Challenges of Multinational Operations under Regulatory Changes

Driven by the "New Southbound Policy," Vietnam has become a key region for Taiwanese businesses expanding into the Southeast Asian market. However, as companies grow, effectively navigating increasingly complex local regulations and ensuring compliance and operational efficiency have become critical challenges for multinational operators. Recently, Vietnam's Ministry of Finance issued Circular No. 99/2025/TT-BTC, which is about to take effect. This new regulation will have a profound impact on companies operating in Vietnam, particularly in terms of financial management and corporate governance.

Communiqué No. 99 is not only a revision of the existing accounting system, but also a milestone in aligning Vietnamese corporate financial management with international standards. For companies still relying on traditional accounting methods or lacking digital systems, this change presents both challenges and opportunities for transformation and upgrading. This article will delve into the core spirit of Communiqué No. 99 and explore how companies can leverage digital tools to transform regulatory pressure into momentum for improving internal governance capabilities.

Knowledge Content and Local Challenges Analysis

1. Core principle: Shifting from "passive compliance" to "proactive governance"

The most fundamental change in Circular 99 lies in granting companies greater accounting autonomy while simultaneously imposing stricter governance responsibilities. Previously, companies had to strictly adhere to the rigid templates outlined in Circular 200/2014/TT-BTC. However, under the new Circular, companies have greater flexibility in designing their accounting systems, vouchers, and ledgers, allowing for adjustments based on internal management needs. However, this increased autonomy comes with stricter governance requirements:

2. Significant differences at the system operation level: data "accuracy" and "traceability"

For businesses with factories in Vietnam, the challenges brought by the new communiqué are not limited to changes in accounting (account titles). The biggest difference lies in the requirements for "internal control data." Communiqué No. 99 no longer focuses solely on "whether the data is correct ," but explicitly requires explanations of "how the data is established, controlled, and reviewed in the ERP system."

Advantages of digital solutions and services

In response to the shift in thinking from "simple bookkeeping" to "corporate governance and risk management" outlined in Communiqué No. 99, companies must fundamentally re-examine their information systems and management processes:

1. Accounting Subject Structure Control and Flexible Adjustment: The ERP system must support flexible revision and supplementation of the accounting subject system. Enterprises can adjust subject names and structures according to internal management needs, while ensuring compliance with the regulatory framework. The system's built-in control mechanism can automatically handle adjustments to accounting subjects that have already been used for transactions, preventing erroneous operations.
2. Electronic signature process and audit trail: Through the electronic signature system, enterprises need to establish a complete electronic signature process that conforms to hierarchical authority and clear responsibilities. The entire historical record of all transaction vouchers from creation, modification to approval, including the executor and specific time, will be fully retained to provide the most credible audit evidence.
3. Automated and refined financial statement management: The ERP system can pre-create financial statement templates that comply with Gazette 99. It not only allows for easy data retrieval at any time but also supports efficient multi-currency accounting management and automatic handling of exchange rate differences. Furthermore, the system can provide detailed financial statement notes according to the new gazette's requirements, ensuring corporate transparency and the feasibility of risk assessments.

Call to Action and Frequently Asked Questions

The effective date of Announcement No. 99 has arrived, and businesses must proactively respond rather than passively wait. The implementation of the new regulations will prompt Taiwanese businesses in Vietnam to rethink how to leverage digital tools to enhance corporate governance and achieve truly international operations.

Take immediate action: It is recommended that companies conduct internal reviews to assess whether their existing ERP systems and processes comply with the requirements of Communiqué No. 99.

FAQ: Questions that businesses care about most

Q1: After the new gazette takes effect, can companies continue to use the existing accounting subject system?

A: Yes. The new gazette grants companies autonomy to revise or supplement existing items, but they must comply with established internal regulations and ensure that the revisions do not alter or affect the items and information in the financial statements. The key is to establish a sound internal control and audit track to prove the legality of the information.

Q2: What specific requirements did Announcement No. 99 put forward for ERP systems?

A: The ERP system must support audit trails that trace back from financial statements to every business transaction, ensuring clear data responsibilities and transparent processes. This includes the complete recording and traceability of basic data, transaction data, adjustment and estimation data, and internal control data.

Q3: What adjustments are required if the Vietnamese subsidiary uses foreign currency for accounting?

A: The new gazette stipulates that enterprises do not need to separately declare or register with the tax authorities when choosing a foreign currency as their accounting unit. However, the system still needs to have a complete foreign currency transaction processing capability and flexibly select the exchange rate according to regulations to ensure that the financial statements accurately reflect the value of assets and liabilities.

Q4: Where can I find the original text of the Vietnam 99/2025/TT-BTC regulation, also known as the 99 Communiqué?

A: Please see the link to the official notification from the Vietnamese government.

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