The requirements for practicing auditing are something that any auditor must understand before signing a contract. audit report Independence in Vietnam. According to Law on Independent Auditing No. 67/2011/QH12, as amended and supplemented by Law No. 56/2024/QH15 (Effective from January 1, 2025), an individual can only be considered a practicing auditor if they simultaneously meet several sets of conditions: professional certification, actual auditing experience, hours of continuing education, and a full-time employment contract with an auditing firm.
In many cases, applications are rejected by the Ministry of Finance or auditors are suspended from practice simply because they lack one of the seemingly minor conditions, such as incorrect calculation of actual working time or incomplete documentation. This article systematizes all current regulations, along with practical examples and important notes. MAN – Master Accountant Network This conclusion is drawn from many years of working alongside auditors and audit firms in Vietnam.
Summary of key requirements for practicing auditing
- The conditions for practicing auditing are a set of mandatory legal standards required for an auditor to be granted a Certificate of Registration for Auditing Practice.
- Main basis: Law on Independent Auditing 2011 (amended by Law No. 56/2024/QH15), Circular 202/2012/TT-BTC (amended by Circular 22/2024/TT-BTC and Circular 05/2025/TT-BTC).
- Target audience: Individuals holding a Certified Public Accountant (CPA Vietnam) certificate who wish to practice at an auditing firm.
- The four core requirements are: being a qualified auditor, having at least 36 months of practical experience, meeting the required hours of continuing education, and having a full-time employment contract.
- Complete documentation must be prepared and submitted through an auditing firm to obtain a certificate from the Ministry of Finance within 15 working days.
What are the legal requirements for practicing auditing?
According to Article 17 of the Law on Independent Auditing, as detailed in Article 3 of Circular 202/2012/TT-BTC, the conditions for practicing auditing are a set of standards that an individual must meet to be granted a Certificate of Registration for Auditing Practice by the Ministry of Finance. This is a mandatory requirement, different from simply possessing an Auditor Certificate.
Many people confuse the two concepts. A Certified Public Accountant (CPA) certificate only proves professional competence that has been assessed. However, to practice, that is, to be authorized to sign audit reports, an individual must register and obtain a separate certificate associated with a specific auditing firm.
Four groups of mandatory conditions:
According to Article 3 of Circular 202/2012/TT-BTC, the conditions for practicing auditing include the following four groups:
- Being an auditor means having full legal capacity, good moral character, a university degree in a relevant field, and an Auditor Certificate issued by the Ministry of Finance.
- Applicants must have at least 36 months of practical auditing experience, counting from the date of their university degree.
- Sufficient hours of continuing education as prescribed by the Ministry of Finance.
- I have a full-time employment contract with an auditing firm.
If any of these four conditions are missing, the application for professional practice registration will not be approved.
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The role of auditing practice requirements in financial risk management.
The requirements for practicing auditing are not merely administrative procedures. They are a screening mechanism to ensure that those signing audit reports truly possess the necessary competence, experience, and professional ethics. Audited financial statements directly impact the decisions of investors, banks, tax authorities, and shareholders.
From the perspective of MAN – Master Accountant Network, an unqualified auditor signing a report renders it legally invalid. Businesses using this report for loans, fundraising, or tax settlements may face the risk of having their application rejected or even being held liable.
Strict control over auditing practice conditions also helps the auditing services market in Vietnam maintain its reputation in the eyes of foreign investors, especially as FDI flows into Vietnam increasingly depend on the transparency of financial reporting.
Who needs to meet the qualifications to practice auditing?
Not everyone has an accounting degree. audit They also need to meet the requirements for practicing auditing. The mandatory group includes:
- I am an individual who already holds a Certified Public Accountant (CPA Vietnam) certificate and wishes to have my audit report signed independently.
- Individuals holding internationally recognized auditing certifications (such as ACCA, CPA Australia, CA) and who have passed the Vietnamese law examination in Vietnamese.
- Auditors currently working at auditing firms or branches of foreign auditing firms in Vietnam, who wish to register for official practice at that entity.
Students or recent graduates with a degree in finance, accounting, or auditing who do not yet possess an auditor's certificate are not directly eligible. However, this group of readers should be aware of the regulations early on to develop a roadmap for accumulating 36 months of practical experience alongside preparing for the certification exam.
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Details of each condition for practicing auditing according to current regulations.
Standards for becoming an auditor
According to Article 14 of the Law on Independent Auditing, a person wishing to become an auditor must have full civil capacity, good moral character, a sense of responsibility, integrity, honesty, and objectivity. Regarding education, they must have a university degree or higher in finance, banking, accounting, auditing, or other fields as prescribed by the Ministry of Finance.
The most important prerequisite remains a valid Auditor Certificate, issued by the Ministry of Finance after the examination as per Circular 91/2017/TT-BTC. In the case of possessing a recognized foreign audit certificate, the individual must pass a Vietnamese law examination in Vietnamese and meet two standards regarding civil capacity and ethical conduct.
Actual time spent doing audits must be at least 36 months.
This is the most time-consuming requirement for many people to meet when applying to practice auditing. The actual time spent auditing is calculated as the total time worked at an auditing firm under a full-time employment contract, accumulated from the time of receiving the university degree to the time of application, based on whole months.
This period must be confirmed by the legal representative or authorized person of the auditing firm where the auditor worked. If that firm has been dissolved, gone bankrupt, split, separated, merged, consolidated, or changed its ownership structure, the applicant needs to obtain confirmation from the legal representative corresponding to the period of employment at that auditing firm.
If the legal representative of the auditing firm at that time is no longer active in the independent auditing field, the auditor must submit an explanation along with supporting documents proving the actual time spent auditing, such as a copy of the social insurance book or a copy of the employment contract.
Enough time to update your knowledge.
Practicing auditors are required to attend the required number of annual continuing education hours as stipulated by the Ministry of Finance, usually through training courses organized by the Vietnam Association of Certified Public Accountants (VACPA) or international professional organizations. This requirement is often overlooked when auditors are busy with the peak audit season at the end of the year and the beginning of the following year.
Full-time employment contract
Auditors must have a full-time employment contract with the auditing firm, with actual daily and weekly working hours consistent with the firm's operating hours. For example, if the firm operates from 8 am to 5 pm, six days a week, the auditor must work the full hours, excluding overtime or days off.
Specifically, practicing auditors are prohibited from simultaneously holding positions as legal representatives, directors, chairmen of the board, chief accountants, or internal auditors at other entities while working at the auditing firm. This regulation aims to ensure independence, one of the core principles of independent auditing.
Cases where individuals are not eligible to register for auditing practice.
According to Article 16 of the Law on Independent Auditing, certain groups of individuals, even with sufficient professional certifications, are not allowed to register to practice auditing, including:
- Officials, civil servants, and public employees working in the public sector.
- The person is prohibited from practicing auditing according to a legally binding court judgment or decision.
- Individuals who are currently under criminal investigation, or who have been convicted of economic crimes or offenses related to finance and accounting and whose criminal records have not yet been expunged.
- Individuals who are subject to administrative measures such as community-based education or placement in a medical facility or educational institution.
- Individuals with prior convictions for serious or more serious economic crimes.
- Individuals who violate laws regarding finance, accounting, auditing, and economic management and are subject to administrative penalties within one year from the date of the penalty decision.
Furthermore, Law No. 56/2024/QH15 adds specific regulations regarding individuals who are prohibited from continuing to practice auditing during their tenure, tightening the requirements compared to the previous law which only stipulated entry-level conditions.
Application documents and procedures for practicing auditing in 2026
Required documents
Based on Article 4 of Circular 202/2012/TT-BTC, as amended by Circular 22/2024/TT-BTC and Circular 05/2025/TT-BTC, the application dossier for auditing practice includes:
- Application for a Certificate of Registration for Auditing Practice, using the form in Appendix No. 01/ĐKHN.
- A copy of the full-time employment contract with the auditing firm.
- A certificate confirming the actual time spent on auditing, in the prescribed form, or supporting documents, or an explanation accompanied by supporting documents regarding the actual time spent on auditing, except for cases exempted under Article 16 of Circular 202/2012/TT-BTC.
- Personal information form as prescribed.
- The criminal record certificate must be issued no more than six months prior to the date of application.
- Two color photographs, 3x4cm in size, taken against a white background within the last six months.
- A copy of the termination notice or employment contract termination notice from the previous employer, if applicable.
- A copy of the work permit in Vietnam for foreign auditors, except in cases where Vietnamese labor law stipulates that a work permit is not required.
- Documentation proving the auditor's continuing education hours at international professional organizations in accounting and auditing, applicable to cases where continuing education hours are counted under this category.
Important note: Since Circular 22/2024/TT-BTC came into effect, the requirement for a copy of the Auditor's Certificate in the application file has been abolished, as this data is now centrally managed by the Ministry of Finance. This is a point where many auditors still prepare excessive documentation due to old habits.
The five-step registration process
- Auditors prepare a dossier and submit it to the Ministry of Finance through the auditing firm where they work. Diplomas and certificates in foreign languages must be accompanied by notarized translations or certified translations by competent authorities. Auditors are responsible for the information declared in the dossier; the auditing firm and organizations and individuals involved in verifying the information in the dossier are also jointly responsible for the accuracy of the verified information.
- The legal representative of the auditing firm reviews the application, confirms that the applicant meets the eligibility requirements for professional registration, and signs the application form.
- Audit firms compile the auditors' files and send them directly or by mail to the Ministry of Finance.
- In cases requiring clarification, the Ministry of Finance has the right to request explanations or additional documents such as social insurance records. If the explanatory documents cannot prove their authenticity, the Ministry of Finance has the right to refuse the request and provide a written response stating the reasons.
- Within 15 days of receiving a valid application, the Ministry of Finance will review and issue a Certificate of Registration for Auditing Practice. The issuance date must not be earlier than the effective date of the full-time employment contract at the auditing firm.
Compilation of legal documents on the conditions for practicing auditing
Important note: Experts at MAN recommend that auditors and audit firms regularly consult the latest consolidated text, as the Independent Auditing Law has undergone several consecutive amendments during the 2024-2025 period, resulting in a series of updated guiding circulars.
| Legal documents | Number / Date of Issue | Related content |
| Independent Auditing Law 2011 | No. 67/2011/QH12 | Original regulations on the conditions and standards for practicing auditors (Articles 14, 16, 17) |
| Law amending and supplementing | Resolution No. 56/2024/QH15, effective January 1, 2025 | Additional regulations regarding the obligations of auditing firms and individuals who are prohibited from continuing to practice the profession. |
| Decree 17/2012/ND-CP | March 13, 2012 | Detailed guidelines for implementing the Law on Independent Auditing. |
| Decree 90/2025/ND-CP | April 14, 2025 | Amend Decree 17/2012, adding criteria for entities eligible for large-scale audits. |
| Circular 202/2012/TT-BTC | November 19, 2012 | Guidelines for registering, managing, and publicly disclosing the list of practicing auditors. |
| Circular 22/2024/TT-BTC | March 26, 2024 | Amendments to the registration form, removing the requirement for a copy of the Auditor's Certificate. |
| Circular 05/2025/TT-BTC | January 24, 2025 | Continue revising Circulars 202/2012, 203/2012 and 157/2014 on quality control of audit services. |
| Circular 91/2017/TT-BTC | August 31, 2017 | Regulations on examination, issuance, and management of auditor certificates. |
Case study: An auditing firm in Ho Chi Minh City processes professional registration applications.
Background
Audit firm Y in Ho Chi Minh City has 18 auditors, 5 of whom recently passed the 2025 Auditor Certification exam and wish to register to practice immediately during the 2026 financial statement audit season. The problem is: 2 of these 5 previously worked at an audit firm that has merged with another entity, making it difficult to obtain confirmation of their actual auditing experience.
How to handle it
According to advice from MAN – Master Accountant Network, Company Y has taken the following steps: (1) contact the current legal representative of the merged entity to request confirmation of the corresponding working time; (2) for the time that cannot be directly confirmed, prepare an explanation along with the social insurance book and old labor contract as proof; (3) review all documents according to the latest form after Circular 22/2024/TT-BTC and Circular 05/2025/TT-BTC come into effect, avoiding submitting missing or extra documents.
Result
All five audit reports were approved by the Ministry of Finance within the 15-working-day deadline, with no further requests for additional documentation. Company Y was able to promptly recruit additional personnel to sign reports during the peak audit season, avoiding a shortage of qualified auditors when clients urgently requested audit reports for shareholder meetings.
Comparison table of groups of conditions for practicing auditing
To practice auditing in Vietnam, individuals must simultaneously meet several conditions regarding expertise, experience, up-to-date knowledge, and legal status as stipulated in the Law on Independent Auditing. Below is a summary table of the important conditions and their corresponding certifying bodies, to help you easily track and compare them when preparing your application for practice.
| group of conditions | Specific requirements | Certification body |
| Professional certification | Possesses a valid auditor's certificate issued by the Ministry of Finance. | Ministry of Finance |
| Actual time | From 36 months of auditing experience, calculated in full months. | The auditing firm where I worked |
| Time for a knowledge update. | The required number of hours per year. | VACPA or an accredited training organization |
| Employment contract | Full-time position, no conflicting job titles. | Current auditing firm |
| Criminal record | Not included in the prohibited group under Article 16 of the Law on Independent Auditing. | competent judicial authority |
Expert opinion: Common risks when meeting the requirements for practicing auditing.
After more than 30 years of providing audit and accounting consulting services to businesses in Vietnam, experts at MAN – Master Accountant Network have identified four of the most common risks faced by auditors and audit firms.
- Risk 1: Miscalculating the actual time spent on the audit: Many auditors include part-time work, internships, or accounting experience at regular businesses in the required 36 months. In reality, only full-time employment under a contract at the auditing firm is counted. This error leads to rejected applications and delays in obtaining certification.
- Risk 2: Documents lack valid verification when the previous business has been dissolved. When the auditing firm where they previously worked ceases operations, many auditors don't know how to obtain replacement confirmation and abandon their applications. The solution from MAN – Master Accountant Network is to prepare a written explanation early, along with supporting documents such as social insurance records and termination notices, to avoid being caught off guard when urgent applications need to be submitted.
- Risk 3: Violation of the principle of independence due to holding multiple positions: Some auditors still hold the title of director or chief accountant at other businesses while registering to practice auditing, directly violating regulations on full-time employment contracts and professional independence. This is an error that can lead to the revocation of their certification if discovered during inspections and audits of the quality of auditing services.
- Risk 4: Failure to keep up-to-date with revised circulars: The period 2024-2025 saw the consecutive issuance of Circular 22/2024/TT-BTC and Circular 05/2025/TT-BTC amending regulations on application forms and templates for auditing practice registration. Auditing firms continued to use outdated and unupdated forms, resulting in applications being returned for revisions and further delays during peak audit seasons.
Conclude
The conditions for practicing auditing are fundamental to ensuring the quality and legality of every audit report issued in Vietnam. From certification standards, experience duration, and knowledge update hours to full-time employment contracts, each condition is linked to a specific goal: protecting the independence and reliability of the auditing profession. Accurately updating the revised regulations in the 2024-2025 period will help auditors and audit firms avoid unnecessary risks when submitting applications.
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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 the Requirements for Practicing Auditing
How much experience is required to qualify as an auditor?
A minimum of 36 months of practical auditing experience at an auditing firm is required, calculated cumulatively in full months from the date of university degree.
Can I practice auditing immediately after obtaining my auditor's certificate?
No. The auditor certification is only one of four requirements. Individuals must still have 36 months of experience, sufficient hours of continuing education, and a full-time employment contract to be eligible to register to practice.
Can foreigners with international auditing certifications practice in Vietnam?
Yes, if the certificate is recognized by the Ministry of Finance and the person passes the Vietnamese law examination in Vietnamese, and also meets the requirements regarding civil capacity and moral character.
Can civil servants and public officials register to practice auditing?
No. According to Article 16 of the Law on Independent Auditing, officials, civil servants, and public employees belong to the group that is not allowed to register to practice auditing.
How long does it take to process an application for auditing practice registration?
Within 15 days of receiving a complete and valid application, the Ministry of Finance will review and issue the Certificate of Registration for Auditing Practice.
