Knowledge base

The Ministry of Finance (Department of Accounting and Auditing Supervision) clarifies that the phrase "organizations and service units not using the state budget" in Article 2.3 of the 2015 Accounting Law refers broadly to any organization that does not fall into the other four categories: state budget agencies, state agencies and budget-funded service units, enterprises, and cooperatives. This is the first interpretation - "organization" stands independently from "service unit." Examples include extra-budgetary state financial funds, social funds, and charitable funds. All such entities are required to organize an accounting apparatus and prepare financial statements. In addition to accounting law, the specific accounting obligations of each organization type depend on its governance structure, operational model, and financial mechanism as defined in relevant specialized regulations.

The Department of Accounting and Auditing Management (Cuc QLKT) under the Ministry of Finance clarifies the accounting treatment for real estate businesses that issue invoices based on agreed collection milestones before transferring the property. Under Circular 99/2025/TT-BTC, Account 3387 (Deferred Revenue) may only be used when cash has already been received; it cannot be credited against Account 131 (Trade Receivables) for invoiced amounts not yet collected and where the goods or property have not been transferred. Any such internal tracking is for management purposes only and must not appear in the statutory financial statements. Tax obligations arising from invoices issued but not yet collected are governed separately by applicable tax law and must be determined accordingly.

The Ministry of Finance confirms that to be appointed as chief accountant or accounting manager, an individual must hold a chief-accountant refresher certificate AND have actual working experience in accounting, as required by Article 53(4) and Article 54(1) of the 2015 Law on Accounting. A person who holds only a second accounting degree but has never practiced accounting and lacks the refresher certificate does not meet the appointment requirements. For State Treasury transaction registration, the Ministry of Finance directs compliance with Article 7(1)(a) of Circular No. 157/2025/TT-BTC dated 31 December 2025. The second signatory on transaction documents must be the chief accountant, the accounting manager, or an authorized delegate. Appointing a person who does not meet these standards violates the Law on Accounting, and such a person does not have legal standing to register as the second signatory at the State Treasury.

The Ministry of Finance provides guidance on accounting for the 'Fund for the Poor' (Quy vi nguoi ngheo) at commune-level Vietnam Fatherland Front (MTTQ) committees under Circular No. 41/2022/TT-BTC. Two approaches apply depending on whether the unit maintains a separate accounting system for the fund. If the unit maintains a separate accounting system: use the account structure under Circular 41/2022, specifically Account 337 (earmarked contributions) and Account 511 (non-earmarked pooled contributions); do not use accounts under Circular No. 24/2024/TT-BTC. If no separate accounting is maintained: record fund activities within the entity's main books under Circular 24/2024, using Accounts 338, 512, or 711 as appropriate, and open separate sub-ledgers for the fund. In both cases, periodic income/expenditure reports must be prepared and financial information publicly disclosed in accordance with regulations.