Accounting for State Science-Technology Contract Payments After Accounts 161 and 461 Are Abolished Under Circular 99/2025/TT-BTC
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Based on:99/2025/TT-BTC - Ministry of Finance
This explanation was generated by AI and checked by an automated AI review, not by a human expert. It is not legal, tax or accounting advice and may contain errors. Check the official document before you rely on it.
A state-owned enterprise signed a contract with the Ministry of Finance to carry out a science and technology task, with a fixed budget of VND 300 million payable upon completion and no invoice required. The contract was signed and completed in 2025, but the Ministry made payment in early 2026. The company ran into a problem because the new enterprise chart of accounts in Appendix II of Circular No. 99/2025/TT-BTC dated October 27, 2025 (effective from January 1, 2026) removed Account 161 - Non-business expenditure and Account 461 - Non-business funding sources, which had previously been used to record this type of funding. The Department of Accounting and Auditing Management and Supervision (Ministry of Finance) responded that, in substance, this is a sale-of-goods and service-provision transaction between the enterprise and the State, with the State acting as a customer, rather than a traditional budget-allocated non-business funding item. The enterprise should therefore rely on the signed science-technology task order contract and apply the revenue and expense recognition guidance in Circular 99/2025/TT-BTC to record the transaction appropriately, instead of looking for accounts equivalent to the abolished Account 161 and Account 461. This is an important reminder for state-owned enterprises and other entities with science-technology task or public-service order contracts with government agencies: from January 1, 2026, revenue from such contracts must be recorded as sales/service revenue under the new accounting regime, since the previous non-business funding accounts have been discontinued.
Situation
A state-owned enterprise signed a contract with the Ministry of Finance to perform a science and technology task. Under the contract, the Ministry is the ordering party and the enterprise is the party receiving the order, with a fixed budget of VND 300 million payable upon completion of the contract. The contract was signed and completed in 2025, and the Ministry made the payment in early 2026. For this contract, the enterprise is not required to issue an invoice.
The question arose because the enterprise chart of accounts in Appendix II attached to Circular No. 99/2025/TT-BTC dated October 27, 2025 of the Ministry of Finance (guiding the enterprise accounting regime, effective from January 1, 2026) no longer includes Account 161 - Non-business expenditure and Account 461 - Non-business funding sources, the two accounts previously used to record this type of funding. The enterprise asked the Ministry of Finance to guide it on which account to use instead.
Official Answer
The Department of Accounting and Auditing Management and Supervision (Ministry of Finance), responding to inquiry ticket No. 100726-22, stated: in substance, this is a sale-of-goods and service-provision transaction between the enterprise and the State, with the State acting as a customer of the enterprise, rather than a non-business funding allocation under the traditional budget mechanism. Therefore, the enterprise should base its accounting on the signed science-technology task order contract with the State and apply the revenue and expense recognition guidance set out in Circular No. 99/2025/TT-BTC, rather than searching for accounts equivalent to the abolished Account 161 and Account 461.
Practical Implications
- From January 1, 2026, revenue from science-technology task orders or public-service contracts with government agencies must be recorded by enterprises as sales/service revenue under the new accounting regime in Circular 99/2025/TT-BTC.
- The traditional non-business funding accounts (Account 161, Account 461) are no longer used in the new enterprise chart of accounts; enterprises should review how they record similar contracts, including ones straddling the transition between the old and new accounting regimes.
- State-owned enterprises and other entities with science-technology or public-service order contracts with government agencies should proactively update their internal accounting procedures and books before Circular 99/2025/TT-BTC takes effect, to avoid errors in revenue and expense recognition.