Can Confirmations via Zalo OA Be Treated as Electronic Accounting Documents for Reward Payments?
The Department of Accounting Management, Supervision and Audit answered a business asking whether Zalo OA confirmations can serve as documents for paying reward support to second-tier agents instead of paper signatures. It cited the 2015 Accounting Law: accounting documents must contain the essential elements in Article 16(1); electronic documents must contain them, be in electronic data form, be encrypted and unaltered in transmission (Article 17); and they must carry an electronic signature or other electronic confirmation under e-transaction law (Article 19(4), amended in 2024). It gave no direct conclusion on Zalo OA and asked the company to assess the rules against its actual situation to decide whether Zalo OA transactions are electronic documents.
RegHub explainer by New MarketerLast updated:
Based on:141026-24 - 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.
The question
A business signed a hard-copy minute with second-tier agents providing that data confirmed via Zalo serves as the basis for paying sales-target reward support. It asked whether interactive confirmations on the Zalo OA platform count as signing documents for payment and for acknowledging receipt of support (including rewards paid in goods) instead of signing on paper.
Essential content of accounting documents (Article 16(1), 2015 Accounting Law)
- Name and number of the document
- Date of issue
- Name and address of the issuing party
- Name and address of the receiving party
- Description of the economic or financial transaction
- Quantity, unit price and amount in figures; total amount for receipts and payments in figures and words
- Signatures and full names of the preparer, approver and other relevant persons
Electronic documents (Article 17, 2015 Accounting Law)
- They count as accounting documents when they contain the Article 16 content, are in electronic data form, are encrypted and are not altered during transmission over networks or on storage media.
- They must ensure confidentiality and data integrity during use and storage, and are managed as accounting records in their original form.
- When a paper document is converted into an electronic one for transactions or payment (or vice versa), the electronic document is valid for that transaction; the paper one is only for record-keeping.
Electronic signature (Article 19(4), amended in 2024)
"Electronic documents must carry an electronic signature or other forms of electronic confirmation under the law on electronic transactions."
Opinion of the Department of Accounting Management, Supervision and Audit
The Department asks the company to rely on the accounting law and its actual circumstances to determine whether documents transacted on Zalo OA are electronic documents. If they meet the conditions, they must carry an electronic signature or other electronic confirmation under e-transaction law.
Note
The answer neither confirms nor rejects that Zalo OA confirmations are valid documents; the determination is left to the company.