Update on some amendments and additions to the accounting regime for small and medium enterprises

7/28/2025

On June 20, 2025, the Ministry of Finance issued Circular No. 46/2025/TT-BTC ("Circular 46"), which takes effect from July 1, 2025. This circular amends, supplements, and annuls certain circulars issued by the Minister of Finance in the fields of accounting and auditing. 

Accordingly, Circular 46 fully annuls Circular No. 70/2019/TT-BTC on guidelines for commune-level budget and financial accounting regime; it also amends, and supplements Circular No. 99/2018/TT-BTC, Circular No. 24/2024/TT-BTC, Circular No. 292/2016/TT-BTC, and Circular No. 150/2012/TT-BTC. Of particular significance, certain provisions of Circular No. 133/2016/TT-BTC (“Circular 133”)—which regulates the accounting regime for SMEs—have also been revised and supplemented under Circular 46. 

From July 1, 2025, Circular 46 amends and supplements Article 10 of Circular 133 regarding the registration of accounting method changes for SMEs as follows:  

  • Accounting documents and accounting books: Enterprises are permitted to amend or supplement accounting documents and accounting books templates from those provided in Appendix 3 and Appendix 4 of Circular 133 to align with their operations characteristics and management requirements. However, such amendents must comply with the Law on Accounting 2015 (Article 16 and Clauses 1 to 4 of Article 24), and must ensure that information is recorded in a complete, timely, truthful, and transparent manner to support the verification and reconciliation of the enterprise’s assets and capital. 
  • The system of accounting accounts: Enterprises shall apply the system of accounting accounts set forth in Appendix 1 enclosed with Circular 133 to record accounting books of economic transactions arising in the enterprise. 
  • Where necessary to suit the operations characteristics and management requirements, enterprises are permitted to amend and supplement the names, codes, structures, and contents reflected in the accounting accounts. However, such amendents and supplements must ensure classification and systematization of arising transactions according to their economic nature, avoid duplication of objects, comply with accounting principles prescribed by law, and must not change or affect the indicators and information presented in the financial statements. 
  • Financial statements: Enterprises shall apply the financial statements system prescribed in Appendix 2 enclosed with Circular 133 to prepare and present their financial statements. 

Where necessary to suit the operations characteristics and management requirements, enterprises are permitted to supplement indicators in the financial statements (“FS”) prescribed in Appendix 2 enclosed with Circular 133. However, such supplementation must comply with Article 29 of the Law on Accounting 2015 and adhere to the principles of preparation and presentation of FS as guided in the Circular. Those contents supplemented must be explained in the notes to FS. 

Note:  

  • In cases where enterprises make amendents or supplements to accounting voucher forms, accounting ledgers, accounting accounts, or add additionalindicators in the financial statements, the enterprises must issue an Accounting Policy Regulation regarding these amended or supplemented contents as the basis for implementation. 
  • In cases where enterprises have specific characteristics which prevent them from supplements or require amendments to the financial statement indicators as guided in Appendix 2 issued together with Circular 133, the enterprises must report to the Ministry of Finance to receive guidance on the preparation and presentation of financial statements.