Official Document 66/QLKT-DN Issued on January 15, 2026, by the Accounting and Auditing Supervision Department, this document provides key guidance for newly established businesses at the end of 2025. In this context... Accounting Law 2015 It was recently amended and supplemented in 2024 and Circular 99/2025/TT-BTC With the law about to come into effect, determining the first accounting period becomes a crucial legal issue for every professional accountant.
The issuance of Circular 66/QLKT-DN clarifies the boundary between the application of the old accounting system (Circular 200) and the new system (Circular 99). For entities conducting audits and tax settlements, correctly understanding the spirit of this circular not only helps avoid presentation errors but also optimizes the documentation process when working with the Tax authorities. Let's explore the key points in detail below.
Official Document 66/QLKT-DN: Detailed guidance on consolidating financial statements for 2025
Official Letter 66/QLKT-DN addresses a common issue: Can businesses established in the last days of 2025 (for example, from December 10, 2025) immediately apply Circular 99/2025/TT-BTC? The answer from the regulatory agency is very clear, based on the principle of retroactive effect and accounting period.
The effective date of Circular 99/2025/TT-BTC is based on Official Letter 66/QLKT-DN.
According to Official Letter 66/QLKT-DN, Circular 99/2025/TT-BTC takes effect from January 1, 2026, and applies to fiscal years beginning on or after this date. Therefore, activities arising before 2026 must still comply with the current regulations in Circular 200/2014/TT-BTC. Official Letter 66/QLKT-DN affirms that there is no basis for applying Circular 99 before its effective date.
Regulations on consolidating accounting periods are outlined in Official Letter 66/QLKT-DN.
Based on Article 12 of the 2015 Accounting Law, Circular 66/QLKT-DN reiterates that if the first accounting period lasts no more than three consecutive months, it may be combined with the subsequent accounting period. However, Circular 66/QLKT-DN also emphasizes the enterprise's right to choose: if they do not wish to combine, enterprises can still prepare separate accounting periods. financial reports Specifically for the final days of 2025.
| Comparison content | Individual accounting periods | Cumulative accounting period (Accumulated) |
| Applicable period | From the date of establishment until December 31, 2025 | From the date of establishment until December 31, 2026 |
| Accounting system | Circular 200/2014/TT-BTC | Circular 99/2025/TT-BTC (part for 2026) |
| According to Official Letter 66/QLKT-DN | In accordance with legal regulations | It must be ensured that it does not exceed 15 months. |
Detailed analysis of the Accounting Law and Circular 66/QLKT-DN regarding the accounting period.
To properly implement Circular 66/QLKT-DN, we need to understand the changes in Clause 4, Article 2 of the 2024 amended Law. Circular 66/QLKT-DN serves as a bridge explaining how this Law will operate during the transition period of 2025-2026.
first and last accounting periods
Official Document 66/QLKT-DN indicates that if a business is established from October 1, 2025 onwards, and its operating time in 2025 is less than 3 months, then according to Official Document 66/QLKT-DN, the business has the right to apply to combine the 2025 accounting period with the 2026 accounting period to save on auditing costs and administrative procedures.
Notify the finance and tax authorities.
Although Circular 66/QLKT-DN allows for flexibility, changes or consolidations of accounting periods must be notified in writing. Circular 66/QLKT-DN notes that consistency in accounting policies is paramount to ensuring transparency for independent audit firms.
Deadline for submitting financial reports for 2026, as per Official Letter 66/QLKT-DN.
Having understood how to consolidate accounting periods through Circular 66/QLKT-DN, businesses need to pay attention to the deadline for submitting documents. Circular 99/2025/TT-BTC stipulates very strict deadlines, which Circular 66/QLKT-DN constantly reminds businesses to comply with.
The fateful 90-day milestone
Similar to previous regulations but more standardized, Circular 66/QLKT-DN confirms that businesses must submit their annual financial statements no later than 90 days from the end of the accounting period. If you apply Circular 66/QLKT-DN to combine 2025 into 2026, the submission deadline will be March 31, 2027.
Term for the Parent Company and the Group
For subsidiary units, Circular 66/QLKT-DN instructs that the submission deadline must be consistent with the consolidation requirements of the parent company. Failure to submit as instructed in Circular 66/QLKT-DN may result in severe administrative penalties for accounting violations.
List of 8 sample annual financial statements according to Circular 99 and Official Letter 66/QLKT-DN
Official Letter 66/QLKT-DN indirectly reminds us about the conversion of forms starting in 2026. Below is a summary table of forms according to Circular 99 that accountants need to prepare after studying Official Letter 66/QLKT-DN.
Financial statements for going concern businesses (Based on Circular 99)
- Form B 01 – DN: Statement of Financial Position (Replacing the old Balance Sheet).
- Form B 02 – DN: Business performance report.
- Form B 03 – DN: Cash flow statement.
- Form B 09 – DN: Notes to the Financial Statements.
Financial statements for businesses that do not meet the going concern assumption.
If a business is in a state of dissolution or bankruptcy, Circular 66/QLKT-DN and Circular 99 require the use of a separate system of forms (symbol DNKLT) to accurately reflect the net recoverable asset value.
Conclude
Circular 66/QLKT-DN serves as a guiding principle for businesses during the turbulent transition period of 2025-2026. Understanding and correctly applying Circular 66/QLKT-DN not only helps businesses comply with the law but also creates a solid foundation for transparent financial management. The guidelines on consolidating accounting periods in Circular 66/QLKT-DN are truly a useful administrative solution for businesses newly entering the market.
To ensure your company's tax return and financial statements are fully compliant with Circular 66/QLKT-DN, partner with MAN – Master Accountant Network.
Service contact information at MAN – Master Accountant Network
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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 Official Document 66/QLKT-DN
Can I use Official Document 66/QLKT-DN to combine the last four months of the year?
No. According to Official Letter 66/QLKT-DN and the Accounting Law, consolidation is only permitted when the accounting period does not exceed 3 consecutive months.
Does Official Document 66/QLKT-DN apply to household businesses?
Official document 66/QLKT-DN focuses on providing guidance for businesses. Household businesses have their own accounting system according to Circular 88.
If I don't consolidate as per Official Letter 66/QLKT-DN, when do I have to submit my 2025 financial statements?
You must submit it no later than March 31, 2026, according to the current accounting regulations (Circular 200 or Circular 133).
