Foreign direct investment (FDI) enterprises must submit their annual financial statements within 90 days from the end of the annual accounting period. For the common calendar-year period, the 2026 statements are due 31/3/2027. Current legal basis: Article 29.3 of the Law on Accounting 2015 combined with Article 25 of Circular 99/2025/TT-BTC. Important: Circular 200/2014/TT-BTC expired on 01/01/2026 — its Article 109 must no longer be cited.
1. Applicable legal framework, in force as of 14/10/2026
- Law on Accounting 2015 (88/2015/QH13) remains in force; Article 29.3 fixes the annual financial statement deadline at 90 days from the end of the annual accounting period.
- Circular 99/2025/TT-BTC is in force and unifies the rules for all enterprise types; Article 25 details the annual statement filing deadline.
- Circular 200/2014/TT-BTC expired on 01/01/2026, replaced by Circular 99/2025. Internal documents and accounting service contracts still citing Article 109 of Circular 200/2014 must be updated.
2. The 90-day rule: how to count
“90 days from the end of the annual accounting period” — the starting point is the last day of the enterprise’s annual accounting period:
- Calendar-year period (01/01–31/12): due 31 March of the following year (e.g., 2026 statements → due 31/3/2027);
- Non-calendar 12-month period (FDI enterprises may elect a 12-month period other than the calendar year): due on the 90th day after that period ends.
Circular 99/2025 unifies a single 90-day standard for all enterprises — no more separate deadlines by enterprise type as in the earlier regime.
3. Filed with whom, and comprising what?
An FDI enterprise’s annual financial statements must be filed with the competent regulators (tax authority, statistics authority, and relevant investment/business registration bodies as applicable). A complete annual set comprises the balance sheet, income statement, cash flow statement and notes — prepared under the current enterprise accounting regime (now Circular 99/2025, replacing Circular 200/2014).
4. The citation trap: Circular 200/2014 is dead
For years, Article 109 of Circular 200/2014 was the familiar basis for the filing deadline. Since 01/01/2026, that circular is no longer in force. Checks show many secondary sources, textbooks and compliance checklists still cite the old instrument — FDI enterprises should review internal materials and replace it with Article 25 of Circular 99/2025.
5. Consequences of late filing
Filing annual financial statements after the 90-day deadline attracts administrative penalties in the accounting domain; fines escalate with the delay and can affect the enterprise’s compliance record with tax authorities, banks and counterparties. For FDI enterprises, financial-statement non-compliance may also draw questions during tax inspections and audits.
6. Frequently asked questions
When must an FDI enterprise file annual financial statements?
Within 90 days from the end of the annual accounting period (Article 29.3 of the Law on Accounting 2015 + Article 25 of Circular 99/2025). For calendar-year periods: 31 March of the following year.
What is the current legal basis?
Article 29.3 of the Law on Accounting 2015 and Article 25 of Circular 99/2025/TT-BTC. Do not cite Article 109 of Circular 200/2014 — it expired on 01/01/2026.
Which instrument did Circular 99/2025 replace?
Circular 200/2014/TT-BTC (expired 01/01/2026), unifying one standard for all enterprises.
How is the deadline counted for a non-calendar accounting period?
The 90th day after the end of the registered 12-month accounting period.
Note: This article provides reference information only and is not legal advice. The content was researched from statutory legal texts and drafted by AI; it will undergo FLAT Law Firm’s QA council review and approval before publication; it is not legal advice from a human lawyer. Regulations may change; please check the current legal texts before relying on this information.
Need support preparing and filing annual financial statements for an FDI enterprise? Contact FLAT Law Firm for support.
Legal content reviewed by the FLAW AI Legal Council and submitted to the owner for approval; not a practicing lawyer’s opinion, not a substitute for legal advice on a specific matter.