The auditing firms approved by the State Securities Commission are listed as qualified auditing organizations to audit the financial statements of large-scale public companies, listed companies, and organizations issuing securities to the public, according to Clause 2, Article 21. Securities Law No. 54/2019/QH14 and Articles 5 and 6 Decree 84/2016/ND-CPThis is a mandatory obligation, further reinforced in Article 17 of Circular 183/2013/TT-BTC: entities with public interest may only select auditing firms from the list published by the State Securities Commission, and may not independently sign contracts with entities outside the list.
This list is reviewed and published annually by the State Securities Commission, usually before November 20th, based on the procedures stipulated in Decree 84/2016/ND-CP as amended. Decree 134/2020/ND-CPIf a business signs a contract with an entity not on the current list, its financial statements may be rejected when filing for listing, offering securities, or making periodic disclosures, directly affecting the progress of the IPO.
This article comprehensively summarizes the legal basis, review criteria, listing process, and practical risks that Vietnamese businesses often face when choosing an unsuitable auditing firm. The content is compiled based on practical experience advising numerous listed companies and those preparing for IPOs.
What are the auditing firms approved by the State Securities Commission of Vietnam (UBCKNN) according to legal regulations?
According to the Law on Independent Auditing No. 67/2011/QH12 and Decree No. 84/2016/ND-CP, an approved auditing organization is an auditing firm that has been reviewed and included in the public list by the competent authority, in this case the Ministry of Finance or the State Securities Commission. This list is updated annually, from January 1st to December 31st.
There are two types of lists that need to be clearly distinguished. One is the list of auditing firms approved by the Ministry of Finance, which applies generally to entities with public interest such as insurance companies and ordinary public companies. The second is... list of auditing firms Approved by the State Securities Commission, this applies specifically to entities with public interest in the securities sector. An auditing firm may be on both lists or only one, depending on whether its application meets the additional requirements specific to the securities sector.
From MAN's perspective, the separation of these two lists often confuses the chief accountants of newly listed companies, leading to them signing contracts with firms that are only qualified for general audits but not for securities auditing.
Why are listed companies required to choose an auditing firm from this list?
Clause 2 of Article 37 of the Law on Independent Auditing clearly stipulates that the annual financial statements of listed companies, public securities issuers, securities companies, and securities investment fund management companies must be audited. Article 17 of Circular 183/2013/TT-BTC adds the obligation that entities with public interest must select auditing firms and practicing auditors from the approved list and are not allowed to arbitrarily choose entities outside the list.
If violations occur, the consequences extend beyond simply having the financial statements deemed invalid. The stock exchange has the right to refuse the listing application, suspend trading of the shares, or require the company to have the entire report re-audited by another qualified entity, resulting in additional costs and delays in the IPO process.
Experts at MAN, with 30 years of experience, note that many businesses preparing for an IPO simply look up listings. auditing firm Approved at the time of contract signing, but forgetting that this list changes annually. An auditing firm that qualified the previous year may no longer be on the list the following year if it does not re-register or no longer meets the eligibility requirements.
Which entities are required to use auditing firms approved by the State Securities Commission of Vietnam?
According to Clause 2, Article 21 of the Securities Law 2019 and Article 4 of Decree 84/2016/ND-CP, as amended by Decree 134/2020/ND-CP, entities with public interest in the securities sector include:
- Large-scale public companies as regulated by securities law.
- Organizations listed on HOSE and HNX
- Organizations registered for trading on UPCoM
- Organizations offering securities to the public, including companies preparing for an IPO.
- Securities company
- Securities investment fund management company
- Securities investment companies and securities investment funds
For companies preparing for an IPO, this obligation arises at the moment of submitting the application for public offering of securities to the State Securities Commission. The financial statements attached to the application, usually the reports for the two most recent fiscal years, must be audited by an approved auditing firm.
What are the requirements for an auditing firm to be approved by the State Securities Commission?
Articles 5 and 6 of Decree 84/2016/ND-CP stipulate that auditing organizations wishing to be approved to audit public interest entities in the securities sector must simultaneously meet the following conditions, in addition to the general conditions for auditing public interest entities:
- Possesses a valid Certificate of Eligibility to Conduct Auditing Services issued by the Ministry of Finance.
- The company must have 15 or more practicing auditors, including a qualified Director or General Director.
- Must have a minimum of 36 consecutive months of auditing experience in Vietnam.
- Audit reports have been issued for at least 250 audited entities during the period from October 1st of the previous year to September 30th of the filing year.
- The quality control system meets the requirements of Vietnamese auditing standards.
- Professional liability insurance has been purchased or a professional liability reserve fund has been established.
- Not subject to restrictions or suspensions as stipulated in the Decree.
- Submit your application by the deadline of October 1st to October 20th each year.
For organizations that were approved in the previous year, the re-registration application also requires that they have issued audit reports for at least 20 public interest entities in the securities sector during the same review period. This is a major obstacle that makes it difficult for many small and medium-sized audit firms to maintain their approval status year after year, especially as the Vietnamese audit market tends to merge to meet the minimum size requirements.
The solution from MAN – Master Accountant Network for businesses during this period is to proactively review the legal status of their clients. auditing unit It is advisable to establish cooperation at the beginning of the fiscal year to avoid the situation where that entity is removed from the list midway, causing disruption to the information disclosure process.
What is the process and timing for the State Securities Commission (UBCKNN) to publish the annual list?
The review process follows a fixed schedule each year:
- From October 1st to October 20th: auditing firms submit registration documents to the Ministry of Finance, and also submit an additional set of documents to the State Securities Commission if registering to audit the securities sector.
- Within 10 working days of receiving the application, if the application is incomplete, the competent authority will request additional information, with the deadline for completion being November 5th.
- Before November 20th of each year: The State Securities Commission reviews, approves, and publicly announces the list of approved auditing firms and practicing auditors on its electronic portal.
- The list is valid for the next calendar year approval period, from January 1st to December 31st.
Businesses should note that the list is updated whenever there are changes during the year, for example, when an auditing firm is suspended or has its approved status revoked due to violations. Therefore, simply checking the list once at the beginning of the year is insufficient; businesses should re-check it at the time of signing the formal audit contract.
Compilation of legal documents related to auditing firms approved by the State Securities Commission.
The table below summarizes the current legal documents that serve as the basis for determining the conditions and procedures for approving auditing firms:
| Document | Date of issuance | Main content |
| Law on Independent Auditing No. 67/2011/QH12 | 29/03/2011 | Regulations outlining the principles, subjects of mandatory auditing, and standards for auditors. |
| Decree 17/2012/ND-CP | 13/03/2012 | Detailed guidelines for implementing the Law on Independent Auditing. |
| Circular 183/2013/TT-BTC | 04/12/2013 | Regulations on independent auditing for entities with public interest, and the obligation to select an approved auditing firm. |
| Decree 84/2016/ND-CP | 01/07/2016 | Standards and conditions for practicing auditors and audit firms approved to audit public interest entities. |
| Securities Law 2019 | 26/11/2019 | Identify entities with public interest in the securities sector as stipulated in Clause 2, Article 21. |
| Decree 134/2020/ND-CP | 05/11/2020 | Amend and supplement Article 4 of Decree 84/2016/ND-CP to conform with the Securities Law 2019. |
| Decree 90/2025/ND-CP | 14/04/2025 | Amendments and additions to Decree 17/2012/ND-CP include criteria for identifying large-scale enterprises subject to mandatory auditing. |
This is a system of documents that any chief accountant or financial director responsible for listing filings needs to be familiar with, as each revision can change the scope of mandatory audits or the conditions for auditor approval.
What entities are included in the list of auditing firms approved by the State Securities Commission?
The number of auditing firms approved by the State Securities Commission of Vietnam (UBCKNN) for the securities sector fluctuates each year, reflecting the increasingly stringent screening process by the regulatory body. In 2020, the list included 30 companies, in 2023 it remained around 30, while the 2025 list published by VACPA includes 27 qualified auditing firms and auditors.
The following groups of businesses have consistently appeared on the list for many consecutive years, due to their workforce size and customer base exceeding the minimum threshold:
- KPMG Limited
- Ernst & Young Vietnam Co., Ltd.
- Deloitte Vietnam Co., Ltd.
- PwC (Vietnam) Company Limited
- AASC Auditing Firm Co., Ltd.
- A&C Auditing and Consulting Company Limited
- Grant Thornton (Vietnam) Co., Ltd.
- AAC Auditing and Accounting Company Limited
In addition to the above group, the annual list also includes several medium-sized auditing firms that meet the criteria, such as AFC Vietnam Audit, Moore AISC, UHY, and Ecovis AFA Vietnam, depending on the review results of each period.
Because the official list changes annually, businesses should not rely on the previous year's list to sign contracts for the current fiscal year. The safest approach is to check directly. List of auditing firms and auditors approved by the State Securities Commission. Published at the most recent time on the official electronic portal of the State Securities Commission or website. Vietnam Association of Certified Public Accountants (VACPA).
What's new in the list of auditing firms approved by the State Securities Commission in 2026?
On November 19, 2025, the Chairman of the State Securities Commission issued Decision No. 902/QD-UBCK approving the list. 28 auditing organizations and 794 practicing auditors The number of qualified auditing firms for public interest entities in the securities sector will increase to 28 in 2026. Compared to 2025, the number of approved auditing firms increased from 27 to 28. During the year, the State Securities Commission also continued to issue additional auditor notices, indicating that this list is regularly updated and not fixed after the initial decision.
In addition, the Ministry of Finance issued Decision No. 3830/QD-BTC dated November 14, 2025, approving... 35 auditing firms and 900 practicing auditors Eligible to audit entities with public interest in 2026. This list has a broader scope, while the securities sector must meet stricter criteria set by the State Securities Commission. Therefore, only 28 organizations approved by the State Securities Commission are eligible to audit entities in this sector.
Listed companies, large-scale public companies, and companies preparing for IPOs in 2026 need to compare their performance. List of 28 auditing organizations according to Decision 902/QD-UBCK when choosing a unit audit of financial statements, instead of just referring to the list provided by the Ministry of Finance. The detailed list is published on the website of the State Securities Commission. and republished by VACPA. Since the list may be updated or revised throughout the year, businesses should regularly check the official source for updated information.
Real-life case study: IPO-preparing company chooses the wrong auditing firm.
A manufacturing company in the southern region, with a registered capital of approximately 300 billion VND, plans to conduct an initial public offering (IPO) in the third quarter. Three months before filing the application, the company signed... financial statement audit contract For the past two years, this small-scale auditing firm has been on the list of firms approved by the Ministry of Finance to audit public interest entities in general, but it has never registered, and therefore has not been approved by the State Securities Commission for the securities sector.
When the IPO registration documents were submitted to the State Securities Commission, the review department discovered that the auditing firm was not on the list of firms specifically approved for the securities sector. The entire financial report had to be re-audited from scratch by a qualified firm, causing the IPO plan to be delayed by more than four months, incurring additional auditing and legal consulting costs.
This situation reveals that the root cause lies not in the professional quality of the initial auditing firm, but in the company's failure to clearly distinguish between the two types of approval lists mentioned above. This is a common mistake, especially for companies undergoing the listing procedure for the first time and lacking a dedicated financial and legal department.
Expert opinion: Common risks Vietnamese businesses face when choosing an auditing firm.
Based on years of experience advising listed companies, the following three risks appear most frequently.
- Firstly, businesses often choose an auditing firm based on the lowest fee, neglecting to verify its eligibility for the specific field of activity. An auditing firm qualified to audit an insurance company may not necessarily be qualified to audit a publicly listed company.
- Secondly, businesses often sign multi-year audit contracts with the same firm without updating that firm's legal status with each new approval period. It is not uncommon for an audit firm to have its status suspended or revoked mid-financial year, especially if that firm fails to meet the minimum client retention requirements.
- Thirdly, and perhaps most subtly, is the possibility of a change in the practicing auditor responsible for signing the report without the company verifying it. The law stipulates that a practicing auditor cannot sign an audit report for the same audited entity for more than three consecutive years, in order to ensure independence. If the company fails to monitor this regulation, the audit report may be deemed invalid even if the auditing firm remains on the approved list.
Experts at MAN, with 30 years of experience, note that managing tax risk and audit compliance risk in Vietnam should be viewed as an ongoing process throughout the financial year, not just a one-time procedure before reporting season. A deep understanding of the realities of tax risk management in Vietnam helps businesses avoid being caught off guard when regulatory authorities discover discrepancies in the auditor's qualifications just before the information disclosure deadline.
Conclude
Choosing the right auditing firm from the list approved by the State Securities Commission is not merely an administrative procedure, but a prerequisite for the validity of a company's listing, securities offering, or periodic information disclosure applications. With a continuously updated legal framework, from the Law on Independent Auditing, Decree 84/2016/ND-CP to Decree 90/2025/ND-CP, businesses need to proactively conduct periodic reviews instead of just checking once when starting a partnership with an auditing firm.
In the journey of complying with auditing laws and financial risk management, MAN – Master Accountant Network accompanies listed companies, public companies, and companies preparing for IPOs through auditing servicesMAN provides accounting and tax consulting services. With a team of experts boasting over 30 years of practical experience in the Vietnamese market, MAN assists businesses in reviewing the legal standing of auditing firms, standardizing financial records, and minimizing compliance risks before each reporting period or public offering of securities.
Service contact information at MAN – Master Accountant Network
- Address: No. 19A, Street 43, Tan Thuan Ward, Ho Chi Minh City
- Mobile/Zalo: 0903 963 163 – 0903 428 622
- E-mail: man@man.net.vn
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Responsible for production and professional content review by: Mr. Le Hoang Tuyen – Founder & CEO of MAN – Master Accountant Network, CPA Vietnam with over 30 years of experience in accounting, auditing, taxation, and corporate financial consulting.
Frequently Asked Questions about Audit Firms Approved by the State Securities Commission (SSC) (FAQ)
Where can I find the updated list of auditing firms approved by the State Securities Commission?
The list is officially published on the electronic portal of the State Securities Commission and is republished annually by VACPA, usually before November 20th.
Are unlisted public companies required to use auditing firms from this list?
Yes, if the business is classified as a large-scale public company under securities law, as it remains a public interest entity in the securities sector according to Article 21 of the 2019 Securities Law.
If an auditing firm is removed from the list mid-fiscal year, are the previously audited reports still valid?
Reports issued before the suspension or revocation of accreditation remain valid, but the business must terminate the contract and select another approved auditing firm for subsequent reports.
Are the list of auditing firms approved by the Ministry of Finance and the list of the State Securities Commission the same?
They are not exactly the same. The Ministry of Finance's list applies to public interest entities in general, while the State Securities Commission's list applies specifically to the securities sector with stricter requirements regarding the number of auditors and years of experience.
When should companies preparing for an IPO check this list?
It is advisable to conduct a review at the very beginning of planning the audit of financial statements for a public offering, at least six months before the expected filing date, to allow sufficient time to address any necessary changes to the auditing firm.
