Foreign investors looking to provide accounting services in Vietnam must understand one critical fact first: from 1 July 2026 to 28 February 2027, the entire pre-licensing regime for accounting services is suspended under Resolution 66.18/2026/NQ-CP. This means that during this period, enterprises (including foreign-invested ones) providing accounting services do not need a Certificate of Eligibility for accounting service business. This is the most significant change in the history of Vietnam’s accounting industry regulation.
1. Current status: suspension of the certification regime (1 July 2026 – 28 February 2027)
Government Resolution 66.18/2026/NQ-CP dated 18 May 2026, effective from 1 July 2026 to 28 February 2027, suspends (“shall not be implemented”) the provisions on business conditions for accounting services in the following articles of the Law on Accounting 88/2015/QH13:
- Article 57 (accountant certificates), Article 58 (practice registration);
- Article 59(1), (2), (3) and points (a), (b) of clause 4 (accounting service business units);
- Article 60 (conditions for issuance of the Certificate of Eligibility), Article 61 (dossiers), Article 62 (issuance timelines), Article 63 (re-issuance), Article 64 (fees);
- Article 65 (business households), Article 66 (changes subject to notification);
- Articles 26 and 27 of Decree 174/2016/ND-CP (capital contribution ratios).
While the Resolution is in effect, its provisions take precedence (Article 7(3) of NQ 66.18). Official Letter 773/QLKT-DN dated 22 May 2026 of the Department of Accounting and Auditing Supervision provides implementation guidance.
At the same time, “accounting service business” has been removed from the list of conditional business lines (NQ 66.17/2026/NQ-CP) and from Appendix IV of the Investment Law under Law 24/2026/QH16 (general effective date 1 March 2027). Note: sources disagree on a separate effective date for the new Appendix IV, so this article only records the general effective date of 1 March 2027.
2. There is no such thing as an independent 100% foreign-owned accounting firm
A common misconception: Vietnamese law does not permit an independent 100% foreign-owned accounting firm. Under Article 59(4) of the Law on Accounting 88/2015/QH13 and Article 30 of Decree 174/2016/ND-CP, foreign investors may only enter Vietnam’s accounting services market through three forms:
- Capital contribution to an accounting service enterprise already established and operating in Vietnam;
- Establishing a branch of a foreign accounting service enterprise in Vietnam;
- Cross-border service provision — subject to conditions: being permitted to provide accounting services in the home country; confirmation of no violations for 03 consecutive years; having at least 02 persons licensed by Vietnam’s Ministry of Finance, including the legal representative; professional liability insurance; and no administrative penalties for cross-border provision in the preceding 12 months.
On ownership ratios: when contributing capital to an accounting service enterprise, there is no separate cap on foreign ownership; only the general 35% cap on charter capital applies to members that are organizations (Article 27 of Decree 174/2016/ND-CP). Note that points (a) and (b) of Article 59(4) fall within the scope suspended by NQ 66.18 during 1 July 2026 – 28 February 2027; the status of cross-border service provision during this period remains unclear and requires further verification before application.
3. The statutory regime (when not suspended): conditions for the Certificate of Eligibility
When the pre-licensing regime operates normally (outside the suspension period), the framework is as follows:
- Enterprise forms: only limited liability companies with two or more members, partnerships, and private enterprises (Article 59 of the Law on Accounting).
- Issuing authority: the Ministry of Finance issues the Certificate of Eligibility for accounting service business.
- Issuance conditions (Article 60 of the Law on Accounting): at least 02 practicing accountants; the legal representative must be a practicing accountant; practicing accountants’ capital contributions must exceed 50% of charter capital; members that are organizations may contribute at most 35% (Articles 26 and 27 of Decree 174/2016/ND-CP, as amended by Decree 151/2018/ND-CP). These ratios are currently “not implemented” under NQ 66.18.
- Minimum capital: the Law on Accounting sets no separate statutory capital requirement for accounting service enterprises.
On market access: foreign investors’ access to the accounting services market is conditional under Item B(33) of Appendix I of Decree 96/2026/ND-CP.
4. Key recent developments
- All pre-licensing barriers temporarily removed from 1 July 2026 (NQ 66.18) — a shift to post-inspection supervision, the biggest change in the industry’s history.
- Accounting service business removed from the conditional business lines list (NQ 66.17) and from Appendix IV of the Investment Law (Law 24/2026/QH16).
- The draft law amending the Law on Accounting and the Law on Independent Audit (proposing to repeal Articles 58, 60–66, and 70a outright) has not been passed — it cannot be cited as current law.
- No statement is made about the legal status after 28 February 2027 — whether the old regime will be restored, amended, or repealed outright remains unknown.
Frequently asked questions
During 1 July 2026 – 28 February 2027, does a foreign-invested company need a Certificate of Eligibility for accounting service business?
No. Under NQ 66.18/2026/NQ-CP, the provisions on conditions for issuing the Certificate (Articles 60–64 of the Law on Accounting) are not implemented during this period, applying to all enterprises including foreign-invested ones.
Can a foreign investor open a 100% foreign-owned accounting firm in Vietnam?
No. The law provides no such form; foreign investors may only participate via capital contribution, opening a branch, or cross-border service provision (Article 59(4) of the Law on Accounting; Article 30 of Decree 174/2016).
Will the licensing regime be restored after 28 February 2027?
This is currently unknown. This article makes no statement about the legal status after that date; investors should monitor new documents from the Government and the Ministry of Finance as the suspension period ends.
See also: accounting setup for newly established FDI companies in Vietnam.
Contact FLAT Law Firm for advice on conditions for accounting service business and foreign investment in this sector.
Note: This article is for reference only and is not legal advice. Laws and regulations may change; specific cases require advice from a licensed lawyer.
For reference only; not legal advice. This content was quality-checked by the AI Legal Council and has not been reviewed by a licensed human lawyer.
