Professional Social Organizations: Circular 133 Does Not Apply, Choice of Corporate or Administrative-Non-Business Accounting Regime
The Department of Accounting and Audit Management and Supervision (Ministry of Finance) answered a reader's question on the accounting regime for a non-profit professional social organization funded by its own resources. According to the answer, Circular 133/2016/TT-BTC does not apply to professional social organizations. They may choose the corporate accounting regime under Circular 99/2025/TT-BTC or the administrative and non-business accounting regime under Circular 24/2024/TT-BTC, to suit their operations and management needs. When applying Circular 99/2025/TT-BTC, the entity must apply it consistently for at least one annual accounting period; if it changes regime, it must restate comparative figures and explain in the notes. On reporting, under Article 29 of the Law on Accounting, financial statements comprise a statement of financial position, a statement of operating results, a cash flow statement, notes and other reports required by law; annual financial statements go to the competent state authority within 90 days of the end of the annual accounting period.
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Question
An accountant of a non-profit professional social organization funded by its own resources (membership fees, sponsorship, member contributions and other lawful income) asked:
- Can it apply the accounting regime under Circular 133/2016/TT-BTC (or its replacement)?
- If not, which accounting regime should it apply?
- Which reports must it submit?
1. Choice of accounting regime
Circular 133/2016/TT-BTC (Article 2) applies to small and medium enterprises (including micro enterprises) in all sectors and economic sectors as defined by the law on SME support, except:
- State-owned enterprises and enterprises with over 50% state-owned charter capital;
- Public companies under securities law;
- Cooperatives and cooperative unions.
SMEs in special sectors (electricity, oil and gas, insurance, securities, etc.) follow the specific accounting regimes issued or approved by the Ministry of Finance.
Circular 99/2025/TT-BTC (Article 31.3): small and medium enterprises, non-public establishments and other accounting units may choose to apply this Circular to suit their operations and management needs. Once applied, it must be used consistently for at least one annual accounting period. When changing regime, comparative figures must be restated as for a change in accounting policy, and the reason and impact explained in the notes to the financial statements.
Circular 24/2024/TT-BTC (Article 2) sets the administrative and non-business accounting regime, applying to state agencies, public service units, political and socio-political organizations, the Vietnam Fatherland Front and other state-budget-using units, and units applying the public service unit financial mechanism (with some exceptions). Other organizations that do not use the state budget may apply this regime as appropriate to their activities.
Conclusion of the Department of Accounting and Audit Management and Supervision: Circular 133/2016/TT-BTC does not apply to professional social organizations. They may choose the corporate accounting regime (Circular 99/2025/TT-BTC) or the administrative and non-business accounting regime (Circular 24/2024/TT-BTC) to suit their operations and management needs.
2. Reports under accounting law
Under Article 29(1) and (3) of the Law on Accounting, financial statements must be prepared and presented in accordance with the accounting standards and regime applied, comprising:
- Statement of financial position;
- Statement of operating results;
- Cash flow statement;
- Notes to the financial statements;
- Other reports required by law.
Annual financial statements must be submitted to the competent state authority within 90 days from the end of the annual accounting period. The answer does not name a specific receiving authority.