Ministry of Finance Guidance on Accounting for Local Housing Funds Managed by Development Investment Funds
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Based on:302/2025/NĐ-CP - Ministry of Finance
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The Ministry of Finance's Department of Accounting and Auditing Management and Supervision issued an official response to a reader's question about accounting treatment between a provincial Local Development Investment Fund (LDIF) and a local Housing Fund, in cases where the LDIF is assigned to manage the Housing Fund under Decree No. 302/2025/ND-CP dated November 19, 2025. According to the guidance, when an LDIF receives entrusted management of the operations and capital of a local Housing Fund, it must separately account for the entrusted capital and any assets formed from that capital, keeping them distinct from the LDIF's own operating capital and assets, per Clause 3, Article 32 and Article 38 of Decree No. 147/2020/ND-CP. Accounting for the entrusted activity follows Circular No. 90/2021/TT-BTC, which allows the fund to open additional detail-level sub-accounts to meet its own management needs. The Ministry also noted that other matters raised - such as final settlement of revenue and expenses, distribution of income-expense differentials, and annual financial planning for the Housing Fund - fall outside the authority of the Department of Accounting and Auditing Management and Supervision and will be forwarded to the relevant unit for a separate response. This guidance applies mainly to off-budget state financial funds at the provincial level and does not directly affect the accounting or tax obligations of private enterprises or household businesses.
The Question
A reader (question code 230626-26, Mr. Dang Duc Tam) submitted a question to the Ministry of Finance regarding Decree No. 302/2025/ND-CP dated November 19, 2025. Under Point d, Clause 4, Article 3 of this Decree, for a local Housing Fund that is not a public non-business unit:
"The fund specified in Points b and c of this Clause is responsible for the operations of the local Housing Fund, may not use its own operating capital for purposes other than the fund's objectives, and must separately account for and track its own operating capital. The legal status, legal entity status, organizational structure, financial regime, asset management and use, and reporting and accounting regime for the local Housing Fund... continue to follow the fund's current operating model."
Based on this, the reader asked the Ministry of Finance for further guidance on three points:
- Management and accounting of the Housing Fund's charter capital: whether to treat it as entrusted (trust) capital under Clause 3, Article 32 and Article 38 of Decree No. 147/2020/ND-CP, or to track it together with the Local Development Investment Fund's (LDIF) owner's equity in the financial statements.
- Separate accounting of capital, assets, revenue, expenses, and income-expense differentials between the LDIF and the Housing Fund, including whether a supplementary schedule must accompany the annual financial statements, and how final settlement and distribution of income-expense differentials should work.
- Whether annual operating and financial plans should be combined or prepared separately for the two funds.
The Ministry of Finance's Response
The Department of Accounting and Auditing Management and Supervision (Ministry of Finance) responded as follows:
- Under Clause 3, Article 32 and Article 38 of Decree No. 147/2020/ND-CP, an LDIF must separately account for entrusted capital and any assets formed from that entrusted capital (if any), keeping them distinct from the fund's own operating capital and assets. The entrusted activity must not affect the fund's other functions and duties.
- Under Point d, Clause 4, Article 3 of Decree No. 302/2025/ND-CP, where an existing financial fund (the LDIF) is assigned to carry out the objectives of a local Housing Fund, that fund is responsible for the Housing Fund's operations, may not use its own operating capital for other purposes, and must separately account for and track the Housing Fund's capital.
- Combining these two provisions: if an LDIF receives entrusted management of a local Housing Fund's operations and capital, it must separately account for the entrusted capital and any assets formed from it, distinct from the LDIF's own operating capital and assets, per Decree No. 147/2020/ND-CP.
- On the specific accounting mechanics: Circular No. 90/2021/TT-BTC dated October 13, 2021 provides guidance on accounting for entrusted management and syndicated capital activities, as well as on preparing and presenting financial statements for such entrusted activities. Under Article 4 of this Circular, off-budget state financial funds may add detail-level sub-accounts to the accounts already prescribed in the Circular to meet their own management needs. Accordingly, an LDIF records entrusted activity under the current accounting regime and may open separate detail accounts for the Housing Fund.
- Regarding the questions on final settlement of revenue and expenses, distribution of income-expense differentials, and annual operating/financial planning for the local Housing Fund: the Department stated these fall outside its functions and duties, and asked the Department of Information Technology and Digital Transformation to forward these items to the appropriate unit for a response to the reader.
Practical Implications
This response is primarily relevant to provincial Local Development Investment Funds that are, or will be, assigned to manage a local Housing Fund under Decree No. 302/2025/ND-CP. It does not directly apply to the accounting or tax obligations of ordinary private enterprises, household businesses, or individuals.