Official Letter 66/QLKT-DN: combining 2025 financial statements and applying Circular 99

The Accounting and Auditing Management and Supervision Department (Ministry of Finance) has issued Official Letter 66/QLKT-DN on combining the 2025 financial statements of newly established enterprises. This guidance helps enterprises determine the correct accounting period and when to apply the new accounting regime.

The first accounting period and combining financial statements

Under Article 12 of the 2015 Accounting Law (as amended by Law No. 56/2024/QH15), the accounting period of a newly established entity is determined as follows:

• First annual accounting period: from the date the Enterprise Registration Certificate is issued to the last day of the annual accounting period (usually 31 December).
• Condition for combining: if the first annual accounting period is no longer than 03 months, it may be added to the next annual accounting period to form a single annual accounting period.
• Time limit: the combined first annual accounting period may not exceed 15 months.

Combining financial statements is therefore an option available to enterprises that meet the time condition, reducing paperwork for entities that operate for only a short time in their first year.

When Circular 99/2025/TT-BTC on the enterprise accounting regime applies

In Official Letter 66/QLKT-DN, the Department clarifies the effective date of Circular 99/2025/TT-BTC dated 27 October 2025:

• Effective date: the Circular takes effect from 1 January 2026.
• Scope: it applies to financial years beginning on or after 1 January 2026.

Note: enterprises may not apply Circular 99 to accounting periods or transactions before 1 January 2026, as there is no provision for retrospective or early application.

The specific case of an enterprise established in late 2025

For an enterprise established on 10 December 2025 (such as 42DOT Vietnam Co., Ltd.), the Department gave the following guidance:

Circular 99 cannot be applied for 2025

Because Circular 99/2025/TT-BTC only takes effect from 1 January 2026, there is no basis to apply it to the period from 10 December 2025 to 31 December 2025.

Combining the 2025 accounting period into 2026

• The period from 10 December 2025 to 31 December 2025 is less than 03 months, so it qualifies to be combined into the 2026 accounting period under the Accounting Law.
• However, if the enterprise chooses not to combine and keeps a separate first accounting period (covering only the days in December 2025), this is also fully consistent with the law.