Right after the enterprise registration certificate is issued, investors often ask a seemingly simple question: must my company have a chief accountant, and what qualifications must that person hold? The answer has two layers — the law requires every accounting entity to organise an accounting apparatus and appoint a person in charge, and the chief accountant position itself is locked by a hard set of standards covering professional ethics, qualifications, a training certificate and actual experience. Appointing the wrong person is not a mere formality defect: financial statements lacking a valid chief accountant’s signature carry a legal flaw.
Must an FDI enterprise appoint a chief accountant?
Article 53 of the Law on Accounting 88/2015/QH13 sets the principle: an accounting entity must organise its accounting apparatus and appoint a chief accountant; where a qualified person is not yet available, it appoints an accounting person-in-charge or hires an accounting service under contract to act as chief accountant. A newly established entity may use a person-in-charge only for the first 12 months from commencing operations — after that, a fully qualified chief accountant is mandatory. FDI enterprises have no separate exception: a 100% foreign-owned company is an “accounting entity” under Vietnamese law and bears the same compliance apparatus. In practice, FDI financial statements are subject to mandatory audit (Article 37 of the Law on Independent Audit 67/2011/QH13) and must bear the chief accountant’s (or person-in-charge’s) signature — filing statements without it draws an administrative fine under Decree 41/2018/ND-CP (Article 11: VND 5–10 million for individuals (organisations pay double)).
The hard standards: four conditions that must coincide
The chief accountant must meet the standards at points a, c and d of clause 1, Article 54 of the Law on Accounting, detailed in Article 21 of Decree 174/2016/ND-CP:
- Professional ethics (point a, Article 54.1 and Article 52): honesty, incorruptibility, law-abiding awareness, and not falling within the categories barred from accounting work under Article 19 of Decree 174/2016/ND-CP (for example, persons under criminal investigation, serving a sentence, or banned from accounting practice by a judgment/decision).
- Professional qualification (Article 21.2, Decree 174/2016): the chief accountant of an enterprise established and operating under Vietnamese law — including FDI enterprises — must hold an accounting qualification at university level or higher. The only adjacent exception: enterprises without State capital and with charter capital below VND 10 billion may apply the intermediate-level threshold (Article 21.3) — an FDI enterprise with charter capital of VND 10 billion or more is outside this exception.
- Chief accountant certificate (point c, Article 54.1): a chief accountant training certificate under the Ministry of Finance programme. This is the condition most often missed when appointing staff seconded from the group: international accounting degrees or parent-company seniority do not substitute for this certificate.
- Actual accounting work experience (point d, Article 54.1): at least 2 years for university graduates, at least 3 years for intermediate/college level. This is hands-on accounting time, evidenced by labour/social insurance records and assignment decisions — not time in unrelated roles.
Appointment procedure inside the enterprise
Appointing the chief accountant is an internal authority under the company charter, not subject to State approval. A standard file includes: a personnel proposal with copies of degrees, the chief accountant certificate and experience evidence; the appointment decision of the competent person/body (owner, members’ council, director — per the charter); the labour contract or position-description annex; and a handover minute for accounting work from the predecessor/person-in-charge (figures cut off at the handover date, document status, accounts and pending obligations). After appointment, the enterprise updates the signature specimen at the bank where accounts are opened (the chief accountant is usually one of the account holders/second signatory) and the digital signature information for tax filing. The chief accountant’s name appears on financial statements, finalisation returns and documents exchanged with the tax authority, so every personnel change in this position must be synchronised immediately.
Common appointment mistakes in FDI enterprises
- Appointing a “chief accountant” with a university degree but no chief accountant training certificate — condition c fails, and every signed set of statements faces challenge.
- Using a person-in-charge beyond the first 12 months without appointing a chief accountant and without a valid service contract.
- Letting the director (legal representative) double as chief accountant: accounting law does not allow the person responsible for managing and operating the accounting entity to double as chief accountant (except for very small private units under specific rules) — and managerially, the person who approves spending also controlling the books is itself an internal control hole.
- Appointing group staff who are foreigners without checking work permit and certificate conditions (the subject of topic FDI-LC-2013 in this stage).
Frequently asked questions
Must an FDI company have a chief accountant?
Yes. Under Article 53 of the Law on Accounting 88/2015/QH13, an accounting entity must appoint a chief accountant; a newly established entity may use a person-in-charge for at most the first 12 months, after which a qualified chief accountant must be appointed or an accounting/audit service enterprise engaged by contract as chief accountant.
What degrees and certificates does the chief accountant need?
An accounting qualification at university level or higher (Article 21.2 of Decree 174/2016/ND-CP; the intermediate exception applies only to enterprises without State capital and charter capital below VND 10 billion); a chief accountant training certificate under the Ministry of Finance programme (point c, clause 1, Article 54 of the Law on Accounting); and not being barred from accounting work (Article 19 of Decree 174/2016).
How many years of actual accounting experience are required?
At least 2 years of actual accounting work for university graduates, and at least 3 years for intermediate/college level (point d, clause 1, Article 54 of the Law on Accounting 88/2015/QH13), evidenced by labour records and actual accounting work history.
What are the appointment conditions for an FDI enterprise’s chief accountant?
Four concurrent conditions: (1) professional ethics and not being barred from accounting work; (2) an accounting qualification at university level or higher (except the small-enterprise exception); (3) a chief accountant certificate; (4) minimum actual experience of 2 years (university) or 3 years (intermediate/college) — under Article 54 of the Law on Accounting and Article 21 of Decree 174/2016/ND-CP.
This article has been quality-reviewed by the FLAW AI Legal Council