How to submit explanatory notes to financial statements via the Public Service portal. This is one of the mandatory administrative procedures that corporate accountants need to perform when settling taxes for 2026. In the context of strong digital transformation, mastering the electronic process not only helps businesses comply with legal regulations but also reduces the risk of administrative penalties due to late or incorrect filing.
According to statistics from the General Department of Taxation, currently more than 991 businesses have filed their taxes online. In particular, with the introduction of... Circular 99/2025/TT-BTCSignificant adjustments have been made to the regulations regarding currency and the presentation of the Financial Statement Notes. Submitting the explanatory notes along with the corporate income tax return is a mandatory requirement for the application to be considered valid.
Legal regulations regarding the Notes to the Financial Statements for 2026
Before delving into how to submit financial statement disclosures, accountants need to be familiar with current legal regulations. In 2026, businesses will adopt the accounting system according to... Circular 200/2014/TT-BTC (for large businesses) or Circular 133/2016/TT-BTC (for small and medium-sized enterprises), in conjunction with the amendments in Circular 99/2025/TT-BTC which has just come into effect.
Explanation Financial reports This document is an integral part of a company's financial statements. It is used to provide a detailed analysis of the figures presented in the Statement of Financial Position, the Statement of Income, and the Statement of Cash Flows. Without this explanatory note, the tax authorities have the right to refuse to accept the tax return or request further explanation.
The importance of submitting financial statement disclosures on time.
Submitting financial statement disclosures on time (no later than the last day of the third month from the end of the calendar year or fiscal year) helps businesses comply with the law.
Specifically, this helps businesses avoid administrative penalties for tax violations under Decree 125/2020/ND-CP. At the same time, businesses provide complete information about their accounting policies to relevant parties and ensure transparency when explaining significant financial fluctuations during the year.
How to submit financial statement explanations via the latest detailed instructions for 2026.
The current filing process has been optimized through the General Department of Taxation's Public Service Portal. Depending on whether your business uses accounting software or files directly, you can choose one of the following two methods.
Step 1: Log in to the administrative procedure processing information system.
To submit the financial statement disclosures, please visit: https://dichvucong.gdt.gov.vn/tthc/homeloginHere, you press the button. "Log in" In the top right corner, use the tax identification number and password provided. Make sure the Digital Signature (USB Token or remote digital signature like MISA eSign) is ready on the device.
Step 2: Declare and submit the Corporate Income Tax Return (Form 03/TNDN)
In the menu ADMINISTRATIVE PROCEDURESTo do this, search for the code: “03/TNDN – Corporate Income Tax Final Settlement Declaration (Circular 80/2021)” and press Enter. Paper. How to submit explanatory notes to financial statements This will accompany this step.
You can file online or upload the XML file from the HTKK software. Submitting an XML file minimizes data entry errors and saves time for accountants when the file contains many complex appendices.
Step 3: Attach the Explanatory Notes to the Financial Statements
After signing the main form, the system moves to the "Attach Documents" section. This is a crucial step. How to submit explanatory notes to financial statementsFind the line "Explanatory Notes to Financial Statements", then click Select and upload the file. The PDF format is recommended for data security and to avoid display errors.
Step 4: Digitally sign and complete the document submission.
Finally, you digitally sign the entire document using a PIN code or confirm it remotely via the CKS application. Press Continue Until you receive the "Application submitted successfully" notification, please download the confirmation message to your computer as proof for record-keeping during the settlement period.
Summary of documents required when submitting financial statement explanations.
Before submitting the explanatory notes to the financial statements through the electronic tax system, businesses need to prepare a complete set of financial statements and tax return forms in the correct format. Carefully checking each document helps avoid errors when uploading them to the system, especially the step of attaching the explanatory notes to the financial statements – a common mistake many accountants make. The table below summarizes the mandatory documents that need to be prepared when submitting the documents.
| No. | Document type | Request format | Important note |
| 1 | Corporate Income Tax Return Form 03/TNDN | XML | Matches the business results appendix. |
| 2 | Financial statement | XML/PDF | According to Circular 200 or 133 |
| 3 | Business Performance Report | XML/PDF | Compare with the revenue stated on the tax return. |
| 4 | Cash flow statement | XML/PDF | Direct/Indirect Method |
| 5 | Explanatory notes to the financial statements | DOCX/PDF | Attachment is mandatory at the appendix step. |
Many accountants often forget this attachment step, causing the system to report the file as "Incomplete". Therefore, controlling the document list is extremely important.
Explain the reason for the change in currency unit in the notes to the financial statements.
The method for submitting the 2026 financial statement disclosures requires special attention to the currency unit as stipulated in Article 5 of Circular 99/2025/TT-BTC. Enterprises are permitted to change their currency unit at the beginning of the fiscal year if there are significant changes in their management and business operations.
In the explanatory statement, businesses are required to clearly state the reasons for the change, the significant impact on financial indicators, and the exchange rate applied when converting the balances. A detailed explanation helps tax authorities and auditors easily assess the reasonableness of the new figures.
Information to be presented when converting financial statements to Vietnamese Dong.
According to Article 6 of Circular 99/2025/TT-BTC, enterprises using foreign currency as their accounting currency must convert it to Vietnamese Dong (VND) when submitting reports. The submission of financial statement explanations now requires absolute transparency regarding the conversion method.
Businesses must clearly state the impact of exchange rate differences and how they are handled (recorded under "Exchange Rate Differences" in equity). A lack of this information can lead to inaccurate assessments of the entity's financial capacity by regulatory authorities.
Common mistakes when submitting financial statement disclosures.
The most common error is the inability to attach files due to large size or incorrect formatting. Accountants should compress PDF files to under 5MB and use filenames without accents. Another error is discrepancies between the figures in the explanatory notes and the tax return.
To process this, you need to cross-check the profit and corporate income tax figures. The correct way to submit the financial statement notes is to ensure that all figures in the attached file are completely consistent with the previously signed XML file.
Conclude
Submitting financial statement explanations through the Public Service portal will become simpler if accountants follow the correct technical procedures and keep up-to-date with Circular 99/2025/TT-BTC. These explanations play a crucial role in clarifying the financial health of a business before the law.
To optimize tax payments and ensure transparent documentation, businesses can seek professional solutions. MAN – Master Accountant Network provides reputable financial statement auditing and tax consulting services. Our team of experts is ready to work with you to help you submit your financial statement disclosures safely and effectively. Contact MAN today!
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Content production by: Mr. Le Hoang Tuyen – Founder & CEO MAN – Master Accountant Network, Vietnamese CPA Auditor with over 30 years of experience in Accounting, Auditing and Financial Consulting.
Frequently Asked Questions about Submitting the 2026 Financial Statement Notes
What is the deadline for submitting the explanatory notes to the 2026 financial statements?
The deadline is the last day of the third month following the fiscal year. For the calendar year 2025, the deadline is March 31, 2026.
What is the penalty for forgetting to submit the explanatory notes to the financial statements?
According to Decree 125/2020/ND-CP, the penalty for incomplete tax documents (lacking supporting appendices) ranges from 2 to 5 million VND.
Is it possible to submit supplementary explanatory notes online?
Yes, you can use the "Submit Appendix" function on the Public Service portal to upload the missing file after submitting the main declaration.
