Summary report on implementation of the 2015 Accounting Law (From 2017 to present)

Dear: ………………………………………………………..

Implement Resolution No. 30/NQ-CP promulgating the Government's action plan to implement Conclusion of the Fourth Conference of the 2030th Party Central Committee on accelerating the building and rectification of the Party and political system ; resolutely prevent, repel and strictly handle cadres and party members who have degraded in political ideology, morality, lifestyle, manifesting "self-evolution", "self-transformation" and accounting and auditing strategies. By 633, promulgated together with the Prime Minister's Decision No. 23/QD-TTg dated May 05, 2022, the Ministry of Finance is developing a plan to submit to the Government to report to the National Assembly for submission of the Law on Amendment and Supplementation. to add the Accounting Law to the National Assembly's 2024 law and ordinance-making program.

To have a basis for implementation, the Ministry of Finance has developed a draft report on summarizing the implementation of the Accounting Law, which summarizes and evaluates the implementation of the Accounting Law, identifies shortcomings, limitations, inadequacies in the implementation of the Law on Accounting, thereby proposing contents that need to be amended and supplemented in accordance with reality.

We request you to comment on the draft Summary Report on implementation of the above-mentioned Accounting Law, in which, you are requested to clearly state the shortcomings and problems of the unit and suggestions. specifically to amend and supplement.

Suggestions should be sent to the Ministry of Finance before September 06, 09 for synthesis.

For more information, please contact the Ministry of Finance (Department of Accounting and Auditing Management and Supervision) Mr. Phan Anh Quan – Tel 024.22202828 (8637); Ms. Tran Huyen Thanh – Tel 024.22202828 (8636).

Thank you very much for your cooperation.

Recipients:
- As above;
– Minister (for reporting);
- Legal services;
- Save VT, QLKT.

KT MINISTER
DEPUTY

Ta Anh Tuan 

LIST OF UNITS SENDING FOR COMMENTS SUMMARY ASSESSMENT OF ACCOUNTING LAW

I. MINISTERS AND SECTORS

1. Ministry of Defense

2. Ministry of Public Security

3. Ministry of Foreign Affairs

4. Ministry of Interior

5. Ministry of Justice

6. MPI

7. Ministry of Industry and Trade

8. Ministry of Agriculture

9. The Ministry of Transport

10. Ministry of Construction

11. Ministry of Natural Resources and Environment

12. Ministry of Information and Communication

13. Ministry of Labour, Invalids and Social Affairs

14. Ministry of Culture, Sports and Tourism

15. Ministry of Science and Technology

16. Ministry of Education and Training

17. Ministry of Health

18. State Bank

19. Government Inspector

20. Government Office

21. State Audit

22. State Capital Management Committee

II. LOCALITIES

63 provinces and centrally run cities.

III. UNIVERSITY, ACADEMY

1. Academy of Finance

2. National Economics University

3. Foreign Trade University

4. University of Commerce

REPORT

SUMMARY OF PRACTICE IMPLEMENTATION OF ACCOUNTING LAW 2015

(From 2017 to present)

The Law on Accounting 2015[1] took effect from 2017, has approached more general principles and practices of accounting, suitable to the conditions and circumstances of Vietnam; as a basis for the completion of a full legal framework on accounting in a closer approach to international practices, organize the preparation of national and local state financial statements, organize the implementation of audits. internal audit at enterprises, state agencies, non-business units; support and guide small and micro enterprises to carry out appropriate and effective accounting work.

Implement the Government's Action Plan in Resolution No. 30/NQ-CP dated 11/03/2022 of the Government, Accounting and Audit Strategy to 2030 issued together with Decision No. 633/QD-TTg dated on On May 23, 05, the Ministry of Finance reported to summarize the implementation of the Accounting Law in the period 2022 up to now, from which to propose additional and amended contents to implement the plan to develop the Draft Amendment Law. , supplementing the Law on Accounting 2017, as follows:

Part I

WORKING LEADING, INSTRUCTIONING, ORGANIZING IMPLEMENTATION OF ACCOUNTING LAW

1. Dissemination, propaganda, monitoring, urging, legal support, guidance to remove difficulties, obstacles and difficulties in the implementation of the Law on Accounting

Accounting Law No. 88/2015/QH13 was approved by the 10th National Assembly, 20th session on November 11, 2015, and took effect from January 01, 01. The Ministry of Finance has presided over and coordinated with relevant agencies and organizations to carry out propaganda and dissemination of the law on accounting to relevant businesses, organizations and individuals in various forms. such as: organizing conferences and seminars to disseminate legal documents; Post articles on mass media.

The Ministry of Finance also actively monitors the implementation of the Law on Accounting, promptly detects and receives feedbacks from accounting units to provide guidance on overcoming and solving problems and difficulties in accounting. Law enforcement practice. In addition, the Ministry of Finance has actively and proactively coordinated with other organizations and units in training and providing legal support for accounting units in complying with legal regulations on accounting. finance, budget, tax and other legislation. These activities have helped the Law on Accounting quickly take effect, come into life, and contribute to promoting the development of Vietnam's accounting field in particular and Vietnam's economy in general.

As for the accounting units, according to the provisions of the Law on Accounting, they all have an organization of their accounting apparatus, arrange for accountants, chief accountants or in charge of accounting, to advise and advise business leaders. businesses, agencies and units in the application and enforcement of the law. These contents are not only related to accounting, but also include other relevant contents such as regulations on budget, finance, tax; building internal processes and regulations; signing and performing the contract; tax declaration, insurance; making payments to partners, buyers, sellers, etc. Thereby, helping the accounting unit to fulfill its responsibilities and obligations towards the state, employees and related parties in accordance with the provisions of law. .

2. Directing and organizing the promulgation of documents detailing implementation guidelines

After the 2015 Accounting Law was promulgated, the Prime Minister signed and promulgated Decision No. 196/QD-TTg dated February 01, 02 promulgating the List and assigning the agency in charge of drafting the Government's documents. The Prime Minister shall detail the implementation of the Laws passed at the 2016th session of the XIII National Assembly, including the Law on Accounting. The organization and implementation of the Accounting Law was closely directed by the Government and the Ministry of Finance through the issuance of Decrees and Circulars guiding the implementation. Since the Law on Accounting was promulgated up to now, there have been many documents issued by the Government and the Ministry of Finance guiding the implementation, including 10 Decrees of the Government and 05 Circulars of the Ministry of Finance (Appendix 39). attach).

The above legal documents have covered quite comprehensively the legal issues in the field of accounting, are quite consistent with reality and have created a solid legal framework, contributing to promoting accounting activities. develop.

In general, documents guiding the implementation of the Accounting Law in detail were promulgated in a timely manner, ensuring the set schedule, creating a system of legal documents on accounting that was synchronous and consistent with other legal documents. other relevant laws. These documents, in addition to accounting objectives, also meet the objectives of simplifying administrative procedures, applying information technology, and reducing costs for accounting units and related parties. with the country's socio-economic development situation and international standards and practices. Thereby, contributing to bringing the Law on Accounting to life, ensuring consistency and efficiency in the application of the law in practice.

Part II

ASSESSMENT OF MAJOR RESULTS IN ACCOUNTING LAW IMPLEMENTATION

1. Overall rating

The promulgation of the Law on Accounting and its guiding documents over the past 6 years has created a legal basis for accounting to perform its role as an important economic management tool and the function of creating a business information system. economic - finance - budget serving the economic management and decisions of the State as well as of each unit, organization and enterprise. Since then, contributing to the successful implementation of key solutions to direct and administer the implementation of the socio-economic development plan according to the Socio-economic Development Strategy and the Government's Resolutions on the following tasks: services and solutions mainly directing the implementation of the socio-economic development plan.

The Accounting Law 2015 is a detailed law, inherited on the basis of the 2003 Accounting Law, with some amendments and supplements to a number of new contents to suit the actual conditions of the economy and society. The detailed provisions include general provisions; accounting work includes accounting vouchers, accounting accounts and accounting books, financial statements; accounting examination; inventory of assets, preservation and archiving of accounting documents; accounting work in case the accounting unit divides, separates, consolidates, merges, transforms its ownership type or form, dissolves, terminates its operation, goes bankrupt; organization of the accounting apparatus and accountants; business activities of accounting services; State management of accounting.

Accordingly, a number of contents in the 2015 Accounting Law have had quite basic innovations compared to the 2003 Accounting Law. For example, in the content of accounting principles, "fair value" was mentioned to create a basis. basis for the application of international financial reporting standards in enterprises; issue relevant accounting standards in this area including those for financial instruments, insurance contracts, fixed assets and investment property. In addition, the Accounting Law 2015 also has regulations on state financial statements and internal audit activities. These are new issues that have been guided and organized by the Government in the past time.

To implement the Law on Accounting, the Government has issued Decree No. 174/2016/ND-CP dated December 30, 12 of the Government detailing a number of articles of the Law on Accounting on the contents of accounting work, organization of the accounting apparatus and accountants, business of accounting services, provision of cross-border accounting services and professional organizations in accounting. These are necessary contents, which are assigned by the Law on Accounting to the Government for guidance to ensure sufficient grounds for implementation.

In addition, the Government issued Decree No. 41/2018/ND-CP dated March 12, 3 on sanctioning of administrative violations in the field of accounting - independent audit, providing regulations on administrative violations. , sanctioning statute of limitations, sanctioning forms, sanctioning levels, remedial measures, competence to make minutes and competence to sanction administrative violations in the field of independent accounting and auditing.

2. Evaluation of the implementation of a number of specific provisions in the Law on Accounting

2.1. About the content of accounting work

Contents of accounting work include activities of organizing and collecting accounting information according to accounting documents; organize classification and record on the accounting database of the unit according to the system of accounts and accounting books; organizations provide information according to the forms of financial statements and settlement reports. The accounting regimes have fully regulated the contents of accounting work applicable to each type of unit in the field of corporate accounting and state accounting. Accordingly, the accounting units shall implement the prescribed accounting regimes and strictly comply with the provisions of the Accounting Law on accounting vouchers, accounting accounts, accounting books and financial statements.

In the field of corporate accounting, the Ministry of Finance has issued Circulars guiding the general accounting regime for units of different types and sizes. These regulations are consistent with the system of 26 Vietnamese accounting standards issued by the Ministry of Finance. Currently, the Ministry of Finance is implementing a draft of the corporate accounting regime, with additional and revised contents in line with practice and management requirements.

In the field of state accounting, the state accounting units shall follow the prescribed accounting regime suitable to each field, such as the administrative and non-business accounting system, the accounting regime applicable to the management board. public investment project management, state budget accounting regime and state treasury professional activities, domestic tax accounting regime, accounting regime for tax collection and other collection of imported and exported goods, public debt accounting regime, accounting regimes for social insurance, health insurance, etc. These accounting regimes guide units in the field of state accounting to prepare their financial statements in accordance with the provisions of the Law on Accounting.

2.2. About the accounting inspection

The Accounting Law specifically stipulates the competent authorities to inspect the accounting work, covering all units from central to local. In addition, the contents of accounting inspection, accounting inspection time, rights and responsibilities of accounting inspection teams, rights and responsibilities of accounting units subject to accounting inspection are also regulated. These regulations are the basis for the ministries, branches and localities to organize the accounting inspection in accordance with the operation organization, apparatus and management requirements of their units.

In the field of corporate accounting, the inspection and supervision of the implementation of accounting standards and regimes at enterprises in order to innovate and improve the efficiency of business operations, serve the management and supervision of enterprises. financial supervision, state capital investment in enterprises. The supervision is also through the activities of auditing financial statements, analyzing, evaluating, classifying enterprises, inspecting, examining and monitoring the implementation of financial mechanisms and policies of enterprises, and publicizing them. disclosure of information on business results and financial position of the enterprise... is maintained effectively. The requirements on inspection, supervision of law enforcement, accounting regime and accounting inspection shall comply with the provisions of the Law on Accounting, Decree No. 174/2016/ND-CP guiding the Law on Accounting. and guiding circulars of the Ministry of Finance. Agencies competent to inspect accounting such as inspection agencies, state audits, etc. directly carry out the inspection and supervision of the implementation of the provisions of the law on accounting.

In the field of state accounting, the requirements for law enforcement inspection, supervision, accounting regime and accounting inspection are complied with the provisions of the Law on Accounting, Decree No. 174/2016/ND -CP, accounting regimes that the entity is the subject to apply. Currently, the supervision of the implementation of the provisions of the law on accounting at state accounting units is carried out directly by agencies competent to inspect accounting such as inspection agencies, state audits, etc. perform. In addition, state budget-using units also organize self-inspection under the guidance of the Minister of Finance's Decision No. 67/2004/QD-BTC dated August 13, 8 on the promulgation of the Regulations. financial and accounting self-inspection at agencies and units funded by the state budget.

2.3. Regarding inventory of assets, preservation and archiving of accounting documents

The Law on Accounting stipulates the cases in which an inventory of assets is required, the main contents of the preservation and storage of accounting documents, including the time limit for document storage, the responsibilities of the accounting unit in case of Accounting documents are lost or destroyed.

Specific contents on preservation and archiving of accounting documents are specified in Decree No. 174/2016/ND-CP dated December 30, 12 of the Government detailing a number of articles of the Law on Accounting, serve as a basis for implementing units for paper-based documents and documents in the form of electronic data.

2.4. Regarding accounting work in case the accounting unit divides, separates, merges, merges, transforms its ownership type or form, dissolves, terminates its operation, goes bankrupt

The Law on Accounting clearly stipulates the content of work in specific cases, serving as a basis for organizational units to perform when activities arise. When actual cases arise, the units, based on the provisions of the Law on Accounting, have organized the accounting work, implemented the financial plans, completed the relevant documents to perform the accounting work. currently terminates operations at the old units and organizes operations at new units in accordance with the law.

2.5. About the organization of the accounting apparatus and accountants

The Law on Accounting clearly stipulates that an accounting unit must organize an accounting apparatus, arrange an accountant or hire an accounting service; The organization of the apparatus, arrangement of accountants, chief accountants, in charge of accounting or hiring services to act as accountants or chief accountants shall comply with the Government's regulations. For the legal representative, the Law also stipulates the responsibility to organize the accounting apparatus, arrange the accountant or decide to hire an accounting service business or a household to provide accounting services in accordance with the law. provisions of the Law on Accounting. Based on these regulations, the accounting units must organize their accounting apparatus and arrange the head of the accounting apparatus according to the standards and conditions prescribed in the Law on Accounting.

In addition, the Law also stipulates that an accounting unit may sign a contract with an accounting service enterprise or a household providing accounting services to hire accounting services or chief accountant services as prescribed by law. the law.

2.6. About the business of accounting services
The Accounting Law 2015 has shown the contents of accounting services in terms of integration. With the goal of economic integration in general and the accounting field in particular, the provisions of the Law are basically relatively complete and clear, creating favorable conditions for the formation and development of businesses. providing accounting services. With the implementation of the Law on Accounting, Vietnam's accounting service market has achieved remarkable results, gradually meeting the practical requirements of the economy and society.

However, it can be assessed that the number of accounting service enterprises registered for business operation is still limited, and the scale is still quite small. Although newly established businesses increase year by year[2], the number of new customers only reached 10.970 in 2020, an increase of 48% compared to 2019.

2.7. About state management activities

The Law on Accounting stipulates that the Government shall perform the unified state management of accounting. The Ministry of Finance is responsible before the Government for performing the state management of accounting, has the tasks and powers to formulate and submit to the Government for decision accounting development strategies and policies; elaborate and submit to the Government for promulgation or promulgate according to its competence legal documents on accounting; issue, re-issue and revoke the Certificate of registration for accounting service practice and the Certificate of eligibility for accounting service business; suspension of accounting service practice and accounting service business suspension; stipulating the examination, granting, revocation and management of accountant certificates; accounting examination; checking accounting service activities; supervising the compliance with accounting standards and accounting regimes; regulations on updating knowledge for practicing accountants; organize and manage scientific research on accounting and application of information technology in accounting activities; inspect, examine, settle complaints and denunciations and handle violations of the law on accounting;

Ministries and ministerial-level agencies shall, within the ambit of their tasks and powers, coordinate with the Ministry of Finance in performing the state management of accounting in their assigned sectors and fields.

Provincial-level People's Committees, within the ambit of their tasks and powers, are responsible for the state management of accounting in their respective localities.

With the above regulations, the coordination between the Ministry of Finance and related units is not really effective, regular and continuous. Therefore, it is necessary to study solutions to better coordinate the work of ministries, ministerial-level agencies with the Ministry of Finance in accordance with the tasks and powers of each unit as prescribed by law.

2.8. About the system of accounting standards

a) Regarding corporate accounting standards, during the period from 2000 to 2005, the Ministry of Finance issued 26 corporate accounting standards. The system of 26 accounting standards and accounting regimes, which are applicable to all businesses in all fields and economic sectors operating in the territory of Vietnam, has made a significant contribution to the governance of Vietnam. , management of enterprises, reflecting many transactions of the market economy, in accordance with the management requirements of the State in the period of reform and world economic integration.

However, in the period 2011-2020, these standards have not been fully updated and promulgated in comparison with international standards. Therefore, before the requirements of the social economy, economic integration and the development of information technology, on March 16, 3, with the consent of the Prime Minister, the Minister of Finance. issued Decision No. 2020/QD-BTC approving the Scheme on application of financial reporting standards in Vietnam, including the following 345 objectives:

– Develop plans, roadmaps and publish, support the application of international financial reporting standards (IFRS) in Vietnam for each specific target group identified, in accordance with international practices in order to purpose of improving the transparency and honesty of financial statements, enhancing the accountability of enterprises to users of financial statements.

– Newly promulgate and organize the implementation of the Vietnamese Financial Reporting Standards System (VFRS) according to the principle of maximum absorption of international practices, in accordance with the characteristics of the Vietnamese economy and the needs of enterprises. to ensure feasibility in the implementation process.

b) Regarding public accounting standards, on July 31, 7, the Minister of Finance issued Decision No. 2019/QD-BTC approving the Scheme on building and announcing public accounting standards in Vietnam, include the following goals:

– Researching, developing, promulgating and publishing the Vietnam Public Accounting Standards System (VPSAS) on the basis of International Public Accounting Standards. Vietnam's public accounting standards system applied to public sector accounting units must ensure the country's economic integration requirements; synchronized with the reform and renewal of economic management policies and public financial management policies of Vietnam; is the basis for providing timely and honest financial information in order to improve the capacity, efficiency, publicity and transparency in the management of the Government's resources.

– The research, development and publication of the Vietnamese public accounting standard system in association with the implementation of the project on building a model for making state financial statements; serve as the basis and foundation for the system of State financial mechanisms and policies with a system of relevant legal documents such as the Law on State Budget; Law on Management and Use of Public Property; Law on Public Debt Management; Law on management and use of state capital invested in production and business in enterprises; The Law on Securities… has been reformed in accordance with international standards and practices.

Vietnam's public accounting standards system is the basis for promulgating a system of specific guiding accounting regimes suitable for each type of unit, characteristics of organization and operation, in a relationship appropriate to other accounting regimes. policy on public finance and state budget.

According to the roadmap of the Project on Public Accounting Standards of Vietnam, from 2020 to 2024, 21 Vietnamese public accounting standards will be issued and announced. Implementing the plan of the Project, by July 7, the Minister of Finance has issued a Decision to announce 2022 Vietnamese public accounting standards.

2.9. About state financial statements
Implementing the Law on Accounting, the Ministry of Finance has developed the Government's Decree and guiding documents for the preparation of state financial statements on the basis of summarizing financial statements of state agencies, public non-business units. financial institutions, economic organizations and other relevant entities in the state sector from fiscal 2018. This report is used to summarize and explain the state's financial situation, the results of state financial activities. and cash flows from state financial activities on a national and local scale.

Basically, the state financial statements have provided information on the state budget revenue and expenditure, state financial funds, public debt, state capital at enterprises, assets, capital sources and use of state budget. using state capital. However, it is also necessary to complete the information of the state financial statements in a more complete and accurate direction.

2.10. About internal audit

Article 39 of the Law on Accounting provides for internal control and internal audit, in which the Government is assigned to provide detailed regulations on internal audit in enterprises, state agencies and non-business units. To fulfill this requirement, the Government issued Decree No. 05/2019/ND-CP dated January 22, 01 of the Government providing for internal audit at ministries and ministerial-level agencies under the Government; People's Committees of provinces and centrally run cities; eligible large-scale public non-business units and enterprises according to the principle of professional independence and efficiency, suitable to the organization and operation of each unit. The Ministry of Finance has also issued Circulars guiding internal audit standards and model regulations on internal audit for units.

The regulated entities need to organize an internal audit department to: Check the suitability, effectiveness and efficiency of the internal control system; Check and confirm the quality and reliability of economic and financial information of financial statements and management accounting reports before submitting them for approval; Inspecting compliance with operating principles, management, compliance with laws, financial and accounting regimes, policies, resolutions and decisions of the leadership of the accounting unit; Detect loopholes, weaknesses, frauds in the management and protection of assets of the unit; propose solutions to improve and complete the system of management and operation of the accounting unit.

2.11. About the activities of professional organizations
Currently, there are two professional organizations in accounting and auditing, namely the Vietnam Association of Accountants and Auditors (VAA) and the Vietnam Association of Certified Public Accountants (VACPA). Members of both these professional organizations are accountants and auditors at agencies, units, organizations and enterprises in Vietnam. Voluntary, not mandatory.

Professional organizations are important bridges between State agencies, enterprises and society; perform the function of social criticism, participate in the development of legal documents reflecting inadequacies and obstacles in law enforcement. Through the activities of professional organizations, the functions and tasks of State management and professional management activities have also been formed and distinguished more clearly. This is an objective reality, derived from international practices and the necessity of the renovation, opening up and international integration for the accounting field in Vietnam.

In recent years, the Ministry of Finance has strengthened the state management of accounting on the basis of renovating the operating mechanism and at the same time improving the quality of professional management in line with international practices. Maintain close cooperation between state management agencies and professional organizations in order to strengthen the supervision of the quality of accounting practice, ensure that the practice complies with the provisions of the law, improve the quality of accounting practice. The quality of accounting service practitioners is on par with developed countries in the region and the world.

2.12. About accounting human resources
Trained, built and developed a team of accountants in the fields of state accounting, corporate accounting; a team of auditors and practicing accountants with professional qualifications, good ethics and professional responsibility. For accounting personnel in the public sector, in addition to meeting the general criteria in the field of accounting, they must also master the regulations on specific financial mechanisms in the public finance sector, regulations on managing the domestic state budget, loans, aid, public investment, etc.

Regularly innovate accounting training methods and programs at training institutions; renovating regulations and methods of organizing accountant exams. Organize knowledge training for officials and accountants; Update knowledge for accountants. Additional resources every year from accounting training institutions, universities and colleges have a large number and good quality, trained with programs increasingly associated with practical requirements.

The number of people with accountant certificates as of December 12 is 2021 people, of which 1.091 people are working in accounting service businesses (accounting for 419% of people with accountant certificates). .

All accountants have bachelor's degree in finance, accounting-auditing, banking, etc., have at least 3 years of practical experience and have passed the national exam to be licensed. Certificate of Accountant, Auditor. With working experience and passing exams to get certification, practicing accountants have general knowledge about economic law, corporate finance, tax policy, accounting - auditing. When registering to practice accounting, in order to ensure the quality of services provided, accountants must update their knowledge annually according to the prescribed time every year.

2.13. About international cooperation in the field of accounting
After more than 20 years of integration in the accounting field, Vietnam has made fundamental changes in the provisions of the legal framework, aiming for the development of the accounting-audit profession and services. In practice, Vietnam has had relations and cooperation with international accounting organizations and countries through the activities of signing agreements in WTO Agreements, Agreements with ASEAN; join the Coordinating Committee on ASEAN Standards Professional Accountants; participating as a member of the ASEAN Federation of Accountants (AFA), Asia - Pacific (CAPA), the world (IFAC).

The Ministry of Finance and professional organizations regularly participate in international and regional conferences and seminars on accounting; participating in the signing of a mutual recognition agreement on ASEAN accounting services; participate in the United Nations Annual Conference on Trade and Investment (UNTAC) in Switzerland; member of the Asia-Oceania Accounting Standards Group (AOSSG).

Maintain activities to promote cooperation with international professional organizations operating in Vietnam such as: ACCA, CPA Australia, ICAEW; The World Bank (WB), Asian Development Bank (ADB), Japan International Cooperation Agency (JICA)… to support and promote the development of accounting activities. Join the Emerging Economy Group (EEG) conference.

2.14. About the application of information technology and other activities
At units, organizations and enterprises, the application of information technology in management activities and organization of accounting work has been implemented, in line with the development of the 4.0 technology revolution. .

At state management agencies, state budget revenue and expenditure units have implemented administrative reform in a substantive manner with specific and practical solutions; deploy and apply online public services for administrative procedures in the accounting field at the highest level in accordance with the permitted conditions; building and synthesizing information and data to publicize information on accounting practice to serve the needs of organizations and individuals.

At units, organizations, training institutions and professional organizations, apply technology in research and training activities; accelerate the digitization process towards digital transformation activities in the field of accounting appropriately and effectively.

Part III

LIMITATIONS AND INadequacies in IMPLEMENTATION OF ACCOUNTING LAW

1. The provisions of the Law on Accounting have lags compared to reality

– The operating environment related to accounting in Vietnam is always changing. The market opening and international integration require timely adjustment of financial and accounting mechanisms and policies; suitable for all economic sectors, including enterprises with 100% foreign capital, branches of foreign enterprises in Vietnam; international integration commitments are more and more extensive, the activities of enterprises are expanded abroad. Therefore, it is required that accounting regulations are more and more close to international practices and standards.

– The scope and subjects of accounting activities are very wide, including units in the public sector, the corporate sector, with different sizes, characteristics of organization and operation, and the degree of state ownership of capital. Therefore, some regulations need to be covered and reasonably guaranteed. In some cases, it is necessary to have more specific regulations to avoid obstacles in the implementation organization. These provisions can be stated in the guiding documents of the Law, however, the Law on Accounting needs to have relevant provisions appropriately. For example, regulations on the organization of the accounting apparatus, titles on accountants, including chief accountants, the relationship between the head of accounting and the leadership and related departments at the unit. problems have arisen, there should be principled regulations for implementation.

– The sense of responsibility, the sense of law compliance of the units, the heads of the accounting units, the people doing the accounting work in the units are not strict, leading to the acts of non-compliance with regulations. on financial and accounting management, there are violations that need to be handled. Errors can arise from subjective and objective reasons, the expression of responsibility for accounting work leads to the quality of financial statements not meeting the requirements, even errors from the subjective reasons of the accounting unit itself and the head of the accounting unit. Some accounting units want to have “beautiful” financial statements to fulfill different purposes. Therefore, many units have intentionally violated the provisions of accounting standards and accounting regimes when preparing and presenting financial statements, resulting in financial statements that do not accurately reflect the financial position of the entity, with information dishonest or concealed.

– The legal framework related to accounting, in different fields, still has certain differences, some points are not synchronized due to requirements and nature of management activities. Differences in mechanisms and policies related to tax policy or other regulations lead to the fact that the units seem to be only interested and focused on complying with tax policies and completing the procedures for implementation. tax obligations, do not pay much attention to complying with regulations of accountants to provide financial information of the entity in accordance with the provisions of the Law on Accounting and accounting standards.

– The technological revolution along with the requirements of the digitization process, especially the digital transformation process, leads to the accounting regulations in the current Accounting Law not keeping up with reality. The units reported problems in signing vouchers, rotating and processing documents, storing accounting documents, etc. Although economic transactions on electronic means are now carried out according to regulations. The provisions of the Law on Electronic Transactions and other specialized laws, however, within the scope of the Accounting Law, there should also be provisions to clarify and synchronize with the Law on Electronic Transactions and other legal regulations. other relevant and relevant to the digital transformation process.

– The current accounting software is developed quite diversely, with different quality, the reason comes from the experience and ability of the accounting software supplier; derived from the ability to grasp and provide technical requirements of the accounting unit to the software supplier, from the understanding and use of applications by the accounting team, employees of the units. accountant. This fact requires appropriate regulations to ensure the quality of accounting software and system applications that accounting units use in accounting work and unit management.

2. Some provisions of the Law on Accounting have revealed shortcomings and shortcomings

Although the above important results have been achieved, the Accounting Law 2015, or more broadly, accounting work in Vietnam still has certain difficulties and limitations, namely:

– The Accounting Law stipulates that assets and liabilities are initially recognized at cost. After initial recognition, for certain classes of assets or liabilities whose values ​​are subject to frequent fluctuations in market prices and whose amounts can be reliably re-determined, they are recognized at cost. fair value at the end of the financial reporting period. This is a regulation to be in line with international practices, to fully reflect the value of assets and liabilities. However, in practice, there are still many obstacles for the organization to implement, whereby relevant conditions need to be clearly defined in order to be able to realize fair value recognition.

Regarding the accounting regime, according to the Law on Accounting, the Ministry of Finance is the agency responsible to the Government for performing the state management of accounting, thereby having the power to issue Circulars and guiding documents to the Government. as a specialized state management agency providing guidance. However, in practice, the credit institution system still applies its own accounting system, with the contents not being updated in a timely manner. Considering the nature of operations of credit institutions, which are also enterprises with the purpose of doing business in the field of money and credit, they can be classified as corporate accounting, but they also have their own characteristics due to characteristics of this organization. The unification of the accounting regime is essential, including such contents as accounting vouchers, system of accounting accounts, accounting books and financial statements. Therefore, this content needs to be studied and considered to have a consistent and appropriate regulation.

- A number of regulations on the content of accounting work, from the stage of vouchers, accounts, accounting books, financial statements, management reports, need to be reviewed and evaluated for appropriate regulations. For example, for financial reporting regulations, regulations on the content, form and time limit for disclosing financial statements also lead to different interpretations in the implementation process, leading to some cases of non-implementation. presently; Information needs also differ in their access to public information about financial statements.

– The process of digitization and digital transformation and modernization of information technology in the field of accounting requires not only the application of accounting units, but also the amendment and supplementation of legal regulations on accounting. accounting suitable for the electronic environment. For example, regulations on signatures, regulations on accounting records, on printing and storing electronic documents, printing and keeping accounting books should be consistent, in order to save money and avoid waste in printing. press but must be effective, safe.

- Regulations on accounting units, organization of accounting apparatus, standards and conditions of accountants, standards and conditions of chief accountants have arisen problems in practice. For example, for state accounting units, the arrangement of separate accounting departments, or belonging to departments/divisions, the organization of dependent accounting units, accounting units reporting books, etc., always encounter problems. problems regarding functions and tasks, the principle of non-duality, and authorization to perform accounting work.

– The Accounting Law 2015 stipulates the conditions for doing business in accounting services and the organization method in order to develop and improve service quality. However, in fact, there are still shortcomings in the business activities of service enterprises, in business registration and accounting service practice. Therefore, although the service market has developed, it has not yet met the expectations and requirements of reality. In addition, the regulations on the responsibilities of service providers and service providers also need to be clarified, especially when customer units develop both in size and quantity. In addition, the provisions related to this content in other legal documents also lead to inconsistency in implementation.

- Professional organizations in accounting are clearly defined in the Law on Accounting. Accordingly, professional accounting organizations are established and operate in accordance with the law on associations and are responsible for complying with the provisions of the law on accounting. Professional accounting organizations are provided with training and knowledge updates for accountants and practicing accountants and perform a number of tasks related to accounting activities prescribed by the Government. However, professional organizations have not yet developed into self-governing organizations, accounting professional activities like in other countries around the world, showing an important role, and coordinating with state management agencies in building up the accounting profession. accounting standards and participate in supervising the quality of accounting services of practicing accountants.

The quality of accounting work is also a matter of concern. In the past time, especially before the Law on Accounting was promulgated and the accounting regimes and standards were guided, the quality of accounting work was appreciated. interested in the work of accounting organization, professional accounting, statistical accounting, financial accounting; however, the quality of accounting has not yet met the requirements of management and the requirements of the society, the accounting manifestations of dishonesty and fraud have occurred and the legal authorities have handled it; financial statements are not timely and unreliable. The reason for the above existence comes from the compliance with the law, it is necessary to be fully guided and have strict sanctions when there is a violation.

3. Relevant legal regulations have changed

– Law on Tax Administration No. 38/2019/QH14 passed by the National Assembly on June 13, 6, effective from July 2019, 01, providing for the application of electronic invoices and documents. The basic content is stipulating that businesses must use electronic invoices in transactions of selling goods and providing services to contribute to overcoming frauds in the use of paper invoices, reducing costs for taxpayers. tax, improving the competitiveness of the whole economy, building a database of invoices, serving the development of electronic tax management. Regulations on principles of making, managing and using invoices; apply invoices when selling goods or providing services; database of e-invoices, electronic documents...

The above regulations take effect from July 01, 7; Accordingly, agencies, organizations and individuals are encouraged to apply the regulations on electronic invoices and documents of this Law before July 2022, 01. Pursuant to the provisions of the Law on Tax Administration No. 7/2022/QH38 and relevant legal documents (Law on Value Added Tax, Law on Accounting, Law on Electronic Transactions, Law on Information Technology), the Government issued Decree No. 2019/14/ND- CP dated October 123, 2020 regulates invoices and documents; The Ministry of Finance issued Circular No. 19/10/TT-BTC dated September 2020, 78 guiding the implementation of a number of articles of the Law on Tax Administration dated June 2021, 17, Decree No. 9/2021/ND- The Government's CP dated October 13, 6 stipulates invoices and documents. Accordingly, it has created a full legal basis for the deployment of e-invoices and documents nationwide, ensuring that by July 2019, 123, the application of e-invoices is deployed nationwide.

– The Law on Tax Administration has contents that are not consistent with the Law on Accounting in terms of signing on financial statements. According to the Law on Accounting, the preparer, chief accountant and legal representative must sign on the financial statements of the enterprise. However, the financial statements of the enterprise when submitted to the tax authority on the declaration system are only required to be digitally signed by the legal representative, not required to be signed by the accountant/chief accountant. This leads to inconsistency between the Law on Accounting and the Law on Tax Administration regarding the signing of financial statements of enterprises.

– The Law on Tax Administration stipulates the conditions for providing accounting services to micro enterprises, whereby Article 150 is supplemented with Article 70a of the Law on Accounting, which stipulates that organizations providing tax procedures services are provided. accounting services for micro enterprises when at least 1 person has an accountant certificate. Meanwhile, the Law on Accounting requires accounting service enterprises to have at least 02 practicing accountants with the capital contribution ratio must account for at least 50% of the charter capital, the capital of the organization must account for a maximum of 35%. and must be granted a certificate of eligibility for accounting services business to be able to provide accounting services. practice registration, service provision dossiers, notification and reporting obligations, etc. In addition, 02 practicing accountants are persons who are granted accounting practice registration certificates together with the procedures. and tight conditions. However, for a tax agent, only 1 person is required to have an accountant certificate, there is no need to register to be granted a certificate of registration to practice accounting services like an accountant practicing in an accounting service enterprise. Without paying certification fees, without having to comply with regulations on notification and reporting obligations, local tax authorities will inspect tax agents like when inspecting taxpayers, etc. .

The above-mentioned problems need to be studied to ensure uniform and uniform regulations on accounting practice licenses and business in the direction of ensuring the similarity in requirements, procedures, obligations... of the application. accounting service provider.

Part IV

PROPOSED MODIFICATIONS AND SUPPLEMENTS

1. Perspectives, goals

1.1. Perspective

- Identify accounting as an important management tool in the new development period of the country's socio-economic development. From there, it is necessary to fully create and improve the quality of accounting information, so that accounting is really an important economic management tool in creating an information system for operating and making business decisions. economy of the State as well as of each enterprise, unit and organization.

– It is necessary to clearly define short-term and long-term goals, systematically establish synchronous solutions to further improve the legal framework on accounting, apply a system of standards and professional methods. services in accordance with international practices with an appropriate roadmap; strengthen the inspection and supervision of accounting activities to ensure compliance with the law on accounting; improve the quality of training and retraining of human resources; develop and enhance the status of professional organizations; application of information technology in the management and implementation of legal regulations on accounting.

– Attention should be paid to strengthening and enhancing the role and capacity of state management agencies and professional organizations in planning the legal framework, organizing the implementation, and inspecting and monitoring the legal framework. Compliance with accounting laws.

– Developing international integration activities, with the implementation of international practices to improve the quality of accounting information, contributing to improving competitiveness and meeting the requirements of international integration.

– It is necessary to realize that the development and improvement of accounting processes and techniques need to be suitable for the application of information technology, in accordance with the digital transformation process and the professional qualifications and skills of human resources. in units and organizations. Accordingly, it is necessary to have appropriate solutions, adapting to the digital transformation process, associated with digitizing activities to reform processes and reform related administrative procedures towards the goal of digital finance.

1.2. Goals

– Complete the legal system on accounting fully, comprehensively and synchronously, in line with international practices and conditions of Vietnam, in order to strengthen the roles and responsibilities of enterprises and units. organizations and individuals in improving the quality of operations, providing accounting information for management, administration, decision-making and determining obligations of agencies, enterprises and organizations.

– Develop a legal framework to apply international financial reporting standards (IFRS) and update Vietnam's financial reporting standards system (VFRS) on the basis of international practices suitable to the market economy. Vietnamese schools; ensure the comparability of economic and financial information of enterprises and organizations in the economy; serve to attract capital from domestic and foreign investors. Announce the Vietnamese public accounting standard system on the basis of international public accounting standards, deploy and apply in accordance with the laws of Vietnam.

- Develop a mechanism suitable to the characteristics of the field of activity in order to:

+ Strengthen the operational capacity of accounting management and supervision agencies. Improve the efficiency of management and supervision of accounting activities at enterprises, accounting units and enterprises providing accounting services.

+ Strengthen inspection and supervision activities and have appropriate sanctions to ensure the compliance with the law of accounting units and accounting service providers in order to improve the quality of financial statements. main and accounting services.

– Developing markets, improving quality and diversifying accounting products and services; restructuring the demand and supply of accounting services in accordance with the law and the needs of the economy - society. Improve the quality and quantity of a team of experts and accountants to provide high quality services; Deploying and expanding the activities of providing accounting services to foreign markets.

- Developing accounting human resources in terms of quantity and quality to meet actual requirements; Renovate the content, programs and methods of training and fostering human resources, combining theory and practice, associated with the process of digitization and digital transformation in accounting. Renovate the process and method of granting professional certificates and practice certificates in accordance with international practices and Vietnam's conditions. There are support solutions to improve the qualifications and professional activities of the accounting team working in small, medium and micro enterprises.

- Promote the role, unify and strengthen the operational capacity of professional organizations in accounting, in the development of legal documents; professional training and retraining; coordinate in inspecting and supervising the compliance with the provisions of professional standards.

- Deeply develop international integration activities, expand cooperation with international organizations on accounting; learning experiences to develop Vietnam's accounting system; improve the position and performance of Vietnamese accountants in the world and in the region.

– Promote the application of information technology in line with the digital transformation process in building the legal framework and organizing the implementation at the units; building a database related to accounting to serve the operations of the units and activities of accounting management and supervision.

2. Proposing specific contents to be adjusted in the Law on Accounting

2.1. Reviewing regulations to match the process of digitization and digital transformation in accounting

Current regulations on vouchers, accounting books, financial statements and other accounting documents are mainly oriented towards paper-based regulations, while additional regulations for electronic transactions are required. Therefore, the regulations on electronic accounting vouchers, making and storing accounting vouchers, signing accounting vouchers should be mainly regulated in the electronic aspect. Cases made on paper are regulated in the direction of more regulation because they arise little and tend to continue to decrease with the digital transformation. The goal to be achieved is to help units have the basis to implement, process and store information on applications, limit the printing and converting of accounting documents and documents to vouchers and documents on the Internet. waste paper.

Regulations on accounting vouchers and accounting books are developed for manual and paper-based accounting activities. For example, when writing a voucher, a pen and ink must be used, numbers and letters must be continuous, without interruption, blank spaces must be crossed, and vouchers must have sufficient numbers of copies as prescribed; sign vouchers with indelible ink, signatures on vouchers of 1 person must be consistent, stamped on the accounting books, accounting books must be written in pen and ink; do not intersperse above or below; do not overlap; no line spacing; in case the page is not fully written, the unwritten part must be crossed out; When the page is finished, add the total data of the page and transfer the total data to the next page…. The regulations on accounting on computers and electronic data are only supplemented, so they are not complete and comprehensive.

Regarding the storage term, the Law on Accounting (Article 41) stipulates the preservation and archiving of accounting documents[3]. In fact, there are accounting documents that are prescribed with an archival period of 5 years, 10 years, but these documents are the basis for making as well as related to the permanent archival accounting documents. Therefore, the above regulation will make it difficult to determine the destruction of accounting documents with different retention periods in the same set of records. This problem is even more difficult when storing on the machine, when the data has a relationship with each other, forming a database, the destruction of accounting documents will affect all data. of the unit.

To meet the requirements of digitization and digital transformation, a number of provisions in the Law on Accounting need to be studied and revised as follows:

- Reviewing regulations on accounting vouchers and accounting books, correcting accounting errors that are not suitable with the current reality of information technology application, need to be revised accordingly.

– Review the regulations on signatures on accounting vouchers (sign all documents with blue ink), accounting documents and other relevant contents, to make amendments suitable for the creation of documents. , transfer, process and store by electronic means, icloud…

– Reviewing regulations related to economic transactions in the electronic environment, practical application of information technology and digital technology in economic transactions, reality of the implementation of regulations on transactions electronic. These contents need to be suitable and synchronized with the implementation of e-invoices nationwide.

2.2. About corporate accounting standards

The Accounting Law 2015 (Article 7) assigns the Ministry of Finance to prescribe accounting standards and professional ethical standards for accounting on the basis of international accounting standards suitable to Vietnam's conditions. In fact, the Ministry of Finance has issued 26 corporate accounting standards, along with accounting regimes applicable to all businesses of all fields and economic sectors operating in the territory of Vietnam. However, in the period 2011-2020, these standards have not been fully updated and promulgated. Therefore, in response to the requirements of the socio-economic, economic integration and the development of information technology, after reporting to the Prime Minister, on March 16, 3, the Minister of Finance issued a Decision No. 2020/QD-BTC approving the Scheme on application of financial reporting standards in Vietnam.

The plan to implement accounting standards is long-term, so the Law on Accounting may need to have clearer provisions on allowing enterprises in Vietnam to apply international financial reporting standards under the guidance of the Ministry of Finance. Finance. In addition, it is possible to consider the establishment of an accounting standards committee under the Ministry of Finance, clearly defining the authority for this committee in the direction of members appointed by the Ministry of Finance but having the power to make independent decisions on expertise. subjects, activities and decision-making on a collective basis….

2.3. About the currency in accounting

The Law on Accounting (Article 10) stipulates that “The monetary unit used in accounting is Vietnam Dong, the national symbol is “d”, the international symbol is “VND”. In case economic and financial transactions are denominated in foreign currencies, the accounting units must record in the original currency and Vietnam Dong at the actual exchange rate, unless otherwise provided for by law; for a foreign currency that does not have an exchange rate with Vietnam Dong, it must be converted through a foreign currency having an exchange rate with Vietnam Dong. An accounting unit that mainly collects and spends in a foreign currency may choose such foreign currency as its own currency for accounting, take responsibility before law and notify the tax authority directly managing it. When preparing financial statements for use in Vietnam, the accounting unit must convert into Vietnam Dong at the actual exchange rate, unless otherwise provided for by law.

In fact, there have been problems when implementing the above regulations, because in fact, in case the enterprise has a functional currency other than VND, the entity must use the functional currency according to accounting standards. maths. The regulation that the unit can choose an accounting unit is VND as in the current Accounting Law which is not consistent with accounting standards, in fact has caused difficulties for units and enterprises. Therefore, it is necessary to study and clearly define the functional currency and the reporting currency.

2.4. About numerals used in accounting

The Law on Accounting (Article 11) stipulates that after the digits thousands, millions and billions, a period (.); When writing digits after the unit digit, a comma (,) must be placed after the unit digit. This regulation is not suitable with the current reality of information technology application, arising right in the production environment of application systems, causing difficulties for accounting work, especially for application units. using accounting software provided by foreign countries. In this case, the units have to re-configure the system, which increases the cost, but reduces the performance of the system because it has to be converted according to Vietnam's regulations.

Therefore, this content needs to study the appropriate regulations to meet the requirements of digitization and digital transformation in the accounting field. Accordingly, there should be flexible regulations in line with international practices, however, it is necessary to pay attention to the content of transitional regulations in the implementation organization.

2.5. About translating vouchers, accounting documents

The Law on Accounting (Article 11) stipulates that the script used in accounting is Vietnamese. In case a foreign language must be used on accounting vouchers, accounting books and financial statements in Vietnam, Vietnamese and foreign languages ​​must be used simultaneously. In fact, the translation of accounting vouchers, accounting books and financial statements as mentioned above is a difficult problem for the operation of enterprises in the process of implementation, including related to archiving of accounting documents. .

This issue needs to be studied more clearly, specifically in the direction of only regulating the translation of documents directly serving accounting books or directly related to payment, such as "Invoices" or related documents. other.

2.6. About the extended accounting period

The Accounting Law (Article 12) stipulates that in case the accounting period of the first year or the accounting period of the last year is shorter than 90 days, it is allowed to add to the accounting period of the following year or to the accounting period of the previous year. that to calculate into an annual accounting period; the first year or last year accounting period must be shorter than 15 months. In this case, the inconsistent use of day and month units leads to problems in practice because 03 consecutive months can be 90 days or more than 90 days. If the unit applies 03 full months, the total number of days may exceed 90 days.

Therefore, this content should be reviewed to stipulate uniform units over time, avoiding problems in practice.

2.7. About prohibited acts in accounting practice

The Law on Accounting (Article 13) stipulates the prohibition of hiring an unqualified entity to provide accounting services to provide accounting services, which is inconsistent with the reality of accounting services and difficult to control and handle. violation reason. Currently, this regulation is similar to that for audit services.

Regarding this content, it is necessary to review to have clearer regulations on the conditions for performing accounting services, in order to develop the market, reduce costs and human resources for the unit. In addition, continue to review the Decree on sanctioning of administrative violations in the field of accounting for regulations in accordance with the provisions of the Law on Accounting.

2.8. Regarding sealing, custody and confiscation of accounting vouchers and documents

For paper-based accounting documents, the regulations on sealing, custody and confiscation of accounting documents, especially accounting vouchers have been implemented widely, without problems, without affecting the number of accounting documents. accounting records. However, for electronic vouchers and electronic accounting documents, activities such as sealing, seizing and confiscating data are not clearly defined, and there is no basis for document delivery. accounting, or if there is a document delivery, it may affect the data on the accounting books, on the database of the entity.

Therefore, it is necessary to review and appropriate regulations on the seizure or confiscation of accounting vouchers, the competent state agency must make copies of the seized or confiscated vouchers, and sign for certification on the vouchers. copy and deliver the copy to the accounting unit; and at the same time make a record clearly stating the reason and quantity of each type of accounting voucher which is temporarily seized or confiscated, and signed and stamped.

2.9. Regulations on accounting books

– Clause 2, Article 25 stipulates “Each accounting unit can only use one accounting book system for an annual accounting period”. The above regulation is not really clear, complete and consistent with the provisions in Clause 10, Article 13 of the prohibited acts "Establishment of two or more financial accounting book systems". In fact, the entity may need to open accounting books for management accounting purposes, the above regulation is not clear about the financial accounting system, so it will not be suitable for opening the book system for the purpose of management accounting. management accounting.

– Some regulations on accounting books, for example, regulations on bookkeeping and correction of accounting books are still mainly based on manual bookkeeping while at present accounting bookkeeping at units is mainly done. By electronic means, the recording of accounting books by electronic means is only prescribed in Clause 7 Article 26 "Accounting units may record accounting books by electronic means...". The above regulations do not cover all units and therefore are not appropriate in the context of technology application in current accounting activities and future trends.

2.10. About financial statements

The Law on Accounting (Article 29) stipulates that the financial statements of an accounting unit are used to summarize and explain the financial position and operating results of the accounting unit. Financial statements of an accounting unit include: Statement of financial position; Report on performance; Statements of cash flows; Notes to the financial statements; Other reports as required by law.

Listing the specific names of the financial statements of the accounting units, as the current Law does, may lead to difficulties in determining the list of reports for the accounting units, in accordance with international accounting standards. In particular, it is noted that small and very small businesses will face difficulties with the organization of the accounting apparatus.

In case of hiring accounting services, it is necessary to consider more about the requirement that both the preparer, chief accountant and legal representative all sign on the financial statements of the enterprise or accounting unit. As a rule, many countries only stipulate that the legal representative is responsible before the law for the financial statements of the enterprise, the legal representative's hiring of any organization or individual to do the accounting or accounting services for them. they still have to be responsible before the law, so they need to find a reputable and quality accounting service provider.

2.11. About enhancing publicity and transparency

The Accounting Law (Article 31) stipulates the disclosure of financial statements for budget-using units, non-budgetary units, accounting units using public contributions, business unit of accounting. However, the form and time limit for disclosure (Article 32) are not really clearly defined for the accounting unit, the forms of publicity are not the same, leading to the unit making the form and perfunctory[4] . The access to public information of interested persons using reported information is in fact limited or there are other cases where confidentiality is required by law.

In addition, it is necessary to review and ensure uniformity, in accordance with the object, content and form of publicizing financial statements of other laws[5]. Some specific orientations for financial reporting disclosure:

– Re-stipulate the content of public financial statements and the form of disclosure to be specific and clear.

– Supplementing regulations to clarify the scope of financial statements disclosure; recipients of financial statement disclosure information; specific regulations or consider removing the content that only requires disclosure of some items of the financial statements, instead, the financial statements should be disclosed, not just some contents.

– Regarding the form of publicity, there should be a mandatory form such as posting on the website/website of the enterprise or the accounting unit, in addition, it is possible to choose additional publicity in other forms.

2.12. About internal audit

The Law on Accounting (Article 39) stipulates that internal audit has the following tasks: Checking the suitability, effectiveness and efficiency of the internal control system; Check and confirm the quality and reliability of economic and financial information of financial statements and management accounting reports before submitting them for approval; Inspecting compliance with operating principles, management, compliance with laws, financial and accounting regimes, policies, resolutions and decisions of the leadership of the accounting unit; Detect loopholes, weaknesses, frauds in the management and protection of assets of the unit; propose solutions to improve and complete the system of management and operation of the accounting unit.

The Government has issued Decree 05/2019/ND-CP dated January 22, 01 detailing internal audit in enterprises, state agencies and non-business units. The Ministry of Finance has also issued Circulars guiding internal audit standards and model regulations on internal audit for units. However, up to now, problems still arise in organizing the internal audit apparatus, ensuring independence, and not increasing the apparatus in both central and local units.

2.13. About the accounting unit

The Law on Accounting (Article 49) stipulates the organization of the accounting apparatus of the accounting unit, the responsibilities of the legal representative of the accounting unit in the organization of the accounting apparatus, and the arrangement of employees. accounting or decide to hire accounting services. However, the determination of which unit is an accounting unit has not been clearly stated in the Law, when only stipulating that the units subject to the application of the Law on Accounting that prepare financial statements are considered as accounting units. accountant. Meanwhile, the regulation of financial reporting units is stated in the Circulars guiding the accounting regime, issued by the Ministry of Finance.

The reality arises, very small-sized units, especially in the public sector, must also organize an accounting apparatus, while the organizational apparatus of the unit is not enough people to arrange the accounting apparatus. [6]. In some cases, the accounting apparatus is arranged in departments, divisions and divisions of the unit that cannot be organized into separate departments, so it is difficult to organize and operate the work. In fact, some accounting units are dependent, but still organize their accounting apparatus because they identify themselves as accounting units and prepare financial statements.

According to current regulations, an accounting unit is one that must prepare financial statements, including micro enterprises. In fact, the case of micro-enterprises that are subject to CIT at the fixed rate must also prepare financial statements, which will not be suitable to the reality, management requirements and conditions of the enterprise, but it is necessary to identify the type of enterprise. Is this an accounting unit, because this business also operates independently, and must also declare and pay taxes in accordance with tax laws.

From the above problems, there should be more appropriate regulations on accounting units or clearer regulations on reporting units. From there, it is clear which units must prepare financial statements and which units must organize their accounting apparatus, thereby reducing social costs, removing difficulties and obstacles for units and enterprises.

2.14. About regulations for accountants

– The Law on Accounting (Article 54) stipulates standards, rights and responsibilities of accountants. Specifically, accountants must have accounting expertise (chief accountants at intermediate level or higher). In addition, Clause 5, Article 18 of Decree 174/2017/ND-CP stipulates: Persons with professional qualifications in accounting are those who have graduated from professional secondary schools, colleges, universities or specialized graduate schools. majoring in finance, accounting and auditing at secondary schools, colleges, universities or academies at home and abroad…”. This regulation is not consistent with the reality of training disciplines and specialties of the current education system. In fact, there are many cases of university graduates majoring in finance, accounting or auditing (for example, business administration) but the transcript clearly states: majoring in accounting, auditing or majoring in accounting and financial management. These cases are considered to have professional qualifications in accounting.

– The Law on Accounting (Article 54) stipulates the standards and conditions for chief accountants who “have a certificate of training for chief accountant”. Currently, the certificate of training for chief accountants includes the certificate of training for chief accountants of enterprises and administrative affairs, however, in the Law on Accounting and the guiding Decree, there is no regulation on the case of having a certificate of training in accounting. The chief accountant of an enterprise can appoint chief accountants of units in the state sector and vice versa. Decree 174/2017/ND-CP stipulates the same standards and conditions for chief accountants and in charge of accounting, causing difficulties in the implementation stage, because if qualified, they are in charge of accounting. accounting, the unit may appoint a chief accountant. In addition, some people have certificates of accountants and auditors at home and abroad, but do not have the conditions to study to grant a chief accountant degree, so they are not eligible to be appointed chief accountant, because the This certificate cannot replace the certificate of training for chief accountant.

The Law on Accounting (Article 53) stipulates that chief accountants of state agencies, organizations and non-business units funded by the state budget, and enterprises in which more than 50% of charter capital is held by the State, outside of the prescribed duties. defined in Clause 1 of this Article also has the duty to assist the legal representative of the accounting unit in financial supervision at the accounting unit. Thus, the provisions of the Law (Clause 2, Article 53) have not mentioned the duties of chief accountants at accounting units, which are agencies responsible for state budget revenues and expenditures at all levels; non-business organizations and units that do not use the state budget to assist the legal representative of the accounting unit in financial supervision at the unit.

From the above fact, it is necessary to review and amend the regulations on accountants, accountants and chief accountants to suit the current reality and the future.

2.15. About the organization of the accounting apparatus, chief accountant

Currently, the Law on Accounting (Article 54) stipulates that the conditions for appointing a chief accountant are to have a chief accountant certificate, but there is no requirement for a certificate of accountant or auditor. In fact, those who have professional qualifications with certificates of accountants and auditors do not have time to go to school to obtain a certificate of chief accountant. Therefore, for the standards and conditions of chief accountants, the condition of having a chief accountant certificate or a certificate of accountant or auditor should be added.

The standard regulations of the chief accountant and the person in charge of accounting are the same, so for small and micro enterprises, it is possible to arrange the person in charge of accounting without having to arrange the chief accountant. meaning in practice.

It is necessary to add a regulation that the chief accountant must be responsible for the financial statements in the period in which he is assigned to be the chief accountant.

Through the actual implementation of the Law on Accounting, some opinions from the fact that the arrangement of chief accountants at state accounting units or the public sector is not really necessary. For a small-sized unit, having to arrange an accounting unit will cause difficulties for the unit. However, if the accounting apparatus is not arranged, it is necessary to have appropriate regulations on the reporting regime and budget compliance of the unit. Therefore, this content needs to be studied carefully, in accordance with the requirements of budget management and public finance at both central and local levels.

2.16. For business activities of accounting services

– The Law on Accounting (Article 59) stipulates that foreign accounting service businesses may contribute capital with individuals to establish an accounting service business. However, Clause 4, Article 59 stipulates that foreign accounting service enterprises conducting accounting service business in Vietnam must contribute capital with accounting service enterprises already established and operating in Vietnam. Male. In fact, documents to prove that foreign business enterprises dealing in accounting services face many difficulties and management is not effective in practice, therefore, it is recommended to reconsider this regulation.

- The Law on Accounting stipulates the conditions for granting the Certificate of eligibility for business in accounting services. In the process of implementation, there were problems that arose in practice. For this content, it should be clearly stated that one or all of the legal representatives are practicing accountants in two cases as follows:

+ For the form of limited liability company or partnership, only 01 legal representative, director or general director should be specified as a practicing accountant. All legal representatives should not be required to be practicing accountants, because enterprises can operate in many fields and have many legal representatives, each in charge of different fields.

+ For more specific regulations on having more than one legal representative, all legal representatives of an enterprise providing accounting services must be practicing accountants.

In addition, it is necessary to review to adjust the following regulations:

+ Reviewing regulations to be consistent with WTO commitments on not restricting foreign investors from establishing accounting service providers in Vietnam.

+ Review and amend business conditions for private enterprises in the direction that only 01 practicing accountant should be prescribed or at least 1 practicing accountant instead of requiring 2 practicing accountants.

+ Review and amend regulations requiring the deletion of the phrase "accounting services" in the name. Through actual implementation, the name of the enterprise may have only the phrase "accounting" but it cannot be deleted (similar to Article 13).

+ In Clause 4, Article 61, it is proposed to remove regulations on labor contracts for practicing accountants. The reason is that in the application file for the certificate of eligibility to provide accounting services, it is stated that the dossier for registration of accounting practice of the individual has a copy of the labor contract working full time at the accounting firm. accounting service business unit.

+ Proposal to amend the regulations on cases of re-grant of certificates of eligibility to provide accounting services when there is a change in information on the Certificate of eligibility to provide accounting services about the legal representative, the Director, General Director (instead of just changing the first and last name as at present), which considers removing the case of changing the address of the branch office providing accounting services.

+ Review the regulations on revocation of the certificate of eligibility to provide accounting services if the failure to maintain business conditions cannot be rectified within 60 days from the date of suspension. If required, within 06 months from the date of ineligibility to provide accounting services, the enterprise will have its Certificate of eligibility to provide accounting services revoked because in fact there are many cases ineligible to do business in accounting services but did not notify the Ministry of Finance, so he was not warned, not suspended from doing business in accounting services, when it was discovered that the suspension period had expired but in fact did not suspended, so the certificate of eligibility to provide accounting services cannot be revoked.

+ In fact, when not meeting the conditions to register to practice, of course, you are not allowed to practice accounting. Therefore, study the removal of Point b, Clause 6, Article 69 on the fact that practicing accountants are not eligible for practice registration and will be suspended from practicing accounting services.

2.17. About providing accounting services

The Law on Accounting stipulates that in order to establish an accounting service-providing business, at least 02 people must have an accounting certificate, of which the director of the enterprise must have an accounting practice certificate for 02 years or more. An enterprise can be established in the form of a limited liability company with two or more members (similar to an independent auditing firm) and has a charter capital according to the Government's regulations. Holders of accounting practice certificates working in enterprises must contribute capital at least 50% of the unit's charter capital.

However, current regulations may limit the development of businesses providing accounting services. On the other hand, these regulations are not similar to those in the Law on Tax Administration on providing accounting services for micro enterprises.

Therefore, it is necessary to review the conditions for practicing accounting, the conditions for registering the business of accounting services to make regulations consistent with reality and in sync with other legal provisions on accounting practice.

2.1.8. About professional organizations of accounting

The Accounting Law (Article 70) stipulates the following professional accounting organizations: “Accounting professional organizations are established and operate in accordance with the law on associations and are responsible for complying with the provisions of the Law on Accounting. regulations on accounting. Professional organizations in accounting are provided with training and updating knowledge for accountants and practicing accountants and perform a number of tasks related to accounting activities prescribed by the Government.

Currently, the professional accounting organization, the Vietnam Association of Accountants and Auditors, has been transformed into an association model. The establishment of the organization and operation of the Association is carried out in accordance with the provisions of the law on the Association, with the responsibility to comply with the provisions of the law on accounting, but there are no specific provisions of the law on the Association.

To implement the Strategy on Accounting and Auditing to 2030, based on the provisions of the law on the Association, it is necessary to study the appropriate provisions in the Law on Accounting, so that the Professional Association can effectively participate in the development of legislation. the law on accounting - auditing, developing and promulgating legal regulations related to the operational responsibilities of professional organizations in accounting - auditing; building a unified, self-managed, professional professional organization model, following international practices, attracting a large number of members to participate. Improve the effectiveness of participating in the formulation and criticism of mechanisms and policies; improve management capacity, supervise the compliance with professional standards, standards and regulations on professional ethics of accountants and auditors; inspecting service quality and fostering professional knowledge and ethics for accountants - auditing practitioners; organize examinations and grant professional certificates according to the provisions of law.

Specifically, it is necessary to research to assign professional activities in accordance with the law and the capacity of professional associations according to the appropriate roadmap, ensuring the principle of stability and being responsible before the law.

2.19. About state management of accounting

In addition to studying regulations for effective coordination of units and implementation of the state administrative reform master program for the period 2021 - 2030, it is necessary to study the provisions in the Accounting Law on public decentralization. management, inspection and supervision more clearly to ensure feasibility and efficiency in practice.

Research to clarify in the Law on Accounting the responsibilities of agencies and units in guiding the accounting regime for banks and credit institutions.

2.20. About accounting software

The current accounting software is developed quite diversely, with different quality, the cause comes from the experience and ability of the accounting software supplier; derived from the ability to grasp and provide technical requirements of the accounting unit to the software supplier, from the understanding and use of applications by the accounting team, employees of the units. accountant.

This fact requires that in the Law on Accounting, there should be new, principled, professional requirements to ensure the quality of accounting software and system applications that the entity uses. accounting used in accounting work, unit management.

3. Relevant contents to be implemented to implement the Law on Accounting

3.1. Promulgating and publicizing accounting standard systems

– Determine the appropriate reporting framework for each type of business in order to improve the efficiency of financial and accounting information[7]. Implement the application of international financial reporting standards in Vietnam according to the roadmap determined by the Ministry of Finance for businesses that need and are eligible for application. Develop and organize the implementation of Vietnamese financial reporting standards in line with international practices and conditions in which Vietnam replaces the Vietnamese corporate accounting standard system. Issue accounting guidance documents suitable for small, medium and micro enterprises.

For the financial reporting standard system, it is necessary to have a clearer direction and ensure the conditions for using fair value in the recognition and presentation of financial statements. This is a rather complicated content, so far there are still obstacles in the process of preparing the conditions for application.

– Announce the Vietnamese public accounting standard system on the basis of international public accounting standards, in line with the reform trend of public financial management and the state budget of Vietnam. Vietnam's public accounting standard system ensures the requirement to create a unified basis for accounting records, which is the standard and format for the preparation and presentation of financial information of accounting units in the region. State, state financial reporting and local government.

3.2. Strengthen the capacity of accounting management and supervision agencies and the effectiveness of inspection and supervision of compliance with accounting laws

– Capacity building for agencies directly performing accounting management and supervision functions; have suitable solutions to attract high-quality personnel to perform well and effectively the tasks of accounting management and supervision. Studying international experiences and implementing appropriate plans to organize activities according to the model of consulting and consulting on accounting, in order to make decisions in accordance with international practices, Vietnamese laws and regulations. unit practice.

- Innovating and effectively implementing the contents, methods and conditions for the management and supervision of accounting activities. Strengthen coordination with agencies and units in charge of inspecting and supervising financial statements and the observance of accounting laws. Coordinate with professional organizations, training institutions and a team of experts with practical experience in accounting practice to enhance professional training in accounting, foreign languages, examination skills, supervision of financial statements, compliance with accounting laws.

- Based on functions and tasks, ensure human resources to supervise the compliance with legal regulations on accounting of enterprises and organizations in the state sector and the enterprise sector. Pay attention to the monitoring mechanism for compliance with accounting standards of listed companies and other public interest companies. Ensure conditions to improve the efficiency of management and supervision of the accounting service market; strictly handle violations of accounting standards and professional ethics in accordance with law.

– Concretize the responsibilities and obligations of businesses, accounting units and individuals in enhancing the publicity and transparency of the financial situation, ensuring equal rights in accessing information of investors. investors and related parties to financial statements and other financial information.

– Strengthen inspection and supervision activities for compliance with legal regulations and professional standards of enterprises and accounting units; businesses providing accounting services; the organization of information systems, the use of software for accounting work in enterprises, accounting units and enterprises providing accounting services. Effectively publicize and transparently disclose economic and financial information of enterprises, accounting units, agencies and economic organizations; in which attention is paid to entities with public interest.

– Strengthen the inspection and guide the organization and effective implementation of internal audit activities at enterprises, People's Committees of provinces and centrally run cities, ministries, ministerial-level agencies and agencies. directly under the Government and large-scale public non-business units in accordance with the Government's regulations and the guidance of the Ministry of Finance[8].

3.3. Market development of accounting services

– Define criteria for entities with public interest in the direction of supplementing necessary subjects, along with stricter and more effective requirements for publicity and transparency of financial statements to ensure public interests. and the overall sustainable development of the economy. Researching and determining the audited subjects of annual financial statements are large-scale public non-business units, especially public non-business units that are autonomous in both investment and recurrent expenditures, and non-business units. public autonomy in recurrent expenditure.

- Develop criteria and orientation on the scale, quantity and quality of services of accounting service enterprises in accordance with the requirements of reality, through the improvement of the mechanism and conditions of practice; increase the quantity and quality of the team of accountants; effectively implement solutions for service supply, in order to improve the quality of accounting services.

 – Completing and implementing legal regulations, creating the basis and conditions for negotiation, joining international agreements and mutual recognition for accounting services with countries in the region and In the world.

3.4. Developing professional associations

- Pursuant to the provisions of the law on associations and the law on accounting, to develop and promulgate legal regulations related to the operational responsibilities of professional organizations in accounting; building a unified, self-managed, professional professional organization model, following international practices, attracting a large number of members to participate.

- Improve the efficiency of participation in formulating and criticizing mechanisms and policies; improve the capacity of accountants to manage and supervise the compliance with professional standards, standards and regulations on professional ethics; checking service quality and fostering professional knowledge and professional ethics for accountants.

- Research to transfer professional activities in accordance with the law and the capacity of professional associations according to the appropriate roadmap, ensuring the principle of stability and taking responsibility before the law.

 – Expand cooperation with professional organizations in the region and the world, in order to improve the operational efficiency of professional associations, contributing to promoting accounting integration.

3.5. Developing human resources in accounting

– Innovating contents, programs and methods to improve the quality of training and fostering of accounting human resources, combining theory and practice, associated with the process of digitization and digital transformation of accounting. Paying attention to high-quality human resources in accounting, serving the needs of businesses, accounting units and other organizations in the entire economy in the context of deepening integration.

- Innovating learning methods, organizing exams and issuing certificates of accountants, ensuring knowledge and skills in accordance with requirements and international practices, ensuring conditions for mutual recognition in the region and in the world. world.

– Raising the sense of discipline, professional qualifications and professional ethics of accountants through reforming regulations on training content and forms, and updating knowledge; pay attention to and encourage international professional certification training programs in order to access knowledge and practice skills in accordance with international practices.

- Renovate the content, form and program of training and fostering chief accountants; develop contents and programs to update professional knowledge every year for chief accountants of units of public interest.

– There are support solutions to improve the qualifications and professional activities of the accounting team working in small, medium and micro enterprises.

3.6. Strengthening and expanding international cooperation activities

– Strengthening relationships and enlisting the help of international professional organizations in accounting and non-governmental organizations in research and exchange of experience in accounting; provide technical support to renew the management model of accounting profession as well as other professional techniques in accounting.

- Studying models of developed countries to apply to Vietnam in organizing and managing activities of checking and supervising financial statements; construction and application of financial reporting standards; building accounting techniques; developing accounting services; complete the model of training, examination, and certification of accountants.

- Research and implement solutions to strongly promote accounting integration; accounting services market with countries around the world and the region.

– Strengthen ASEAN cooperation in the field of mutual recognition of accounting services, expand the exchange of professional accountants with ASEAN standards, increase the number of Vietnamese accountants who obtain ASEAN professional accounting certificates and participate in providing accounting services in ASEAN countries.

Participate in the development of international financial reporting standards and public accounting standards of the International Accounting Standards Boards. Continue to support professional organizations to fully fulfill their roles as members of the International Federation of Accountants (IFAC), ASEAN Association of Accountants (AFA) and members of the Asia-Pacific Accountants Association. Duong (CAPA).

3.7. Information technology application and other activities

– Regarding technology application: Continue to review, reduce and simplify administrative procedures to create favorable conditions, save time and costs for businesses and accounting units; accounting service businesses and accountants. Effectively applying development achievements of information technology, meeting the requirements of the digitalization and digital transformation process in accounting activities at state agencies, enterprises and accounting units.

About other activities:

+ Implement effectively and qualitatively the preparation of state financial statements in order to fully reflect information on the assets, resources and obligations of the Government and local authorities, serving as a basis for planning. financial and budgetary management mechanisms and policies.

+ Building a data system to serve the management and supervision of the accounting service market; connection of information between regulatory agencies, accounting supervision and stock market; ensure the transparent and timely disclosure of information to the market about the team of accounting firms as well as practicing accountants.

+ Relevant units shall coordinate in organizing information systems and data on financial information of enterprises and accounting units, serving the data exploitation according to public services of organizations and individuals. ensure that official information is used in economic relations and transactions.

+ Organize the financial accounting apparatus at state accounting units in a streamlined and efficient manner. Implement solutions to improve the quality of the preparation and presentation of state financial statements, improve the accountability of units in the effective management and use of state assets and resources from the central government. to the local.

Appendix

DOCUMENTATION OF ACCOUNTING LAW

(1) Decree No. 174/2016/ND-CP dated December 30, 12 of the Government detailing a number of articles of the Law on Accounting;

(2) Decree No. 25/2017/ND-CP dated March 14, 3 of the Government on State financial statements;

(3) Decree No. 41/2018/ND-CP dated March 12, 03 of the Government on regulations on sanctioning of administrative violations in the field of independent accounting and auditing;

(4) Decree No. 05/2019/ND-CP dated January 22, 1 of the Government regulating internal audit;

(5) Decree No. 102/2021/ND-CP dated November 16, 11 of the Government amending and supplementing a number of Articles of Decrees on sanctioning of administrative violations in the field of tax and invoices; customs; insurance business, lottery business; management and use of public property; practice thrift, fight waste; national reserve; State Treasury; independent accountants and auditors;

(6) Circular No. 53/2016/TT-BTC dated March 21, 03 amending and supplementing a number of articles of Circular 2016/200/TT-BTC dated December 2014, 22 guiding the corporate accounting regime Karma;

(7) Circular No. 133/2016/TT-BTC dated August 16, 8 guiding the accounting regime for small and medium enterprises;

(8) Circular No. 271/2016/TT-BTC dated November 14, 11 stipulating the rate of collection, collection and payment of fees for assessment and issuance of Certificate of practice registration, Certificate of eligibility for service business. accounting and auditing services;

(9) Circular No. 292/2016/TT-BTC dated November 15, 11 guiding the annual update of knowledge for practicing accountants and those registering to practice accounting services;

(10) Circular No. 296/2016/TT-BTC dated November 15, 11 guiding the issuance, revocation and management of the Certificate of registration for accounting service practice;

(11) Circular No. 297/2016/TT-BTC dated November 15, 11 on grant, management and use of Certificate of eligibility for business in accounting services;

(12) Circular 317/2016/TT-BTC dated December 07, 12 guiding the accounting applicable to the Vietnam Environmental Protection Fund issued by the Minister of Finance;

(13) Circular No. 24/2017/TT-BTC dated March 28, 3 guiding the accounting regime of cooperatives and unions of cooperatives;

(14) Circular 77/2017/TT-BTC dated 28/7/2017 guiding the State Budget accounting regime and State Treasury professional activities issued by the Minister of Finance;

(15) Circular No. 91/2017/TT-BTC dated August 31, 08 of the Ministry of Finance providing for the examination, granting and management of auditor's and accountant's certificates;

(16) Circular No. 107/2017/TT-BTC dated 10/10/2017 guiding the administrative and non-business accounting regime;

(17) Circular No. 16/2018/TT-BTC dated February 07, 02 guiding a number of articles on financial regimes applicable to credit institutions and foreign bank branches;

(18) Circular No. 23/2018/TT-BTC dated March 12, 3 guiding the accounting of covered warrants for securities companies that are issuers;

(19) Circular No. 74/2018/TT-BTC dated August 16, 08 guiding the accounting regime for loans and debt repayment of the Government and local authorities; statistics and monitoring of on-lending and Government guarantee debts;

(20) Circular 99/2018/TT-BTC dated November 01, 11 guiding the preparation of general financial statements of state accounting units being superior accounting units issued by the Minister of Finance;

(21) Circular No. 102/2018/TT-BTC dated 14/11/2018 guiding the accounting of Social Insurance;

(22) Circular 103/2018/TT-BTC dated 14/11/2018 guiding the accounting applied to the Fund “For the Poor” issued by the Minister of Finance;

(23) Circular 108/2018/TT-BTC dated 15/11/2018 guiding national reserve accounting issued by the Minister of Finance;

(24) Circular 109/2018/TT-BTC dated November 15, 11 guiding the accounting regime applicable to the Accumulation Fund for debt repayment issued by the Minister of Finance;

(25) Circular 112/2018/TT-BTC dated November 15, 11 of the Ministry of Finance amending and supplementing a number of articles in Circular 2018/174/TT-BTC dated November 2015, 10 of the Ministry of Finance guiding the professional accounting of taxes and other revenues for exported and imported goods promulgated by the Minister of Finance;

(26) Circular No. 132/2018/TT-BTC dated December 28, 12 guiding the accounting regime for micro enterprises;

(27) Circular No. 133/2018/TT-BTC dated December 28, 12 guiding the preparation of state financial statements;

(28) Circular No. 05/2019/TT-BTC dated January 25, 01 guiding accounting applicable to microfinance institutions;

(29) Circular No. 44/2019/TT-BTC dated July 19, 07 amending and supplementing a number of articles of Circular 2019/292/TT-BTC dated November 2016, 15 of the Minister of Finance guiding guidelines for updating knowledge annually for practicing accountants and those registering to practice accounting services and Circular No. 11/2016/TT-BTC dated November 296, 2016 of the Minister of Finance guiding the issuance of , revoke and manage the certificate of registration of accounting service practice;

(30) Circular 70/2019/TT-BTC dated October 03, 10 guiding the commune budget and finance accounting regime issued by the Minister of Finance;

(31) Circular 76/2019/TT-BTC dated 05/11/2019 guiding the accounting of transport and irrigation infrastructure assets issued by the Minister of Finance;

(32) Circular 79/2019/TT-BTC 14/11/2019 guiding the accounting regime applicable to project management boards using public investment capital issued by the Minister of Finance;

(33) Circular No. 89/2019/TT-BTC dated December 26, 12 guiding the accounting applicable to the Vietnam Securities Depository Center;

(34) Circular No. 19/2020/TT-BTC dated March 31, 03 amending Circular No. 2020/77/TT-BTC dated July 2017, 28 guiding the State budget accounting regime and operations State Treasury operations issued by the Ministry of Finance;

(35) Circular 39/2020/TT-BTC dated May 15, 05 amending the reporting regime in the Circular in the field of independent accounting and auditing;

(36) Circular 40/2020/TT-BTC dated 15/05/2020 guiding the reporting regime in the field of independent accounting and auditing in Decree 174/2016/ND-CP dated 30/12/ 2016 guiding the Law on Accounting and Decree 17/2012/ND-CP dated March 13, 03 guiding the Law on Independent Audit;

(37) Circular 66/2020/TT-BTC dated 10/07/2020 promulgating the Model Regulation on internal audit applicable to enterprises;

(38) Circular 78/2020/TT-BTC dated 14/08/2020 guiding professional accounting for civil judgment enforcement;

(39) Circular No. 08/2021/TT-BTC dated January 25, 01 promulgating internal audit standards and principles of professional ethics;

(40) Circular 09/2021/TT-BTC dated 25/01/2021 guiding the inspection of accounting service activities;

(41) Circular 26/2021/TT-BTC dated 07/04/2021 guiding the accounting work when converting public non-business units into joint stock companies;

(42) Circular No. 39/2021/TT-BTC dated June 01, 6 amending and supplementing a number of articles of Circular No. 2021/133/TT-BTC dated December 2018, 28 of the Ministry of Finance guiding prepare state financial statements;

(43) Circular 88/2021/TT-BTC dated 11/10/2021 guiding the accounting regime for business households and individuals, promulgated by the Minister of Finance;

(44) Circular 90/2021/TT-BTC dated October 13, 10 guiding the accounting applicable to the State Financial Fund off-budget issued by the Minister of Finance.

[1] Law on Accounting No. 88/2015/QH13 dated November 20, 11.

[2] In 2018 there were 91 enterprises, an increase of 12,8% compared to 2017; in 2019 there were 118 enterprises, an increase of 30% compared to 2018; in 2020 there are 148 enterprises, increasing by 25,4% compared to 2019; In 2021, there are 153 businesses, up 3% compared to 2020.

[3] At Clauses 1, 2, 3, accounting documents must be archived for a period of 5 years, 10 years and permanently archived.

[4] For example, the entity implements one of the forms of publicity such as publication; Announce by document; listing; posting on the website; other forms as prescribed by law.

[5] For example, the Law on Credit Institutions, the Law on Securities, the Law on Investment, the Law on Insurance Business, etc. have specific provisions.

[6] Some provincial social organizations, such as the Association for the Blind and the Association for Study Promotion, are identified as accounting units. However, the organizational structure is not enough to form the accounting apparatus at the unit.

[7] The reporting framework for enterprises includes: Enterprises applying international financial reporting standards; enterprises applying Vietnamese financial reporting standards; enterprises applying the accounting regime for small and medium enterprises, enterprises applying the accounting regime for micro enterprises.

[8] According to the provisions of Decree No. 05/2019/ND-CP dated January 22, 01 of the Government on Internal Audit.