The first year of an FDI company often presents a paradox: transaction volume is still low, yet compliance demands are at their densest — initial tax registration, opening the books, monthly filings, year-end audit preparation. Hiring a full-time chief accountant may be premature, while engaging a service provider without the statutory practice qualifications is a genuine legal risk. This article helps the investor decide whether to outsource, and if so, how to choose a provider lawfully.
The legal frame: not everyone may sell accounting services
Article 57 of the Law on Accounting 88/2015/QH13 allows an accounting entity to hire an accounting service enterprise or an audit enterprise to perform accounting work, including the chief accountant role, under contract. Article 58 of the same law sets the practice conditions: an accounting service business must hold a Certificate of eligibility to provide accounting services issued by the Ministry of Finance, and the person directly in charge must hold an accounting service practice certificate with registered practice (detailed conditions in Decree 174/2016/ND-CP on accounting service business and practice conditions). The practical consequence when choosing: a “consulting company” without this certificate is not legally qualified to sign an accounting service contract — whatever other support work it may do. The list of eligible accounting service enterprises is published by the Ministry of Finance; the investor’s first check is to look the provider up in that list and match the certificate number stated in the contract.
Should a first-year company outsource?
Outsource when: monthly document volume is still low (under a few hundred vouchers), the investor has not yet found a qualified chief accountant, and the group requires reporting at both the VAS and IFRS layers. Do not outsource everything when: the enterprise is already running a plant with thousands of vouchers, multiple warehouses and production shifts — then an in-house team is mandatory and the service provider should only review. Under any model, one thing can never be outsourced: ultimate responsibility for the truthfulness and completeness of accounting information always rests with the enterprise and its legal representative — outsourcing does not transfer this responsibility anywhere; it only adds a contractually liable party.
Selection criteria: five questions to ask before signing
- Licence: the number of the Certificate of eligibility to provide accounting services and the name of the in-charge person holding a practice certificate — verifiable in the Ministry of Finance’s published list?
- Sector experience: how many FDI clients in the same sector (manufacturing, trading, services) has the provider served? Does it have experience working with Big-4/group auditors and IFRS reporting packages?
- Assigned personnel: who does the work directly, who reviews (these must be two different people), and are their qualifications and certificates set out in a contract annex?
- Liability and insurance: compensation terms where errors cause back taxes and late-filing penalties; does the provider carry professional indemnity insurance?
- Data handover: on whose system does the accounting data live, in what format; on termination, within how long are the complete books, electronic vouchers and software data handed over? This is the most underrated clause and the one with the longest consequences.
Is the external provider liable when reports are wrong?
Yes — at three levels. Contract level: the provider bears compensation liability under the signed service contract, including penalties and back taxes arising from its errors if the contract so provides (investors should require this clause in writing, with a liability cap and an incident notification mechanism). Practice level: accounting service practitioners and enterprises face practice sanctions under the Law on Accounting and Decree 174/2016/ND-CP for breaches of conditions and professional standards — up to suspension and revocation of the certificate. Enterprise level: before the tax authority and State agencies, the enterprise remains the subject responsible for its own filings; assessments are paid first, and recovery from the provider is a separate civil relationship afterwards. Understanding these three levels prevents the illusion that outsourcing “transfers compliance risk”.
What does accounting service for an FDI company cost?
The market for FDI accounting services in Hanoi and Ho Chi Minh City usually prices monthly packages by document volume and scope (tax filings only; filings plus bookkeeping; bookkeeping plus group reporting and audit support). For a low-volume first-year company, a basic package commonly runs at a few million dong per month; a manufacturing company with warehousing, costing and two-layer group reporting is several times higher. These are market reference levels at the time of writing (October 2026), not regulated tariffs — the real value of comparison lies in the itemised scope: require every quotation to state the number of filings, the report types, whether finalisation/audit support is included or charged separately, and the fee for reconstructing past data if any.
Frequently asked questions
Should a first-year FDI company hire external accounting services?
Usually yes, while document volume is low and no qualified chief accountant has been hired: it costs less than a full-time hire and brings a certificated review team. Once a plant operates at high volume, build an in-house team and keep the provider in a review role. Under any model, ultimate responsibility for the figures stays with the enterprise (Article 57 of the Law on Accounting 88/2015/QH13).
How do we choose a reputable accounting service provider?
The first hard criterion is legal capacity: a Certificate of eligibility to provide accounting services under Article 58 of the Law on Accounting 88/2015/QH13 and Decree 174/2016/ND-CP, verifiable in the Ministry of Finance’s published list. Then come FDI sector experience, assigned personnel holding practice certificates, liability clauses and data handover terms on termination.
Is the external provider liable when reports are wrong?
Yes — compensation under the contract, and practice sanctions. But before State authorities the enterprise remains responsible for its own filings; outsourcing does not transfer that responsibility, and recovery from the provider is a separate relationship afterwards.
What does accounting service for an FDI company cost per month?
It depends on document volume and scope: a low-volume first-year company commonly pays a few million dong per month for a basic package in Hanoi/Ho Chi Minh City; manufacturing with costing and group reporting is several times higher. These are October 2026 market references — compare quotations by itemised scope, not headline numbers.
This article has been quality-reviewed by the FLAW AI Legal Council
