Accounting violations rarely start as major offences — they accumulate from seemingly small lapses: financial statements filed a few weeks late, statements filed without the audit report, incomplete voucher retention, ledgers that cannot be printed on inspection. For FDI enterprises, whose statements are read simultaneously by the tax authority, banks and the parent, the reputational cost usually exceeds the fine. This article summarises the current penalty framework for self-assessment.
The current legal frame: Decree 41/2018/ND-CP
Administrative penalties in accounting and independent audit are currently governed by Decree 41/2018/ND-CP — the framework in force at the time of writing (October 2026), applying uniformly to all enterprises including FDI enterprises, with no separate framework for foreign capital. Three structural principles matter: (1) the decree’s fine levels are for organisations; violating individuals pay half — except the articles on the exception list in Clause 2, Article 6 (Articles 8, 9, 10 and 11), whose levels are for individuals, with organisations paying double; (2) beyond fines, each violation carries remediation measures (compelled re-preparation/re-filing of reports, compelled supplementary audit, restoration/cancellation of wrong vouchers); (3) serious conduct beyond the administrative threshold — forgery, voucher destruction, false statements — can be criminally prosecuted under the Penal Code (see topic FDI-LC-2061). The decree’s violation groups cover the whole accounting life cycle: vouchers, ledgers, accounts, financial statements, stock-taking, retention, and the organisation of the accounting apparatus/chief accountant (see topics FDI-LC-2060, FDI-LC-2062 on specific error groups).
The violations FDI enterprises are most often fined for, and typical levels
- Procedurally defective statements: filing financial statements without the attached audit report for a mandatory-audit entity — VND 10–20 million (Point b, Clause 2, Article 12 of Decree 41/2018/ND-CP), plus remediation compelling filing with the audit report attached (Clause 5, Article 12); failing to file financial statements with the competent authority — VND 40–50 million, among the highest levels in the reporting group.
- Statement figures errors: statements prepared against the rules, figures not matching ledgers/vouchers — fined under Article 11 of Decree 41/2018/ND-CP (preparing statements inconsistent with ledger and voucher figures falls under Clause 3, Article 11, in the VND 20–30 million group; publicly disclosed figures that are untruthful fall under Clause 3, Article 12).
- Signature and responsibility errors: statements missing signatures of the preparer, chief accountant or legal representative — VND 5–10 million (Article 11 of Decree 41/2018/ND-CP).
- Voucher and retention errors: vouchers lacking mandatory contents, retention not per period/document type — lower levels under Article 8 and the retention articles, but large voucher volumes make the aggregate risk non-trivial.
- Apparatus organisation errors: failing to appoint a chief accountant where mandatory, unqualified accounting personnel — fined under the articles on accounting work organisation (see the chief accountant cluster FDI-LC-2012 to FDI-LC-2016).
Maximum fines and accompanying remediation
Within Decree 41/2018/ND-CP, the heaviest per-violation levels (e.g. non-filing of statements, administrative-level forgery of vouchers/statements) reach VND 40–50 million for organisations — the absolute fine is not large against FDI scale, but the accompanying consequences are the significant part: the penalty decision always carries corresponding remediation (compelled preparation and filing of correct statements, compelled audit, compelled re-filing), the violation sits in the compliance history used in tax risk assessment, and where the same conduct involves a tax shortfall, the enterprise additionally bears separate tax handling (clawback, incorrect-declaration fines under Decree 125/2020/ND-CP) in parallel with the accounting fine. In other words, the accounting fine is the “surface” sanction layer — the real risk is that an accounting error opens the path to tax adjustments and deeper inspection.
Frequently asked questions
What is the latest fine framework for accounting violations?
The framework in force is Decree 41/2018/ND-CP on administrative penalties in accounting and independent audit — applying uniformly to all enterprises including FDI. Its fine levels are for organisations; individuals pay half (except Articles 8, 9, 10 and 11, which are individual levels — organisations pay double); remediation measures accompany each violation.
Which accounting errors are FDI enterprises most often fined for?
Procedural errors around financial statements are most common: filing without the attached audit report where audit is mandatory (VND 10–20 million, Clause 2, Article 12), not filing statements (VND 40–50 million), figures inconsistent with ledgers/vouchers (Clause 3, Article 11, VND 20–30 million), missing signatures (VND 5–10 million), plus voucher and retention errors.
What is the maximum fine for an accounting violation?
At the per-violation level in Decree 41/2018/ND-CP, the heaviest conduct (such as non-filing of statements) reaches VND 40–50 million for organisations. Serious forgery beyond the administrative threshold can be criminal; an accounting error with a tax shortfall is separately handled under Decree 125/2020/ND-CP.
Do accounting fines come with remediation measures?
Yes — penalty decisions usually carry remediation corresponding to the violation: compelled preparation/re-filing of correct statements, compelled audit, compelled restoration or cancellation of wrong vouchers. Failure to remediate on time continues liability and affects compliance history.
This article has been quality-reviewed by the FLAW AI Legal Council