The initial audit files under Decree 90 are becoming the focus of attention as the large-scale businesses Entering the implementation phase of the latest regulations in 2026, and in the context of the government tightening transparency in the financial market, establishing a standardized documentation system is a shield protecting the reputation of businesses. Many business owners are currently facing immense pressure as their old accounting systems do not meet the stringent standards of independent auditing firms.
In 2025, over 301 businesses undergoing their first audit received qualified opinions due to deficiencies in the preparation of original documents. This led to serious consequences for their credit rating and ability to raise capital. This article will analyze in detail the necessary items for the first audit dossier under Decree 90. We hope to help managers overcome psychological barriers and proactively control financial processes more effectively.
Summary of key points regarding the initial audit dossier under Decree 90
- The initial audit file under Decree 90 is The collection of legal documents, accounting records, original vouchers, and evidence related to opening balances and transactions occurring during the first fiscal year subject to mandatory auditing under Decree 90/2025/ND-CP.
- PurposeVerify the accuracy of financial statements and ensure that the business complies with current Vietnamese accounting standards.
- Applicable subjectsLarge businesses are now subject to mandatory audits for the first time, based on criteria such as assets, revenue, or workforce.
- The time neededRight from the beginning of the fiscal year, this process needs to be completed before the auditing firm officially begins its work at the company.
What constitutes a large-scale enterprise and why is an initial audit report required under Decree 90?
According to the latest update Decree 90/2025/ND-CP, criteria for determination large-scale businesses Mandatory auditing from fiscal year 2025 has been specifically defined. Businesses are eligible if they meet at least two of the following three criteria: an average annual number of employees participating in social insurance exceeding 200; total annual revenue exceeding 300 billion VND; or total assets exceeding 100 billion VND. This determination is based on financial statements and insurance data from the immediately preceding year.
The initial audit file under Decree 90 serves as a comprehensive financial medical record for the entity. The biggest challenge lies not in the figures generated during the year, but in verifying the accuracy of the opening balances. If these balances are not verified, auditors will find it difficult to ensure the continuity of the indicators in the current financial statements.
The value of a well-prepared set of documents also lies in its ability to optimize tax obligations for the business. When the documentation is complete and accurate, the business avoids the risk of expense disallowance during post-audits by the tax authorities. A logical system of documents is the clearest evidence of the professional management capabilities of the business leader.
Key legal documents governing audit criteria: Decree 90
To build a comprehensive accounting record, the chief accountant and CEO need to have a thorough understanding of the key current legal documents that govern the process. Audit criteria under Decree 90Below are the most important documents up to the year 2026:
- Decree 90/2025/ND-CPRegulations specifying the entities required to have their annual financial statements audited and the criteria for classifying their size.
- Law on Independent Auditing No. 67/2011/QH12: This document outlines the general legal framework, rights, and obligations of the parties involved in independent auditing activities.
- Circular 200/2014/TT-BTCThis guide to corporate accounting practices serves as the basis for auditors to compare actual accounting entries.
- Vietnamese Auditing Standard No. 510 (VSA 510): Specific regulations regarding the audit duties on opening balances for initial audits.
Omitting any of the above guidance documents could lead to inaccurate documentation preparation. This makes it difficult for the entity to meet the stringent requirements of a professional audit team.
Detailed checklist of documents in the initial audit file under Decree 90
Based on practical experience, we've divided this checklist into three main groups to make it easier for businesses to implement.
Group 1: Legal documents and organizational structure
This is the foundation upon which auditors assess the internal control environment.
- The latest business registration certificate and articles of operation.
- List of management team and departmental organizational chart.
- Minutes of the Board of Directors meeting regarding major financial decisions.
- Internal spending regulations and financial approval procedures.
Group 2: Opening Balance Records (Extremely Important)
For the first audit, this is the most time-consuming part to review.
- Financial statements from previous years and detailed accounts receivable/payable reconciliation statements.
- Inventory cards and physical inventory count records as of January 1st.
- Table of depreciation of fixed assets from the time of their formation.
- The detailed ledger lists accounts with large balances or unusual fluctuations.
Group 3: Documents generated during the fiscal year
- Economic contract accompanied by acceptance and settlement report.
- Bank payment documents and cash receipts/disbursements.
- Tax returns of all kinds and employee payroll and insurance records.
- Decisions to change charter capital or invest in new projects.
Case Study: Lessons Learned from a Documentation Failure Incident at a Large Logistics Company
In 2025, MAN undertook its first audit of a logistics company with a revenue of VND 1.5 trillion. Due to oversight, the company only prepared documents for the current year, neglecting to reconcile the opening balances. This left the auditors without a basis to verify the value of outstanding assets.
When the company failed to provide documentation for the purchase of its vehicle fleet from five years prior, it received an "Exception" opinion. The consequence was a reduction in its bank loan limit (40%) due to a decline in its financial credibility. The company subsequently faced a severe shortage of working capital.
Following the incident, MAN assisted in reviewing and restoring all historical documents for the client. At the next audit, the company received a "Full Acceptance" opinion. Its reputation with financial partners was thus fully restored.
Comparing the risks involved in preparing the initial audit report under Decree 90.
To get an overview of the impact of document preparation, businesses can refer to the risk comparison table below. Proactively reviewing documents not only optimizes processing time but also directly protects the financial interests and reputation of the entity with banking institutions.
| Comparison criteria | Prepare all necessary documents. | Inadequate preparation/Deficiencies |
| Audit opinion | Full acceptance | Except or Rejected |
| Execution time | On schedule (2-3 weeks) | Duration (2-3 months) |
| Audit costs | According to the original contract | Labor costs for review are incurred. |
| Tax risk | Low, easy to explain | High, susceptible to tax assessment. |
| Bank reputation | Increase your ability to borrow money. | Competency is being reviewed. |
Expert opinion: Common pitfalls and how to handle them.
With 30 years of experience, I've found the biggest obstacle is the lack of connection between CEOs and accountants. Many leaders delegate everything without realizing that administrative documents like meeting minutes are crucial. Accountants cannot draft these documents on their own without instructions from their superiors.
Another common mistake is storing documents in a disorganized manner, not according to the accounting system. When requested, accountants spend days searching for and matching records. This creates a negative impression of the company's internal control system to the audit team.
My advicePlease conduct a thorough review before auditing unit Officially getting involved. Internal detection and correction are always cheaper than having errors appear in public reports. For sensitive items, a third-party audit is absolutely essential.
Large-scale enterprise audit service solutions at MAN
At MAN – Master Accountant Network, we build specialized solution roadmaps to optimize life value. auditWe not only verify the data but also advise on improving financial management processes.
Pre-audit review process
This solution helps businesses eliminate potential risks before an independent entity begins work. MAN conducts a review of key items and directly compares documents with accounting records. This minimizes the risk of receiving qualified opinions and saves businesses time.
Establishing and standardizing the electronic document system.
MAN supports businesses in digitizing their initial audit record management processes under Decree 90 effectively. This solution enables instant data retrieval and ensures strong linkages between different types of documents. This is a crucial stepping stone for large-scale businesses to successfully undergo digital transformation.
In-depth consultation on opening balances and fixed assets.
MAN's team of experts is directly involved in restoring historical evidence and recalculating depreciation. We use advanced data analysis software to detect anomalies in balances. From there, businesses can make adjustments that best comply with current accounting standards.
Training and capacity building for the accounting department.
MAN's goal is to elevate our clients' accounting teams through in-house training programs. We provide guidance on document preparation and updates on the latest changes in tax policies. This helps businesses be fully prepared for future audits.
Conclude
Preparing the initial audit documentation under Decree 90 is a meticulous process requiring a deep understanding of the law. Instead of viewing it as a burden, CEOs should see it as an opportunity to standardize the company's financial foundation. A transparent set of documents is the most credible passport in the eyes of international investors and partners.
MAN – Master Accountant Network We are proud to be a trusted partner supporting large-scale businesses in their significant transformation. We provide solutions. auditing services Comprehensive, from establishing internal controls to managing tax risks. With extensive experience, MAN is committed to providing complete peace of mind for today's leaders.
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
- Email: man@man.net.vn
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.
5 Frequently Asked Questions about Initial Audit Documentation under Decree 90
What are the penalties for not conducting an audit as stipulated in Decree 90?
The administrative penalty can be up to 50 million VND according to accounting regulations. However, the greater risk is attracting attention from the tax authorities and having your reputation damaged by credit institutions.
What does the cost of preparing the initial audit report typically include?
The costs include audit service fees, internal personnel fees, and system review consulting fees. This investment helps businesses avoid larger financial losses due to errors.
Did the auditor examine all 100% documents?
Auditors use a sampling method based on an assessment of actual risks. However, businesses must still prepare all necessary documents to be ready to provide when requested.
What is the deadline for submitting the initial audit report?
Typically, audited financial statements must be submitted within 90 days of the end of the year. Businesses need to proactively manage their time to avoid delays according to regulations.
Can businesses prepare the application themselves, or should they hire a consulting firm?
Businesses can establish their own accounting system if they have a strong accounting team and a deep understanding of Decree 90. However, for the first time, having a professional firm to assist will ensure maximum safety.
