When Do State-Owned Companies Close Their Accounting Books?

Quick answer: A state-owned company (an enterprise in which the State holds 100% of charter capital) is an enterprise, so it applies the Enterprise Accounting Regime under Circular 99/2025/TT-BTC (which replaced Circular 200/2014/TT-BTC from 01/01/2026), not the public administrative and non-business accounting regime — which is now governed by Circular 24/2024/TT-BTC (replacing Circular 107/2017/TT-BTC from 01/01/2025). Accounting books are closed at the end of each accounting period (annual, quarterly, monthly periods) to prepare financial statements; for the annual accounting period, books are closed at the end of 31 December each year (except where the enterprise has an annual accounting period different from the calendar year under the Law on Accounting).

Distinguishing the two accounting regimes

• Circular 99/2025/TT-BTC — guiding the Enterprise Accounting Regime. Under Clause 1, Article 2, it applies to enterprises in all sectors and all economic components, including companies in which the State holds 100% of charter capital — a state-owned company, despite state capital, remains an enterprise operating under the Law on Enterprises;
• Circular 24/2024/TT-BTC — guiding the public administrative and non-business accounting regime, applicable only to administrative and non-business units (State agencies, public non-business units, socio-political organizations and other State-budget-using units), not to enterprises.

Applying Circular 24/2024/TT-BTC (or the expired Circular 107/2017/TT-BTC) to a state-owned company is a wrong-subject application of the accounting regime.

When accounting books are closed

Under the Law on Accounting 2015 (as amended by Law No. 56/2024/QH15):

• Under Clause 6, Article 26, accounting units must close their accounting books at the end of each accounting period before preparing financial statements, and in other cases as prescribed by law;
• Under Point a, Clause 1, Article 13, a normal annual accounting period is 12 months, from the beginning of 01 January to the end of 31 December of the calendar year; accounting units with specific organizational or operational characteristics may choose an annual accounting period of a full 12 months under the calendar year (beginning on the first day of the first month of a quarter), but must notify the finance authority;
• In addition to closing at the end of the annual accounting period, accounting units also close books at the end of quarterly and monthly accounting periods as required by law for reporting purposes.

Key notes

• When a state-owned company converts its enterprise type (e.g., equitization), the conversion point is the book-closing, inventory and enterprise valuation milestone under equitization law and guidance of the Ministry of Finance.
• Book closing must be accompanied by asset inventory and debt reconciliation so that financial statement figures are truthful.

How ANT Legal can help

ANT Legal advises on accounting law compliance and audits for state-capital enterprises and provides legal support during equitization and enterprise-type conversion. For advice on your specific case, please contact our lawyers at 0966.475.966.

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The ANT Legal AI Legal Council reviewed this article under its internal 7-step process (cross-checked against current law — Circular 99/2025/TT-BTC, Circular 24/2024/TT-BTC, the Law on Accounting 2015 as amended by Law 56/2024/QH15; Circular 200/2014/TT-BTC expired on 01/01/2026 and Circular 107/2017/TT-BTC expired on 01/01/2025). This is not a confirmation that a human lawyer has reviewed your specific case.