Accounting in Vietnam: 7 Internal Controls Businesses Should Review in 2026

Updated: October 27, 2026

For businesses operating in Vietnam, accounting is not simply a matter of recording transactions and preparing financial statements. Reliable financial information depends on the procedures used to approve transactions, verify supporting documents, reconcile balances, protect accounting data, and review reports before they are finalized.

These responsibilities become particularly important for foreign-invested enterprises (FIEs), which may need to satisfy Vietnamese statutory requirements while providing financial information to overseas parent companies.

The regulatory environment has also evolved. Circular No. 99/2025/TT-BTC, which applies to financial years beginning on or after January 1, 2026, introduces an updated enterprise accounting regime and expressly addresses businesses’ responsibilities for internal governance and control.

For finance directors, chief accountants, and business owners, this creates an opportunity to review whether existing accounting procedures are sufficiently documented, consistent, and appropriate for the company’s operations.

This guide explains the regulatory context for accounting in Vietnam in 2026, examines seven important areas of internal control, and provides a practical framework for identifying weaknesses before they affect financial reporting.

1. Accounting in Vietnam Under Circular 99/2025/TT-BTC

On October 27, 2025, the Ministry of Finance issued Circular No. 99/2025/TT-BTC guiding the Enterprise Accounting Regime (Thông tư số 99/2025/TT-BTC hướng dẫn Chế độ kế toán doanh nghiệp).

Under Clause 1, Article 31, the Circular takes effect on January 1, 2026, and applies to financial years beginning on or after that date. It replaces Circular No. 200/2014/TT-BTC within the relevant accounting regime, subject to the transitional provisions and exceptions specified in Circular 99.

Businesses should first confirm which accounting regime applies to their circumstances, rather than assuming that every entity follows identical requirements.

The official text is available through the Government of Vietnam’s Official Gazette – Circular No. 99/2025/TT-BTC.

1.1. What does Circular 99 say about internal controls?

One of the provisions most relevant to financial management is Clause 2, Article 3.

This provision requires enterprises to establish internal governance regulations, or equivalent documentation, and organize internal controls that clearly define the rights, obligations, and responsibilities of the departments and individuals involved in initiating, executing, managing, and controlling economic transactions.

In practical terms, a company should be able to explain who is responsible for a transaction at each stage, what evidence supports it, and how the transaction is checked before its financial effects are reported.

For example, when a supplier invoice is received, the company should have a procedure for verifying the invoice, confirming the related purchase, authorizing payment, and recording the transaction. The responsibilities of the employees involved should not depend solely on informal instructions.

Circular 99 does not require every business to adopt an identical control structure. The procedures should reflect the company’s size, operations, organizational responsibilities, and applicable legal obligations.

1.2. Why is this important for foreign-invested enterprises?

Many foreign-invested companies operate with two interconnected reporting requirements.

The Vietnamese entity must maintain accounting records and prepare reports in accordance with its applicable local accounting framework. At the same time, an overseas parent company may request financial information for consolidated reporting, management analysis, or group-level decision-making.

These reporting processes can use different account classifications, reporting formats, currencies, or accounting policies.

Without clear procedures, differences between local and group reports may be difficult to explain. The challenge is not necessarily that either report is incorrect, but that adjustments and classifications must be traceable to reliable information.

For this reason, businesses reviewing accounting in Vietnam should consider both statutory compliance and the effectiveness of their internal financial reporting processes.

2. Seven Accounting Internal Controls Businesses Should Review

An effective internal control environment does not necessarily require complicated procedures. It requires controls that address identifiable risks, establish accountability, and generate information that management can verify.

The following seven areas provide a practical framework for assessing accounting operations in 2026. They are recommended management review areas, not a statutory seven-point checklist.

2.1. Establish Clear Responsibilities and Approval Procedures

Financial transactions typically involve several activities: initiating a purchase, verifying the transaction, approving payment, recording the accounting entry, and reviewing the resulting information.

When responsibilities are unclear, important decisions may be made without appropriate authorization or supporting evidence.

Consider a company in which one employee can independently create a new supplier, change that supplier’s bank details, approve an invoice, and arrange payment. Even when the employee acts appropriately, the absence of independent review creates unnecessary exposure to errors or unauthorized transactions.

A practical control is to establish an approval structure based on the nature and value of transactions. The structure should identify who can authorize expenditure, who verifies supporting documents, and who is responsible for recording and reviewing the transaction.

For smaller businesses, complete segregation of duties may not always be possible. Management can instead introduce compensating controls, such as independent review of bank payments or periodic verification of changes to supplier information.

The important consideration is whether the company has a documented and workable method for identifying responsibility.

Management review question: Can the business identify who authorized, processed, recorded, and reviewed a significant financial transaction?

2.2. Verify Supporting Documents Before Recording Transactions

Supporting documents are essential to the reliability of accounting information.

Under Clause 1, Article 10 of Circular 99/2025/TT-BTC, economic and financial transactions arising in connection with an enterprise’s activities must be supported by accounting documents. The provision also specifies that an accounting document is prepared once for each transaction.

Clause 3 of the same Article addresses the appropriate delegation of authority for signing accounting documents, taking account of legal requirements, management needs, and internal governance procedures.

In day-to-day operations, companies should examine whether supporting documents accurately reflect the underlying transactions.

For example, an invoice for purchased goods may need to be considered together with the purchase agreement, delivery documents, warehouse records, and payment information. An invoice alone may not resolve every question about what was purchased, when goods were received, or whether the transaction was properly authorized.

A reliable procedure enables the accounting team to trace a recorded entry back to the relevant commercial activity.

This becomes particularly important when transactions are processed by different departments or when documents are received after the accounting period in which the underlying activity occurred.

Companies should also define how incomplete documents, conflicting information, or disputed transactions are handled.

Management review question: Can material accounting entries be traced to complete, consistent, and appropriate supporting records?

2.3. Maintain Consistent Accounting Policies and Account Classifications

A chart of accounts provides the structure through which financial transactions are classified and presented. However, its usefulness depends on whether account classifications are applied consistently and reflect the nature of the company’s operations.

Circular 99 includes an updated enterprise accounting framework. Article 11 addresses the chart of accounts and the conditions applicable when enterprises make permitted additions or adjustments.

Companies should therefore review whether their existing chart of accounts and accounting policies remain appropriate under the regime applicable to them.

For example, a manufacturing company may require detailed accounting information on raw materials, work in progress, production costs, and finished goods. A consulting business may instead require more detailed tracking of project-related expenses and service revenue.

An accounting structure that does not reflect these differences can reduce the usefulness of financial information.

For foreign-invested enterprises, another consideration is the relationship between Vietnamese accounting classifications and the reporting categories used by the overseas parent company.

Where mapping or reclassification is necessary, the company should maintain a clear explanation of the adjustments performed. Changes to accounting policies and account structures should also be properly reviewed and documented.

These arrangements make it easier to identify whether differences in financial reports reflect legitimate accounting treatments or inconsistencies in the underlying records.

Management review question: Are accounting policies, account classifications, and reporting adjustments clearly documented and consistently applied?

2.4. Perform Regular Reconciliations and Investigate Differences

A reconciliation compares information from different records or sources to determine whether the amounts are consistent.

In a business environment, reconciliations can involve bank balances, receivables, payables, inventory, intercompany accounts, or other significant financial information.

Clause 2, Article 13 of Circular 99/2025/TT-BTC requires accounting books to be recorded on the basis of accounting documents, with information recorded accurately, truthfully, and in accordance with the supporting documents.

Regular reconciliations help businesses identify issues that may otherwise remain unnoticed until financial statements are prepared.

For instance, a supplier statement may show a different outstanding balance from the amount recorded in the company’s accounts payable ledger. This difference could arise from a missing invoice, an unrecorded payment, a credit note, or a timing difference between the parties.

The objective of reconciliation is not simply to make two numbers match. The accounting team should determine why a difference exists, verify the relevant documents, and record any necessary correction through an appropriate process.

Companies should also establish clear responsibility for resolving outstanding reconciliation items. An unexplained difference that is repeatedly carried forward can weaken the reliability of subsequent reporting periods.

For businesses with multiple operating locations or related-party transactions, reconciliation procedures may need to cover additional systems and reporting entities.

Management review question: Are significant account balances regularly reconciled, and are unresolved differences investigated before financial reports are finalized?

2.5. Strengthen Accounting Software and Data Security Controls

Accounting software can streamline transaction processing, improve access to financial information, and support reporting activities. However, the reliability of the output depends on the accuracy of the underlying data and the controls built around the system.

Article 28 of Circular 99/2025/TT-BTC addresses requirements relating to accounting software. These include matters such as the accuracy of processed information, the traceability of changes to recorded accounting data, information security, and the availability of data for authorized users.

Clause 2, Article 28 also establishes responsibilities for the accuracy and truthfulness of accounting information produced through accounting software.

In practice, management should consider whether user access is appropriate for each employee’s responsibilities.

An employee responsible for entering purchase invoices, for example, may not need authority to modify historical entries or change payment approval settings. Similarly, access granted to employees who have left the company should be reviewed and revoked when appropriate.

Businesses should also examine how accounting data is backed up, how changes are recorded, and whether the organization can recover essential financial information after a technical disruption.

When accounting software is integrated with invoicing, inventory, payroll, or banking systems, the accuracy of transferred information becomes another area of concern.

For additional information, businesses can refer to PHAM CONSULT’s article on accounting software regulations in Vietnam in 2026.

Management review question: Can the company identify who has access to accounting data, what changes were made, and how critical records are protected?

2.6. Reconcile Vietnamese Accounting Records with Group Reporting

For foreign-invested enterprises, reliable financial reporting often requires coordination between the local accounting team and the overseas finance department.

The information prepared for a parent company may differ from Vietnamese statutory reports because of group accounting policies, reporting formats, account mappings, or currency requirements.

A parent company may, for example, request an IFRS-based reporting package. That requirement does not automatically replace the accounting obligations of the Vietnamese legal entity.

The company should therefore establish a documented process for preparing and reviewing any adjustments required for group reporting.

A reconciliation between local accounting records and the reporting package can help identify where differences arise and whether those differences are properly supported.

This is particularly important when the business reports financial results in a currency different from that used in its Vietnamese accounting records.

Responsibility for preparing and reviewing adjustments should be clearly assigned. The final reporting package should also be supported by documentation that can be examined when questions arise.

Businesses considering changes to their accounting currency can refer to PHAM CONSULT’s analysis of financial statement preparation when changing accounting currency under Circular 99.

The objective is not to eliminate every difference between local and group reporting. It is to ensure that differences are understood, appropriately treated, and traceable.

Management review question: Can the company explain and support the adjustments between Vietnamese statutory accounting records and the reporting information submitted to its parent company?

2.7. Establish a Reliable Financial Closing and Reporting Process

Financial closing is the process through which a company reviews and finalizes accounting information for a reporting period.

It may involve completing outstanding accounting entries, reconciling accounts, reviewing estimates and adjustments, and preparing financial statements for management review.

Under Clause 3, Article 13 of Circular 99/2025/TT-BTC, enterprises must close their accounting books at the end of the accounting period for the preparation of financial statements and in other cases required by law.

Article 25 also establishes the general deadline for submitting annual financial statements to competent authorities: no later than 90 days after the end of the annual accounting period. Other applicable legislation may impose additional or different reporting requirements in particular circumstances.

Meeting a deadline is important, but timely submission should not come at the expense of reliable information.

A structured closing process should specify when supporting documents must be submitted, which accounts require reconciliation, who reviews proposed adjustments, and who approves financial reports before release.

For example, if the warehouse department does not submit inventory information on time, the accounting team may be unable to complete its review of inventory balances. Similar difficulties can arise when payroll information, customer invoices, or supplier confirmations are delayed.

A closing timetable supported by clear departmental responsibilities can help address these issues before they affect the annual reporting process.

Regular monthly or quarterly reviews may also reduce the accumulation of unresolved matters at year-end.

Management review question: Does the company have a documented closing timetable with defined responsibilities, review procedures, and approval requirements?

3. A Practical Accounting Internal Control Checklist for 2026

The seven control areas can be summarized in a management checklist. This framework is intended to support an internal review and should be adapted to the company’s operations and risk profile.

Control area	Key question	Evidence to review
Transaction approval	Are authority and responsibilities clearly assigned?	Approval policies and authorization records
Supporting documents	Are recorded transactions supported by appropriate evidence?	Contracts, invoices, delivery records and payment documents
Accounting policies	Are classifications and policy changes consistent and documented?	Accounting policies and account-mapping schedules
Reconciliation	Are material differences identified and investigated?	Reconciliation reports and supporting explanations
Software controls	Are access rights, data changes and backups appropriately managed?	User permissions, system logs and backup records
Group reporting	Are local and group reporting differences explained?	Reporting packages and adjustment schedules
Financial closing	Are closing procedures and responsibilities clearly established?	Closing schedules, review records and financial statements

This is a suggested management review checklist, not a mandatory seven-item form issued under Circular 99/2025/TT-BTC.

Companies should prioritize areas where an error could have a significant effect on financial reporting, operational decisions, or compliance obligations.

A smaller business may require relatively straightforward procedures, while a company operating multiple locations or handling complex transactions may need more extensive controls.

4. Practical Example: Identifying an Accounting Discrepancy Before Month-End

Consider a hypothetical foreign-invested trading company in Vietnam that purchases products from domestic suppliers and reports monthly financial information to its overseas parent company.

During month-end reconciliation, the accounting team discovers that an invoice has been recorded in the accounting ledger, but the warehouse management system does not show a corresponding goods receipt.

Initially, the difference may appear to be a routine timing issue. However, several explanations are possible: the goods may not yet have arrived, the warehouse transaction may not have been entered, the invoice may relate to another delivery, or an accounting entry may have been processed incorrectly.

A company with effective controls would investigate the matter using the purchase order, supplier invoice, delivery records, and warehouse information.

The responsible employees would determine the status of the transaction and whether any accounting adjustment is necessary under the applicable accounting requirements.

The conclusion would then be documented and reviewed before the relevant reporting information is finalized.

This example shows how several controls work together. Supporting documents help establish what occurred, reconciliations reveal inconsistencies, approval procedures clarify responsibility, and the closing process ensures that unresolved issues receive appropriate attention.

It also illustrates why a functioning accounting system does not depend exclusively on accounting software. Reliable results require both appropriate technology and effective operational procedures.

5. How Should Businesses Improve Their Accounting Processes?

Improving internal controls should begin with an assessment of existing procedures rather than the immediate introduction of additional administrative requirements.

Management should identify the company’s most significant accounting processes, consider where errors or unauthorized transactions could arise, and determine whether current controls are adequate.

For example, a business experiencing frequent discrepancies between inventory records and accounting balances may benefit more from improving its goods receipt and reconciliation procedures than from redesigning unrelated approval processes.

After identifying priority areas, the company should document the responsibilities of the departments and individuals involved.

Where appropriate, this may include updating internal policies, adjusting accounting software permissions, improving document handover procedures, or introducing additional management reviews.

Implementation should also include a mechanism for evaluating whether the revised procedures are working as intended.

A control that exists only in a written policy may provide limited value if employees do not understand it or if management does not review its operation.

In the context of accounting in Vietnam, the effectiveness of internal controls should be evaluated alongside the company’s applicable statutory obligations and financial reporting needs.

Businesses with limited accounting resources may consider professional assistance when evaluating existing procedures, addressing complex reporting issues, or implementing improvements to accounting systems.

6. Frequently Asked Questions About Accounting in Vietnam

6.1. Are these seven internal controls mandatory under Circular 99?

No. Clause 2, Article 3 of Circular 99/2025/TT-BTC addresses the responsibility to establish internal governance regulations or equivalent documents and organize internal controls.

The seven areas discussed in this article are a practical framework for business review. They should not be interpreted as seven separately prescribed statutory requirements.

6.2. Does Circular 99 apply to every business in Vietnam?

Businesses must identify the accounting regime applicable to their legal status and circumstances. Circular 99 provides guidance for the enterprise accounting regime within its scope, while other accounting regimes and sector-specific requirements may be relevant to certain entities.

Companies should confirm the applicable regime before making changes to their accounting policies or reporting procedures.

6.3. Can an FDI company prepare reports under IFRS for its parent company?

An overseas parent company may require financial information prepared under IFRS or group-specific accounting policies.

However, preparing such information does not automatically replace the Vietnamese statutory accounting and reporting requirements applicable to the local entity. The company should maintain an appropriate process for reconciling relevant differences.

6.4. Is accounting software sufficient to ensure compliance?

No. Accounting software can support reliable recording, processing, and reporting, but it cannot independently resolve all issues relating to document accuracy, authorization, employee responsibilities, or management oversight.

Businesses should establish appropriate procedures around the systems they use.

6.5. How often should accounting controls be reviewed?

The appropriate frequency depends on the nature of each control and the risks involved.

Certain activities, such as transaction authorization, may occur whenever a relevant transaction is processed. Other procedures, such as balance reconciliations or user-access reviews, may be performed periodically.

Management should determine a review schedule consistent with the company’s size, operations, and reporting requirements.

6.6. When should a business seek professional accounting support?

Professional support may be appropriate when a company experiences recurring reconciliation differences, difficulties adapting to regulatory changes, unclear accounting responsibilities, unreliable management reports, or complex reporting requirements from an overseas parent company.

An assessment can help determine whether the company needs targeted technical assistance, improvements to internal procedures, or broader support for its accounting function.

7. How PHAM CONSULT Can Support Your Accounting Operations

Reliable accounting information supports more than statutory reporting. It enables management to monitor business performance, evaluate financial risks, and make decisions based on information that can be explained and verified.

For businesses operating in Vietnam, developing an appropriate accounting structure involves balancing compliance requirements with operational efficiency and financial management needs.

PHAM & ASSOCIATES CONSULTING COMPANY LIMITED (PHAM CONSULT) provides professional accounting and business advisory services, including support for foreign-invested enterprises.

Depending on the agreed scope of work, PHAM CONSULT offers assistance with the preparation and review of financial statements, the design and implementation of accounting systems, internal control procedures, bookkeeping, accounting department organization, and financial management reporting.

Businesses seeking to review or improve their accounting arrangements can explore PHAM CONSULT’s Accounting Services for further information.

For an initial consultation, please contact PHAM CONSULT to discuss your company’s existing accounting processes, reporting requirements, and areas where professional assistance may be useful.

PHAM CONSULT

Website: https://phamconsult.com/

Email: info@phamconsult.com

Ho Chi Minh City Office: +84 28 3930 2487

Disclaimer: This article provides general information about accounting practices and internal controls in Vietnam. The recommendations are intended for management consideration and do not replace a review of applicable legislation or professional advice based on a company’s specific circumstances.