The accounting and audit community is in the "drawdown" phase to switch to a new corporate accounting regime according to Circular 99/2025/TT-BTC (issued on October 27, 2025). This is an important legal document replacing Circular 200/2014/TT-BTC, which has existed for more than a decade.
However, the regulation effective from January 1, 2026 has created a "reflection point" for businesses whose financial years do not coincide with the solar year (e.g. FDI enterprises, schools, or agricultural companies...).
A representative of a business (abbreviated as T.P) recently sent a hot question to the management agency. This person said that the company applies a financial year starting from October 1 every year and ending on September 30 next year.
Our company has a fiscal year from October 1, 2025 to September 30, 2026. So, at the time of January 1, 2026 when the new Circular takes effect, do we have to apply it immediately or are we allowed to wait until the next fiscal year?" - a representative of T.P Company expressed concern about data disruption if we have to change the accounting regime midway.
In fact, changing the accounting regime between years is a taboo, which can lead to errors in financial statements and difficulties in comparing data.
To solve this problem, the Department of Accounting and Audit Management and Supervision (Ministry of Finance) has issued specific guidance based on Clause 1, Article 31 of Circular No. 99/2025/TT-BTC.
This agency affirms that the principle of applying the law is based on the start of the financial year. The document stipulates: "This Circular takes effect from January 1, 2026 and applies to the financial year starting from or after January 1, 2026".
Thus, for the case of T.P Company:
Current fiscal year (from October 1, 2025 - September 30, 2026): The old regime will continue to be applied (according to Circular 200) until the end of the term. No conversion will be implemented on January 1, 2026.
Next fiscal year (starting from October 1, 2026 - September 30, 2027): This is the time when businesses are required to officially apply the new accounting regime according to Circular 99.
