Short answer: When facing a post-clearance audit (PCA), companies need two document groups: (1) commercial vouchers for the shipment — commercial invoice, transport documents, sale contract, C/O, payment vouchers, technical documents (Article 79.1 of the Customs Law); (2) accounting records — accounting books, accounting vouchers, financial statements and related documents (Article 80.3(b) of the Customs Law). New under Circular 121/2025/TT-BTC: customs may send a Notice to prepare dossiers and documents (form 13/CBTL) so the company prepares exactly within the audit scope. Important caveat: the checklist below combines statutory scope with practical experience — the actual required scope follows the specific audit decision; not every PCA demands all items.
1. Statutory document list
PCA at the customs authority’s headquarters (Article 79.1 of the Customs Law 54/2014/QH13) — the declarant provides:
- Commercial invoice;
- Transport documents (B/L, AWB…);
- Goods sale contract;
- Certificate of origin (C/O);
- Payment vouchers;
- Technical dossiers and documents of the goods under audit;
- Written explanations of related matters.
PCA at the declarant’s headquarters (Article 80.3(b) of the Customs Law) — the audit team cross-checks:
- Accounting books, accounting vouchers;
- Financial statements;
- Related documents and the actual condition of import/export goods within the scope and contents of the audit decision.
2. The 13/CBTL preparation notice — new under Circular 121/2025
Under point 63 of Article 1 of Circular 121/2025/TT-BTC (amending Article 142 of Circular 38/2015/TT-BTC): where necessary, the audit-decision issuer sends a written Notice in form 13/CBTL (Appendix VIII) stating what the declarant must prepare (customs dossiers, vouchers, related documents) and requiring the appointment of an authorized representative to work with the audit team.
Practical use: companies should prepare exactly to this notice’s scope — neither over- nor under-preparing — saving time and avoiding unnecessary disclosure of out-of-scope documents.
3. Practical checklist for companies
Compiled from the scope of Articles 79 and 80 of the Customs Law plus professional experience:
- Customs declarations, customs value declarations (if any), clearance/goods-release decisions;
- Foreign trade contracts, contract appendices; commercial invoice, packing list, bill of lading (B/L, AWB);
- C/O (where tariff preferences are claimed); payment vouchers (L/C, TTR remittance slips, bank statements); insurance and freight documents;
- Technical documents, catalogues, drawings (proving HS code, value, origin);
- Accounting books, accounting vouchers, financial statements, raw-material settlement reports (for processing/export-production);
- Written explanations of discrepancies (price, quantity, HS code) + the seller’s published discount schedule (where discounts apply).
Companies should organize dossiers per declaration: customs dossier + payment vouchers + corresponding accounting entries kept together for fast cross-checking during a PCA.
4. Actual preparation time
- Risk-based / compliance audits (Article 78.2, 78.3): the decision is served no later than 05 working days before the audit date — the minimum statutory preparation time.
- Audits on signs of violation (Article 78.1): no advance notice — conducted immediately after the decision is announced.
Companies should therefore maintain complete, systematic import/export dossiers at all times rather than scrambling when an audit decision arrives.
5. Dossier retention: 05 years
Customs declarants must retain customs dossiers for cleared goods for 05 years from the customs declaration registration date (Article 25.2(dd) of the Customs Law — article number per the original law, being cross-checked against consolidated document 54/VBHN-VPQH 2026); retain accounting books and vouchers per statutory periods; and present dossiers and provide information/vouchers when customs requests an audit.
This 05-year period matches the window for customs to issue PCA decisions (Article 77.3) — dossiers must remain complete throughout the auditable period.
6. Company rights and consequences of non-compliance
Company rights during the audit:
- Require the team leader to present the audit decision and customs inspector’s ID card;
- Provide documents, vouchers and data during the audit to prove declared contents are correct or to explain questioned items (Circular 121/2025);
- Where disagreeing with the conclusion’s contents, request that the company’s opinions be recorded (note: the “right to reserve opinions in the PCA conclusion” has not been traced to an original provision — phrase it as a request for recording, not as a statutory right).
Consequences of non-compliance: the declarant must comply with the audit decision. Non-compliance → administrative violation sanctions as prescribed; the non-compliance record is updated into the customs electronic data system, and subsequent shipments may face stricter control measures (document check / document check + physical inspection) (Article 142 of Circular 38/2015).
Frequently asked questions
Does every PCA require the full checklist above?
No. The checklist combines statutory scope with professional experience. The actual scope follows the specific audit decision and the 13/CBTL preparation notice (if any).
Is there time to prepare after receiving a PCA decision?
For risk-based/compliance audits, at least 05 working days. For audits on signs of violation, no advance notice — hence the need to keep dossiers systematically at all times.
How long must customs dossiers be retained?
05 years from the customs declaration registration date (Article 25.2(dd) of the Customs Law), plus accounting books and vouchers per statutory periods.
Who should represent the company before the audit team?
Under form 13/CBTL, the company appoints an authorized representative — ideally someone who understands the dossiers and is duly authorized to explain and sign records.
What if the company refuses to provide dossiers?
Administrative violation sanctions; the non-compliance record enters the customs electronic data system, and subsequent shipments may face stricter inspection measures.
Need help reviewing customs dossiers, preparing for a post-clearance audit, or handling a back-tax assessment? Reach us via the Contact page of FLAT Law Firm.
For reference only, not legal advice.