. A specific area of content has been retained to ensure continuity in state management.
These are the provisions related to the accounting for the equitization of state-owned enterprises. Specifically, the following provisions of Circular 200 remain in effect until replaced by another legal document:
- Accounting regulations are found in Article 21 (paragraphs 3.11, 3.12); Article 35 (paragraph 3.3).
- The guidelines in Articles 38, 40, 45, 47, 54, 57, 62, 63, 67, 71, 74, 77, 92, 93, and 94 relate directly to the equitization process.
This means that businesses undergoing a transition from state ownership to joint-stock companies still need to refer to these business lines in the old Circular 200.
Reference: Balance sheet according to Circular 200.
Scope and conditions for applying the new accounting system from 2026.
Circular 99/2025/TT-BTC is designed to standardize Vietnam's corporate accounting system, bringing it closer to international standards.
- Mandatory entities: Businesses of all economic sectors (except those with their own accounting systems issued by the Ministry of Finance).
- Voluntary participants: Small and medium-sized enterprises (SMEs), non-public institutions, and other accounting units have the right to choose to apply Circular 99 if they deem it appropriate to their scale and management requirements.
- Principle of Conversion: Once chosen, the business must maintain consistency for at least one accounting year. If there is a change in accounting method between years, the business must restate the comparative figures and provide a clear explanation in the Notes to the Financial Statements.
Reference: Balance sheet according to Circular 99.
The hottest new developments from January 1, 2026
Besides determining the validity of Circular 200, accountants need to pay special attention to the new regulations on currency units in Circular 99:
Greater freedom in choosing a foreign currency as the accounting currency.
From 2026, businesses can choose a foreign currency to record in their accounting books if they meet the following criteria:
- It is the primary currency that influences the prices of goods and services (often used for price listing and payment).
- As the primary currency, it significantly impacts labor costs, raw material costs, and other production costs.
Strict regulations regarding the conversion of reports to VND.
Even if a business keeps its books in a foreign currency, when submitting financial statements to government agencies or publishing them publicly, those statements must be presented in Vietnamese Dong (VND).
- Assets and liabilities: Converted using the average buying and selling exchange rates of the bank with which transactions are regularly conducted at the end of the period.
- Equity capital: Converted at the actual exchange rate on the date of capital contribution.
- Exchange rate differences: Recorded under the "Exchange rate differences" item in the equity section of the Statement of Financial Position.
To avoid being caught off guard and to ensure accuracy during the transition period, businesses can consider using... full accounting service Professional support from specialized accounting and tax firms like MAN – Master Accountant Network for in-depth assistance.
Advice for accountants and businesses
The expiration and replacement of Circular 200 with Circular 99 is a major change. To avoid being caught off guard, businesses need to:
- Update accounting software: Contact your software providers to adjust your chart of accounts and report templates according to Circular 99 before the 2026 accounting period.
- Staff training: Organize training sessions for the accounting department to ensure they understand how to handle exchange rate differences and transitional regulations.
- Reviewing 2025 data: Ensuring accurate ending balances for 2025 to serve as the basis for transferring balances to the new accounting system.
Hopefully, this article has adequately answered the question "Is Circular 200/2014/TT-BTC still in effect?" and given you an overview of the upcoming changes in accounting policy.
Contact MAN – Master Accountant Network for free support and advice!
Contact information MAN – Master Accountant Network
- Address: No. 19A, Street 43, Tan Thuan Ward, Ho Chi Minh City
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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 about Circular 200 and Circular 99
No. Circular 99/2025/TT-BTC is only effective for fiscal years beginning on or after January 1, 2026. Therefore, the 2025 financial statements must still comply with Circular 200/2014/TT-BTC.
It is not mandatory. SMEs can continue to apply Circular 133/2016/TT-BTC. However, if a business wants to improve its governance standards or is expanding, it may voluntarily choose to apply Circular 99, but must ensure consistency throughout the accounting period.
The transition to a new accounting system primarily involves changes in accounting methods and presentation. Businesses need to transfer balances from the old to the new accounting system. Asset revaluation is only carried out in specific cases as stipulated by law (such as privatization, splits, mergers) or as required by new accounting standards, if any.
The provisions related to accounting for equitization in Circular 200 will remain in effect until the Ministry of Finance issues a new legal document specifically to replace it. Can I prepare the 2025 financial statements according to Circular 99?
Are small and medium-sized enterprises (SMEs) currently applying Circular 133 required to switch to Circular 99?
When transitioning from Circular 200 to Circular 99, is it necessary to re-evaluate all assets?
How long will Circular 200 remain in effect regarding the equitization process?
