Handling Account 161 and 461 Balances When Transitioning from Accounting Regime Circular 200/2014/TT-BTC to Circular 99/2025/TT-BTC
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Based on:Thông tư số 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.
From 1 January 2026, Circular No. 99/2025/TT-BTC on the enterprise accounting regime took effect, eliminating Account 161 (Non-business Expenditure) and Account 461 (Non-business Fund Source). The Department of Accounting and Auditing Supervision (Ministry of Finance) advises that the transfer of balances depends on the underlying nature of the funds received from the state. Three scenarios apply: (1) if the amounts are collected or disbursed on behalf of the state, transfer to Account 138 (Other receivables) and Account 338 (Other payables); (2) if the amounts are subsidies to reduce production and business costs, record as a reduction of the relevant costs; (3) if the amounts represent a state procurement order (where the state is the customer), record as accounts receivable or advance receipts from customers. Because the question did not clearly describe the nature of the funds, the Department had insufficient basis to provide specific guidance and asked the enterprise to review the nature of each amount before applying the correct accounting treatment.
Question
A 100% state-owned public utility enterprise uses Account 161 (Non-business Expenditure) and Account 461 (Non-business Fund Source) under the previous accounting regime to track non-business spending and state-budget allocations. Since Circular No. 99/2025/TT-BTC took effect on 1 January 2026 and no longer includes these two accounts, the enterprise requested guidance from the Ministry of Finance on how to handle the remaining balances.
Official guidance
Based on Circular No. 99/2025/TT-BTC dated 27 October 2025 issued by the Minister of Finance on the enterprise accounting regime (effective 1 January 2026), Appendix II's chart of accounts no longer includes Account 161 or Account 461.
The Department of Accounting and Auditing Supervision noted that because the question did not clearly describe the nature of the funds received from the state, it could not provide specific guidance. Enterprises must first determine the nature of each amount and then apply the corresponding treatment:
- Collection or disbursement on behalf of the state - Record in Account 138 (Other receivables) and Account 338 (Other payables).
- Subsidy to reduce production and business costs - Record as a reduction of the relevant production and business costs.
- State procurement order (state as customer) - Record as accounts receivable or advance receipts from customers in a sale of goods or services to the state.
Action points
- Review all balances in Account 161 and Account 461 and determine the nature of each amount received from the state.
- Classify each amount into one of the three scenarios above and transfer the balance to the corresponding account.
- Retain supporting documents evidencing the nature of each amount to facilitate future inspections or audits.