ENTERPRISE SUBJECT TO MANDATORY AUDIT IN 2025

legal basis:

 – Law on Independent Audit 2011, as amended and supplemented, most recently in 2024.

 – Decree No. 17/2012/ND-CP guiding the Law on Independent Audit.

 – Decree No. 90/2025/ND-CP, issued on April 14, 2025, amending and supplementing several provisions of Decree 17/2012/ND-CP, effective immediately.

 – Under Decree 90/2025, an additional group “large-scale enterprises” is required to have annual financial statements audited if they meet at least 2 out of 3 criteria.

ENTERPRISES SUBJECT TO MANDATORY AUDIT IN 2025

Under the Law and Decree 17/2012:

  + Foreign-invested enterprises (FDIs);

 + Credit institutions, including branches of foreign banks;

 + Financial institutions;

 + Insurance enterprises, insurance brokers, reinsurers;

 + Public companies, securities-issuing organizations;

 + State-owned enterprises, enterprises with state capital as prescribed;

 + Investors/projects using state budget capital, when required to audit the final settlement of projects.

Under Decree 90/2025:

+ Other enterprises that satisfy at least 2/3 criteria:

   • Average annual employees participating in social insurance ≥ 200;

   • Annual revenue ≥ VND 300 billion;

   • Total assets ≥ VND 100 billion.

>> CRITERIA FOR LARGE-SCALE ENTERPRISES

–  Average annual employees participating in social insurance > 200: calculated based on social insurance data of the preceding year.

– Annual revenue > VND 300 billion: according to the financial statements of the preceding year.

– Total assets > VND 100 billion: at the end of the fiscal year of the preceding year.

>> TRANSITIONAL PROVISIONS            & EXCEPTIONS

–  If in the fiscal year 2024 an enterprise meets the “large-scale” criteria → mandatory audit applies from FY2025 onwards.

– If for 2 consecutive years the enterprise no longer satisfies 2/3 criteria → mandatory audit obligation ceases until the criteria are met again.

>>> ILLUSTRATIVE EXAMPLES

– Company X (2024): Employees = 220; Revenue = VND 280 billion; Assets = VND 90 billion → meets only 1 criterion → not subject to mandatory audit in 2025 (unless falling into other mandatory groups).

 – Company Y (2024): Employees = 250; Revenue = VND 320 billion; Assets = VND 80 billion → meets 2 criteria → subject to mandatory audit in 2025.

>>> NOTES & RISKS

– Enterprises must monitor data of the preceding year to determine their obligation.

– Failure to conduct audit when required by law may result in administrative penalties, reputational damage, and difficulties in financing or cooperation.

– Enterprises should prepare accounting records, appoint auditors, and schedule audits early

IFRS Auditing and Consulting Company Limited
The company provides a wide range of services such as audit of financial statements, tax advice, accounting services and valuation services with leading experts working in large auditing firms, multinational corporations