Must an LLC Appoint a Chief Accountant? What Is the Appointment Time Limit?

Short answer: Yes. A limited liability company must appoint a chief accountant. Where a chief accountant cannot be appointed immediately, the company may arrange an accounting supervisor or hire chief accountant services, but the arrangement of an accounting supervisor may last at most 12 months — after this period, the company must arrange a person to serve as chief accountant (Article 20 of the Law on Accounting 2015).

Legal basis

• Law on Accounting 2015 (Article 20 — chief accountant; Articles 53, 54 — standards and conditions);
• Decree No. 174/2016/ND-CP (Articles 19 and 21 — standards for chief accountants and accounting supervisors).

Must an LLC appoint a chief accountant?

Under Clause 1, Article 20 of the Law on Accounting 2015, an accounting unit must appoint a chief accountant. This applies to limited liability companies (single-member and multi-member), regardless of capital size.

Where the company cannot immediately appoint a chief accountant, it may:

• Arrange an accounting supervisor; or
• Hire chief accountant services as prescribed.

What is the time limit for appointing a chief accountant?

This is a point many enterprises misunderstand. The law does not prescribe a general “appointment time limit” for all cases, but sets a limit for the temporary solution:

• The arrangement of an accounting supervisor may last at most 12 months;
• After 12 months, the company must arrange a person to serve as chief accountant (appoint a chief accountant or hire chief accountant services).

In other words, an LLC has at most 12 months to complete the appointment of a chief accountant from the time it arranges an accounting supervisor.

Standards for chief accountants and accounting supervisors

Under Article 21 of Decree No. 174/2016/ND-CP:

• Chief accountants and accounting supervisors must satisfy the standards at Points a, c, and d, Clause 1, Article 54 of the Law on Accounting and must not fall under the cases prohibited from being accountants (Article 19 of Decree No. 174/2016/ND-CP);
• Professional qualifications: university degree or higher for enterprises in general; professional secondary school or higher for enterprises without state capital and with charter capital below VND 10 billion;
• Certificate: the Ministry of Finance regulates the organization, training, and issuance of chief accountant certificates. For a parent company that is a state-owned enterprise or an enterprise with state capital exceeding 50% of charter capital: the chief accountant or accounting supervisor must have at least 05 years of actual accounting work experience.

Frequently asked questions

What if a newly established LLC has no chief accountant yet?

The company arranges an accounting supervisor for at most 12 months, while recruiting or training personnel meeting the standards to appoint a chief accountant before the deadline.

Is failing to appoint a chief accountant penalized?

Yes. Failing to arrange an accountant, chief accountant, or accounting supervisor as prescribed may be subject to administrative sanctions in the accounting sector; the specific fine level should be checked against current sanctioning regulations.

To set up your accounting apparatus in compliance from the outset, you should contact ANT Legal’s lawyers at 0966.475.966 for review and advice before proceeding.