Standards and Conditions for Chief Accountants and Accountants in Charge

1. How are the standards and conditions for accountants in charge prescribed?

Under Article 21 of Decree 174/2016/ND-CP on standards and conditions for chief accountants and accountants in charge:

• Chief accountants and accountants in charge must meet the standards prescribed at Points a, c and d, Clause 1, Article 54 of the Law on Accounting 2015 (amended and supplemented by Law 56/2024/QH15, effective from 01/01/2025) and must not fall under the cases of persons not permitted to perform accounting as prescribed in Article 19 of this Decree. The Ministry of Finance regulates the organization, training and issuance of chief accountant certificates.
• Chief accountants and accountants in charge of the following accounting units must have accounting professional qualifications at university level or higher, including:
  • Agencies with state budget revenue and expenditure tasks at all levels;
  • Ministries, ministerial-level agencies, agencies under the Government, agencies under the National Assembly, other central state agencies, and accounting units under these agencies;
  • Public service units under ministries, ministerial-level agencies, agencies under the Government, other central agencies, and provincial People’s Committees;
  • Specialized agencies under provincial People’s Committees and equivalents; state management agencies under these agencies;
  • Central agencies organized vertically and located in provinces;
  • Political organizations, socio-political organizations, socio-political-professional organizations, social organizations, and socio-professional organizations at central and provincial levels that use the state budget;
  • Investment project management boards with their own accounting apparatus using the state budget for Group A projects and national important projects;
  • Level-1 estimate units under the district-level budget;
  • Enterprises established and operating under Vietnamese law, except for the case at Point g, Clause 3 of this Article;
  • Cooperatives and cooperative unions with charter capital of VND 10 billion or more;
  • Branches of foreign enterprises operating in Vietnam.
• Chief accountants and accountants in charge of the following accounting units must have accounting professional qualifications at professional secondary level or higher, including:
  • Specialized agencies under district-level People’s Committees with an accounting apparatus (except level-1 estimate units under the district-level budget);
  • Central agencies organized vertically and located at district level, and provincial agencies located at district level;
  • Political organizations, socio-political organizations, socio-political-professional organizations, social organizations, and socio-professional organizations at district level that use the state budget;
  • Investment project management boards with their own accounting apparatus using the state budget, except for the cases at Point g, Clause 2 of this Article;
  • Commune/ward/town budget and finance accounting units;
  • Public service units other than those at Point c, Clause 2 of this Article;
  • Enterprises established and operating under Vietnamese law without state capital and with charter capital below VND 10 billion;
  • Cooperatives and cooperative unions with charter capital below VND 10 billion.
• For organizations and units other than those specified in Clauses 2 and 3 of this Article, the standards of qualifications and professional competence for chief accountants and accountants in charge shall be decided by the unit’s legal representative in accordance with the Law on Accounting and other relevant laws.
• Chief accountants and accountants in charge of a parent company that is a state enterprise, or an enterprise with state capital exceeding 50% of charter capital, must have at least 05 years of actual accounting work experience.
• The professional standards and conditions for chief accountants and accountants in charge of units under the people’s armed forces shall be prescribed by the Ministry of National Defense and the Ministry of Public Security.

2. May an accountant in charge be appointed when a chief accountant cannot yet be appointed?

Under Article 20 of Decree 174/2016/ND-CP:

• Accounting units must arrange a chief accountant, except for the units specified in Clause 2 of this Article. Where a unit cannot immediately appoint a chief accountant, it shall arrange an accountant in charge or hire services to act as chief accountant as prescribed. The maximum period for arranging an accountant in charge is 12 months, after which the accounting unit must arrange a chief accountant.
• Accountants in charge:
  • State-sector accounting units including: an accounting unit with only one accountant or one person serving concurrently as accountant; and commune/ward/town budget and finance accounting units — these do not appoint chief accountants but only accountants in charge.
  • Micro enterprises under the law on support for small and medium enterprises may arrange an accountant in charge and are not required to arrange a chief accountant.
• The term of appointment of chief accountants of state-sector accounting units, and the term of appointment of accountants in charge of the units specified at Point a, Clause 2 of this Article, is 5 years, after which the procedures for reappointment of chief accountants and accountants in charge must be carried out.
• When changing a chief accountant or accountant in charge, the legal representative of the accounting unit or the manager/operator of the accounting unit must organize the handover of work and accounting documents between the former and the new chief accountant or accountant in charge, and notify the relevant departments in the unit and the agencies where the unit opens transaction accounts of the name and signature specimen of the new chief accountant or accountant in charge. The new chief accountant or accountant in charge is responsible for their own accounting work from the date of handover. The former chief accountant or accountant in charge remains responsible for the accounting work during the period they were in charge.
• The Ministry of Home Affairs guides the job responsibility allowances, competence, procedures for appointment, reappointment, dismissal and replacement of chief accountants and accountants in charge of state-sector accounting units.

Accordingly, where a unit cannot immediately appoint a chief accountant, it shall arrange an accountant in charge or hire services to act as chief accountant as prescribed. The maximum period for arranging an accountant in charge is 12 months, after which the accounting unit must arrange a chief accountant.

3. Is a company penalized for failing to reappoint its chief accountant or accountant in charge?

Under Article 17 of Decree 41/2018/ND-CP on penalties for violations of regulations on organizing the accounting apparatus and arranging persons to perform accounting or hiring accounting services:

– A fine of VND 5,000,000 to VND 10,000,000 for any of the following acts:

• Hiring organizations or individuals not meeting the standards and conditions for accounting practice to provide accounting services for the unit;
• Failing to reappoint the chief accountant or accountant in charge within the prescribed time limit;
• Failing to organize the handover of accounting work upon changes in accounting personnel, chief accountant or accountant in charge;
• Failing to notify as prescribed upon changes of the chief accountant or accountant in charge.

– A fine of VND 10,000,000 to VND 20,000,000 for any of the following acts:

• Failing to organize the accounting apparatus of the accounting unit; failing to arrange persons to perform accounting or to act as chief accountant, or failing to hire accounting service organizations or individuals to perform accounting or to act as chief accountant as prescribed;
• Arranging persons to perform accounting whom the law prohibits from performing accounting;
• Arranging persons to perform accounting, to act as chief accountant or accountant in charge who do not meet the prescribed standards and conditions;
• Appointing a chief accountant or accountant in charge without following the prescribed order and procedures.

– A fine of VND 20,000,000 to VND 30,000,000 for any of the following acts:

• Arranging persons responsible for managing or operating the accounting unit to concurrently perform accounting, warehousing, cashiering, or asset purchase/sale — except private enterprises, limited liability companies owned by one individual, other types of enterprises without state capital that are micro enterprises under the law on support for small and medium enterprises;
• Arranging a chief accountant who does not meet the prescribed standards and conditions;
• Hiring a chief accountant who does not meet the prescribed standards and conditions.

– Remedial measures:

Appointing or hiring qualified accounting personnel, chief accountants or accountants in charge as prescribed for the cases at Points a and b, Clause 1; Points b and c, Clause 2; and Points b and c, Clause 3 of this Article.

Accordingly, a fine of VND 5,000,000 to VND 10,000,000 applies to the act of failing to reappoint the chief accountant or accountant in charge within the prescribed time limit.

Notes on applying current legal provisions

This article belongs to the General Knowledge group and is presented for reference, helping readers understand the legal issue at an overview level before preparing dossiers or conducting transactions.

Legal provisions may change depending on timing, locality, dossier type and specific circumstances. Where it is necessary to determine the exact legal basis applicable to your dossier, you should contact an ANT Legal lawyer at 0966.475.966 for review and advice before proceeding.

Common risks to note

• Applying legal texts that have been amended, supplemented or replaced.
• Preparing incomplete dossiers, documents or evidence.
• Misunderstanding the applicable conditions, procedures, time limits or competent authority.
• Signing, filing or conducting transactions without fully assessing legal risks.

How can ANT Legal help?

ANT Legal assists in reviewing specific situations, checking dossiers, identifying the applicable legal basis, advising on handling plans, and representing you in working with individuals, organizations or competent authorities when necessary.

For quick advice, you may contact a lawyer at 0966.475.966.

Related articles

• Rules on termination of the validity of outbound investment registration certificates under Vietnamese law
• If the minutes of a General Meeting of Shareholders in Vietnamese and a foreign language differ, which minutes apply?
• Does a cooperative registration dossier require the cooperative’s production and business plan?
• Where must a cooperative announce a voluntary contribution campaign? What commitments must the announcement contain?
• To become Chairman of a central cooperative, what university qualifications are required?