GUIDANCE ON THE LAW ON INDEPENDENT AUDIT – DECREE NO. 90/2025/ND-CP AMENDING DECREE NO. 17/2012/ND-CP

On April 14, 2025, the Government issued Decree No. 90/2025/NĐ-CP, which amends and supplements Decree No. 17/2012/NĐ-CP detailing and guiding the implementation of certain provisions of the Law on Independent Audit. This Decree takes effect from April 14, 2025. Accordingly, the Decree introduces several key amendments and supplements, including:

I/ EXPANSION OF MANDATORY AUDIT SUBJECTS

The Decree supplements regulations requiring large-scale enterprises to have their annual financial statements audited, provided they meet at least two out of the following three criteria:

  • The average annual number of employees participating in social insurance of over 200 (calculated as “total number of employees participating in social insurance – all employees managed and paid by the unit participating in social insurance” of all months in the previous year divided by 12 months);
  • Having annual total revenue exceeding VND 300 billion (based on the annual financial statements of the the previous year, prepared in accordance with applicable accounting regulations);
  • Having total assets exceeding VND 100 billion (based on the annual financial statements of the previous year, prepared in accordance with applicable accounting regulations).

II/ EXEMPTION FROM MANDATORY AUDIT

Enterprises do not satisfy the criteria for determining large-scale enterprises for two consecutive years will not be required to conduct mandatory audits until they continue to satisfy the above criteria.

III/ CHANGE IN CONTINUOUS AUDIT SIGNING PERIOD

According to Decree No. 90/2025/ND-CP, practicing auditors not allowed to sign audit reports for a entity for more than 5 consecutive years instead of 3 consecutive years as per Decree 17/2012/ND-CP.

IV/ TRANSITIONAL PROVISIONS

  • Auditors who signed audit reports before January 1, 2025, shall continue to sign until the end of the 5-year consecutive period;
  • Enterprises with financial data for the year 2024 that meet the criteria of large-scale enterprises will apply mandatory audit from the the fiscal year 2025 onwards.