Supplementing mandatory audit subjects for 2025

Decree No. 90/2025/ND-CP amending and supplementing a number of articles of Decree No. 17/2012/ND-CP detailing and guiding the implementation of a number of articles of the Law on Independent Audit 

On April 14, 2025, the Government issued Decree No. 90/2025/ND-CP of the Government: Amending and supplementing a number of articles of Decree No. 17/2012/ND-CP dated March 13, 2012 of the Government detailing and guiding the implementation of a number of articles of the Law on Independent Audit 

The specific amended and additional provisions are as follows: 

Supplement the criteria for determining large enterprises that are subject to mandatory audits, specifically: 

Article 1. Addition of several points and clauses to Article 15 of Decree No. 17/2012/ND-CP 

Enterprises classified as other large-scale enterprises in accordance with Point đ, Clause 1, Article 37 of the Law on Independent Audit are those that meet at least two out of the following three criteria: 

• Having an average number of employees participating in social insurance of more than 200 people per year; 
• Having annual total revenue exceeding VND 300 billion; 
• Having total assets exceeding VND 100 billion. 

Principles for determining the average number of employees participating in social insurance per year, annual total revenue, and total assets are as follows: 

• The number of employees participating in social insurance includes all employees managed, employed, and paid by the entity who are registered under the social insurance regime in accordance with the law on social insurance; 
• The average number of employees participating in social insurance per year is calculated by summing up the number of such employees of all months in the preceding year and dividing by 12 months; 
• The number of employees participating in social insurance for each month is determined at the end of the month and based on the social insurance payment documents submitted to the social insurance agency for that month; 
• The annual total revenue is determined based on the annual financial statements of the preceding year, prepared in accordance with accounting laws; 
• The total assets are determined at the end of the fiscal year based on the annual financial statements of the preceding year, prepared in accordance with accounting laws. 

Enterprises that fail to meet the criteria for determining large-scale status for two consecutive years shall not be subject to mandatory audit requirements until they once again satisfy the prescribed criteria. 

Amend the regulations regarding the time for auditors to sign reports for an entity, specifically 

Article 2. Amendment and supplementation to Clause 2, Article 16 of Decree No. 17/2012/ND-CP, as follows: 

A practicing auditor shall not sign audit reports for the same audited entity for more than five consecutive years. 

Transitional provisions regarding the time for auditors to sign reports for an entity and large enterprises subject to mandatory audits, specifically 

Article 4. Transitional provisions 

Practicing auditors who have signed audit reports for an audited entity before January 1, 2025, may continue to sign audit reports for that audited entity. 

Enterprises with total revenue and total assets recorded in the financial statements for the fiscal year 2024, and with an average number of employees participating in social insurance during 2024 that satisfy the criteria under Clause 1, Article 1 of this Decree, shall be subject to mandatory audit for the financial statements starting from the fiscal year 2025 onwards. 

This Decree takes effect from April 14, 2025.