Ministry of Finance Q&A: Accounting for Pre-accrued Major Fixed Asset Repair Costs under Circular 99/2025/TT-BTC
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The Department of Accounting and Auditing Management and Supervision (Ministry of Finance) clarified that Circular 99/2025/TT-BTC on enterprise accounting standards, effective from 1 January 2026, governs fiscal years starting on or after that date. For enterprises that had been pre-accruing major fixed asset repair costs but had not yet performed the repairs when the Circular came into force: enterprises must stop further pre-accrual. When the actual repair is subsequently carried out, the enterprise offsets actual repair costs against the pre-accrued amount. Any difference between the pre-accrued amount and actual costs is allocated gradually to production and business expenses over future periods. There is no mandatory retrospective restatement of previously accrued amounts. This is important guidance for enterprises with significant fixed assets (factories, heavy equipment) that have been using the pre-accrual method for major repairs.
Ministry of Finance Policy Q&A - Accounting and Auditing Management Department
Question (code 180526-6, Le Minh Duc): Pre-accrued major fixed asset repair costs are no longer compatible with Circular 99 - must the enterprise restate retrospectively? How should the remaining pre-accrued balance be handled?
Responding authority: Department of Accounting and Auditing Management and Supervision - Ministry of Finance
Legal references cited:
Clause 4, Article 30, Circular 99/2025/TT-BTC: "If an enterprise has been pre-accruing major fixed asset repair costs but the repair has not yet been performed when this Circular takes effect, the enterprise shall cease further pre-accrual. When the major repair is subsequently performed, the enterprise shall offset the actual repair cost against the pre-accrued amount; the difference between the pre-accrued amount and the actual cost shall be allocated gradually to production and business expenses in future periods."
Clause 1, Article 31, Circular 99/2025/TT-BTC: The circular takes effect from 1 January 2026 and applies to fiscal years starting on or after 1 January 2026.
Practical conclusions:
- From 1 January 2026: stop accruing major repair costs
- When repair actually occurs: offset actual costs against the pre-accrued amount
- Difference: allocate gradually to business expenses over future periods (not expensed at once)
- No mandatory retrospective restatement of previously accrued amounts