Ministry of Finance Q&A: Detailed vs Lump-Sum Budget Submission to State Treasury
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The Ministry of Finance clarified that two older circulars (Circular 161/2012/TT-BTC and Circular 39/2016/TT-BTC) have expired. The applicable legal framework for State Treasury expenditure control now rests on: clause 4, Article 58 of the State Budget Law No. 89/2025/QH15; Decree 347/2025/ND-CP on State Treasury administrative procedures; and Decree 73/2026/ND-CP implementing the State Budget Law. Under current rules, the State Treasury processes payments only when expenditures appear in the approved budget allocation. Budget allocations to spending units must be detailed by sector and expenditure task. For autonomous-budget units, Decree 75/2026/ND-CP requires the primary budget unit to allocate budgets in two distinct parts (autonomous and non-autonomous), with detailed supporting notes submitted to the finance authority and the State Treasury. Practical implication: the initial submission package to the State Treasury must include a detailed budget breakdown, not just a lump-sum total, since the Treasury checks each expenditure item against the approved detailed budget.
Ministry of Finance Policy Q&A
Question: When submitting the initial package to the State Treasury, must the annual budget show a lump-sum total (one line) or a detailed breakdown? Does a lump-sum contradict the expenditure condition requirement?
Responding authority: Ministry of Finance
Legal references cited in the official answer:
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Clause 4, Article 58, State Budget Law No. 89/2025/QH15: The State Treasury processes expenditure payments when items appear in the competent authority-approved budget or under interim budget allocation provisions.
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Points c, d, clause 2, Article 6, Decree 347/2025/ND-CP: Treasury processes payments/advances for state budget sources when the expenditure is in the approved budget and within the account balance. The same applies to other lawful revenue sources (fees, service revenue).
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Clause 2, Article 21, Decree 73/2026/ND-CP: Treasury reviews the dossier against the issued budget allocation and may refuse payment for items not included in the approved budget.
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Clause 2, Article 19, Decree 73/2026/ND-CP: Budget allocations to spending units must be detailed by sector and expenditure task.
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Point a, clause 2, Article 11, Decree 75/2026/ND-CP (administrative autonomy regime): The primary budget unit must allocate budgets in two distinct parts - autonomous and non-autonomous - with detailed task-by-task notes sent to the finance authority and State Treasury.
Conclusion: The budget submission to the State Treasury must be a detailed breakdown (not a lump-sum), corresponding to each approved expenditure task.