When a chief accountant resigns, is dismissed or is rotated by the group, FDI enterprises often hesitate over two questions: must the change be approved/notified to the tax authority, and how to change the person without leaving a responsibility gap over the figures. Unlike a change of legal representative, changing the chief accountant is not a State registration procedure; the legal centre of gravity lies in an internal decision by the competent level and a complete handover minute.
Is State registration or approval required?
No. The chief accountant is not part of enterprise registration content, and accounting law sets no pre-notification procedure for changing this position. Appointment and dismissal are decided by the enterprise’s competent level under its charter and the Law on Accounting 88/2015/QH13 (Article 53). What the enterprise must guarantee is continuity: at all times there must be a person validly holding the chief accountant or accounting person-in-charge role (within the first-12-months limit for new entities) or an accounting service contract acting as chief accountant — leaving the position vacant breaches the accounting apparatus rules and is a serious demerit in inspections. One practical note: chief accountant information was declared in the initial tax registration file and appears in many dealings with the tax authority; on a change, the enterprise should update tax registration information where the change falls within notifiable items under tax administration rules, and — more importantly — immediately synchronise the filing digital signature, e-portal accounts and bank signature specimens.
The change sequence: six steps that must not be reordered
- Dismissal and appointment decisions: the competent level under the charter (owner/members’ council/director) issues the decision dismissing the outgoing and appointing the incoming chief accountant, stating the effective date. The incoming person must meet the standards of Article 54 of the Law on Accounting and Article 21 of Decree 174/2016/ND-CP before signing anything.
- Cut off the figures at the handover date: a provisional close at the effective date: bank/cash balances reconciled to reality, receivables/payables agreed with major customers/suppliers, inventory — if a full count is impossible, cash count and bank reconciliation are the mandatory minimum.
- Draw up the accounting work handover minute: the Law on Accounting requires that on a change of chief accountant, the outgoing person hand over the accounting work and documents to the incoming person, and notify the relevant departments within the entity and the bank where accounts are opened of the change. The minute lists: bookkeeping systems and software (with administrator accounts), original vouchers in storage, seals/digital signatures/tokens under management, filings in progress, the calendar of upcoming obligations, and known outstanding issues (unresolved differences, dossiers under tax authority explanation requests).
- Update the bank: replace the account holder/second signatory specimen, revoke the outgoing person’s e-banking rights on the very effective date.
- Update the tax filing infrastructure: revoke/reissue the digital signature and rights on the e-filing system, the e-invoice portal and e-social insurance; change accounting software account passwords.
- Notify internally and to related partners: a written notice to departments, the audit firm under contract, the bank and — by practice — the managing tax authority through the e-transaction channel if contact information changes.
Responsibility of the outgoing and incoming persons around the cut-off
The allocation principle: the outgoing chief accountant answers for the figures and documents of the period under their charge up to the handover date; the incoming chief accountant answers from acceptance, but has the right — and should — record in the handover minute every anomaly detected at acceptance (balance differences, missing vouchers) so those anomalies do not “migrate” into their responsibility. If the outgoing person leaves abruptly or refuses to cooperate in the handover, the enterprise draws up an inventory and cut-off minute witnessed by the legal representative and related departments, seals the documents, and simultaneously appoints an acting/new chief accountant to preserve continuity; the non-cooperation is recorded in the personnel file and handled under the labour contract/internal rules. The financial statements for a period containing the cut-off are signed by the chief accountant in office at the signing time, on the basis of the handed-over figures — one more reason the handover minute must cut off real figures, not be a formality.
Frequently asked questions
Must a change of chief accountant be notified to the tax authority?
Accounting law sets no registration or approval procedure for changing the chief accountant; it is an internal decision under Article 53 of the Law on Accounting 88/2015/QH13. The enterprise must ensure continuity of a valid holder, update notifiable tax registration information (if any), the filing digital signature and bank signature specimens.
What does the procedure for dismissing and appointing a new chief accountant include?
Dismissal and appointment decisions by the competent level under the charter; cutting off the figures and an accounting work/document handover minute under the Law on Accounting; updating bank signature specimens; revoking/reissuing digital signatures and rights on e-filing systems; and notifying related departments and the bank where accounts are opened.
What should the handover minute contain when the chief accountant changes?
Cut-off balances at the handover date (cash, bank, reconciled receivables/payables), the inventory of books and accounting documents, software administrator accounts and digital signatures/tokens, filings and obligations in progress, and every anomaly known at handover. The incoming person should record detected anomalies expressly to delimit responsibility.
How long does the chief accountant change procedure take?
The law sets no separate deadline for the whole process, but continuity is mandatory: the position of valid chief accountant/person-in-charge must never be vacant, and operational updates (bank signatures, filing digital signatures) should be completed on the very day the decision takes effect to avoid disruption to transactions and filings.
This article has been quality-reviewed by the FLAW AI Legal Council
