1. Introduction to the Accounting Regulation

From January 1, 2026, enterprises are entitled to amend and supplement the system of accounting accounts, accounting vouchers, and accounting books in accordance with the guidelines in Appendices I, II, III, and IV issued together with Circular 99/2025/TT-BTC, to align with the characteristics of their production–business activities and internal management requirements.

To ensure proper implementation of the regulations, enterprises are required to issue an Accounting Regulation (or an equivalent document) as the legal and operational basis for execution.

KMC provides consulting services to develop and establish the Accounting Regulation, assisting enterprises in compliance with the regulations, reducing tax inspection risks, and optimizing financial management.

2. When Do Enterprises Need to Issue the Accounting Regulation?

Enterprises must issue an Accounting Regulation or an equivalent document in the following cases:

- Designing or amending accounting voucher templates

    • When an enterprise designs new or adjusts existing accounting voucher templates compared with the sample guidelines in Appendix I, pursuant to Clause 2, Article 9 of Circular 99/2025/TT-BTC.

- Amending or supplementing the system of accounting accounts

    • This includes the names, codes, structures, and content representation of accounting accounts as guided in Appendix II, pursuant to Clause 2, Article 11 of Circular 99.

- Amending or supplementing accounting book templates

    • When an enterprise changes or adds accounting book templates compared with the guidelines in Appendix III, pursuant to Clause 2, Article 12 of Circular 99.

- Adding items in financial statements

    • When an enterprise adds new items to financial statements as guided in Appendix IV, pursuant to Clause 1, Article 18 of Circular 99.

- Additional cases (detailed)

    • Applying a new accounting method or transitioning accounting regimes.
    • Adjusting authorization, internal control, and accounting responsibilities.
    • Changing organizational structure, expanding branches, or merging/splitting enterprises.

Thus, the Accounting Regulation serves as the legal and operational basis to help enterprises implement a synchronized accounting system in compliance with Circular 99/2025/TT-BTC.

3. Requirements When Developing the Accounting Regulation

When developing the Accounting Regulation, enterprises must ensure the following legal and operational requirements:

- Clearly state the necessity of amendments and supplements

    • Each adjustment must have a legal basis and practical justification to ensure transparency in internal control and inspection.

- Clearly define the enterprise’s legal responsibility

    • The enterprise is legally responsible for the accuracy, truthfulness, and completeness of the issued contents.

- Ensure compliance with accounting principles for accounts

    • Amended or supplemented accounts must:
      • Be correctly classified according to economic nature;
      • Avoid duplication of objects;
      • Comply with Vietnamese accounting principles;
      • Not distort or affect financial statement (FS) indicators.

- Ensure transparency of accounting vouchers and books

    • Amended accounting vouchers must fully, timely, truthfully, and transparently reflect transactions, making them easy to check, control, and reconcile assets and capital.
    • Accounting books (if amended) must also ensure completeness, transparency, and ease of verification and reconciliation, in accordance with Clause 2, Article 11 of Circular 99/2025/TT-BTC.

- Internal guidance and periodic updates

    • The Regulation should provide guidance for preparing internal reports, management reports, and trial balances.
    • The Regulation must include a plan for updates when new Circulars are issued or tax laws change, ensuring continuous legal compliance.

4. Notes When Opening New or Adjusting Accounting Accounts

According to Circular 99/2025/TT-BTC:

- Enterprises have the right to amend or supplement accounting accounts (name, code, structure, content) as long as they do not distort the financial statements (FS) and are consistent with the characteristics of business activities and internal management requirements.

Compared with the previous regime (Circular 200/2014/TT-BTC):

- Opening Level 2 and Level 3 accounts no longer requires approval from the Ministry of Finance.

- Amending or supplementing Level 1 or special Level 2 accounts previously required written approval from the Ministry of Finance.

Principles for implementation:

- Opening new accounts: must be based on the nature of the arising transactions, avoid duplication, and be easily reconcilable with accounting vouchers and FS.

- Amending existing accounts: must ensure that FS figures are not distorted.

- Special accounts: must provide detailed guidance on accounting methods, classification, and data aggregation.

- Risk control: all changes must be approved, with documentation and before–after comparison tables retained.

Circular 99/2025/TT-BTC increases enterprise autonomy, removes the requirement for Ministry of Finance approval, and enables greater flexibility in organizing the accounting system.

5. KMC Consulting Services for Establishing the “Accounting Regulation”

To support enterprises in complying with Circular 99/2025/TT-BTC and implementing a transparent accounting system, KMC provides professional consulting services to establish the Accounting Regulation with the following steps:

Step 1: Review the existing accounting system

- Assess the level of compliance with legal regulations.

- Identify accounting vouchers, books, and accounts that need adjustment.

Step 2: Develop or standardize accounting templates

- Design accounting vouchers and accounting books suitable for the enterprise’s characteristics and internal management requirements.

- Ensure transparency, completeness, timeliness, and truthfulness in accordance with the Accounting Law.

Step 3: Draft the Accounting Regulation

- Complete the Regulation with full legal content, accounting guidelines, internal control measures, and periodic updates.

- Ensure feasibility, clarity, and ease of practical application.

Step 4: Guide implementation within the enterprise

- Train the accounting department on accounting principles, authorization controls, and transaction recording procedures.

- Support practical applications and supervise operational processes.

Step 5: Support during inspection and audit

- Assist the enterprise in providing explanations, supplying legal documentation, and ensuring risk control and legal compliance.

6. Benefits of Using KMC’s Services

- 100% Legal Compliance: fully meets the requirements of Circular 99/2025/TT-BTC and the Accounting Law.

- Transparent Accounting System: accounting vouchers, books, and accounts are standardized and synchronized.

- Optimized Internal Management: facilitates verification, control, and reconciliation of assets and capital.

- Reduced Risk during Tax Inspection: complete legal documentation and transparent explanations.

- Time and Cost Savings: enterprises do not need to independently develop, review, and repeatedly check their systems.

7. Contact KMC Today

📞 Contact KMC for consulting services to establish a legally compliant Accounting Regulation and optimize internal management: [081 489 4789 / info@kmc.vn]

KMC is committed to providing comprehensive support-from reviewing, drafting, and implementation to accompanying enterprises during inspections and audits - helping enterprises operate a transparent, accurate, and efficient accounting system.