Circular No. 05/2025/TT-BTC amending and supplementing certain provisions of Circular No. 202/2012/TT-BTC dated November 19, 2012, issued by the Minister of Finance guiding the registration, management, and public disclosure of the list of practicing auditors; Circular No. 203/2012/TT-BTC dated November 19, 2012, issued by the Minister of Finance on the procedures and formalities for issuing, managing, and using the Certificate of Eligibility to Operate Auditing Services; and Circular No. 157/2014/TT-BTC dated October 23, 2014, issued by the Minister of Finance regulating quality control of auditing services.

b) List of practicing auditors not allowed to continue practicing auditing, including auditors whose practice has been suspended, auditors whose Registration Certificate for Practicing Auditors has been revoked, and other cases where the Registration Certificate for Practicing Auditors has expired or lost its validity according to regulations."

3. Amending and supplementing Clause 1 Article 12 as follows:

"1. A practicing auditor shall be suspended from practicing auditing in the following cases:

a) Being administratively sanctioned twice within a continuous period of 36 months for violations related to independent auditing activities;

b) Using a Registration Certificate for Practicing Auditors that has expired or lost its validity in auditing activities (if the violation is discovered while the person is still a practicing auditor);

c) Refusing to comply with the competent authority's regulations regarding inspection and audit supervision related to independent auditing activities;

d) Using information related to audit files, clients, or audited entities to infringe upon the interests of the State, public interest, or the legitimate rights and interests of organizations, institutions, or individuals;

đ) Signing an audit report when not a practicing auditor (if the violation is discovered while the person is still a practicing auditor);

e) Not preparing an audit file for an audit engagement or other assurance service;

g) Conducting audits, signing audit reports, or reporting on review work results for entities with public interest without approval from the Ministry of Finance to conduct audits for such entities;

h) Signing an audit report or reporting on review work results for entities with public interest while suspended or disqualified from conducting audits for such entities;

i) Conducting audits and signing audit reports for an entity with public interest for more than five consecutive fiscal years;

k) Failing to meet the annual continuing professional education hours requirement set by the Ministry of Finance;

l) Violating the provisions of Article 19 of the Law on Independent Auditing regarding situations where a practicing auditor cannot perform audits;

m) Allowing another organization or individual outside the entity where they are employed to hire, borrow, or use their Auditor Certificate to register for practicing auditing or to register for practicing auditing at an entity where they are not actually working under a full-time labor contract;

n) Committing serious professional misconduct or seriously violating auditing standards and professional ethics standards for accounting and auditing."

4. Supplementing Clause 4 Article 12 as follows:

"4. Suspension period for practicing auditing:

a) Six months for practicing auditors in the cases specified in Points a, b, and c of Clause 1 of this Article;

b) Twelve months for practicing auditors in the cases specified in Points d, đ, e, g, h, i, k, l, and m of Clause 1 of this Article;

c) A practicing auditor in the case specified in Point n of Clause 1 of this Article shall be suspended from practicing auditing in accordance with the law on quality control of audit services."

5. Amending and supplementing Clause 1 Article 13 as follows:

4. Add Clause 4 to Article 12 as follows:

"4. Period of suspension from practicing auditing:

a) Six months for auditors practicing in cases specified in points a, b, and c of Clause 1 of this Article;

b) Twelve months for auditors practicing in cases specified in points d, đ, e, g, h, i, k, l, and m of Clause 1 of this Article;

c) Auditors practicing in the case specified in point n of Clause 1 of this Article shall be suspended from practicing auditing in accordance with the laws on quality control of auditing services."

5. Amend and supplement Clause 1 of Article 13 as follows:

"1. The auditor shall have their Registration Certificate for Auditing Practice revoked in the following cases:

a) Fraud or forgery of documents to meet the conditions for obtaining a Registration Certificate for Auditing Practice;

b) Registering to practice auditing at an auditing firm but not actually working full-time under a labor contract with that auditing firm;

c) Working for two or more auditing firms or branches of foreign auditing firms in Vietnam simultaneously;

d) Contributing capital to two or more auditing firms;

đ) Being suspended from practicing auditing twice within 36 consecutive months;

e) Being prohibited from practicing auditing pursuant to a court judgment or decision that has become legally binding; being criminally prosecuted; being convicted of one of the offenses related to economic management order violations, financial crimes, accounting, or auditing offenses without having the criminal record expunged; being subject to administrative educational measures at commune, ward, town level, compulsory drug rehabilitation, or compulsory education;

g) Having their Auditor Certificate revoked."

Article 2. Amending and supplementing certain provisions of Circular No. 203/2012/TT-BTC dated November 19, 2012, of the Minister of Finance on the procedures and regulations for issuing, managing, and using the Certificate of Eligibility for Operating Auditing Services

1. Amending and supplementing Point b Clause 1 Article 8 as follows:

"b) Name, number, and date of issuance of the Registration Certificate for Auditing Practice of the legal representative and the General Director (Managing Director) of the auditing firm (if they are not the legal representative);"

2. Amending and supplementing Article 12 as follows:

"1. An auditing firm shall be suspended from operating auditing services in the following cases:

a) Violating the cases stipulated in Point a, b Clause 1 Article 27 and Clause 1b Article 29 of the Independent Audit Law;

b) Providing auditing services without having been issued a Certificate of Eligibility for Operating Auditing Services; continuing to operate auditing services after temporarily suspending such services or being suspended from operating auditing services (if the violation is discovered when the auditing firm has already been issued a Certificate of Eligibility for Operating Auditing Services and meets the eligibility criteria);

c) Assigning a person to sign the audit report who is not a practicing auditor;

d) Assigning a practicing auditor to conduct audits and sign financial statement audit reports for a public interest entity for more than five consecutive fiscal years starting from the second time;

đ) Failing to provide information and documents upon request of authorized agencies or organizations;

e) Failing to explain or cooperate upon request of authorized agencies or organizations;

g) An auditing firm in Vietnam jointly operating with a foreign auditing firm fails to store the audit file of the joint operation with the foreign auditing firm to provide cross-border auditing services in Vietnam;

h) Using information related to the audit file, client, or audited entity to infringe upon the interests of the State, public interest, rights, and legitimate interests of agencies, organizations, or individuals;

i) Failing to prepare an audit file for the audit;

k) An auditing firm providing auditing services or review services to a public interest entity without approval from the Ministry of Finance or when suspended or revoked its qualification for auditing;

l) Providing cross-border auditing services in Vietnam without having been issued a Certificate of Eligibility for Operating Cross-Border Auditing Services; continuing to operate cross-border auditing services after temporarily suspending such services or being suspended from operating auditing services (if the violation is discovered when the auditing firm has already been issued a Certificate of Eligibility for Operating Auditing Services and meets the eligibility criteria);

m) Violating the case stipulated in Point c Clause 1 Article 27 of the Independent Audit Law.

2. Suspension period for operating auditing services:

a) Suspension from operating auditing services for three months for auditing firms falling under the cases stipulated in Points a, b, c, d, đ, e Clause 1 of this Article;

b) Suspension from operating auditing services for six months for auditing firms falling under the cases stipulated in Points g, h, i, k, l Clause 1 of this Article;

c) An auditing firm falling under the case stipulated in Point m Clause 1 of this Article shall be suspended from operating auditing services according to the laws on quality control of auditing services.

3. An auditing firm suspended from operating auditing services must cease operating auditing services from the date of the suspension decision.

In the case where an auditing firm is currently suspended from operating auditing services or temporarily suspended from operating auditing services and is further suspended for the violations stipulated in Clause 1 of this Article, the suspension period will not be counted towards the current suspension period or temporary suspension period of operating auditing services.

4. The Ministry of Finance shall publish the decision to suspend operating auditing services on its official website within seven days from the date of the decision."

3. Amending and supplementing Clause 4, Clause 5 Article 16 as follows:

"4. A branch of an auditing firm failing to meet the conditions stipulated in Article 31 of the Independent Audit Law for three consecutive months shall be suspended from operating auditing services for three months.

5. If an auditing firm is suspended from operating auditing services, its branches shall also be suspended from operating auditing services for the same duration as the auditing firm."

4. Supplementing Clause 9, Clause 10 Article 17 as follows:

"9. Notify the Ministry of Finance in writing within ten days from the date when the auditing practitioner is prohibited from practicing auditing according to a court judgment or decision that has become legally effective; is criminally prosecuted; is convicted of one of the offenses infringing economic management order, financial crimes related to position, accounting, or auditing without having their criminal record expunged; is subject to administrative educational measures at commune, ward, town level, compulsory drug rehabilitation, or compulsory education facility."

"10. Maintain a register of auditing contracts and issued audit reports, registering signatures of auditing practitioners at the company; establish procedures for issuing audit reports and controls over the signatures of auditing practitioners on audit reports to regularly review and compare registered signatures with those on audit reports; promptly detect and report to competent authorities about counterfeit seals and signatures, cases where individuals who do not meet the conditions for registration of practice sign audit reports without actually participating in the audit."

Article 3. Amend and supplement some articles of Circular No. 157/2014/TT-BTC dated October 23, 2014, of the Minister of Finance on quality control of auditing services.

1. Amend and supplement Point c Clause 1 Article 11 as follows:

“c) The audit files selected for inspection must be audit files that have issued audit reports during the period from the establishment of the auditing firm (for the first inspection of an auditing firm) or from the last inspection to the inspection date, while also being able to assess the quality of the auditing services of the auditing firm and auditing practitioners. In necessary cases, the audit files inspected may also include audit files that have issued audit reports during the period from the establishment of the auditing firm.”

2. Amend and supplement Article 26 as follows:

"1. An auditing firm shall be suspended from providing auditing services for a period of three months when the competent authority concludes:

a) The quality of auditing services is classified as Level 3 “Auditing service quality does not meet requirements” through two consecutive inspections;

b) The quality of auditing services is classified as Level 4 “Weak auditing service quality, serious errors.”

2. An auditing firm shall be suspended from providing auditing services for a period of six months when the competent authority concludes that the quality of auditing services is classified as Level 4 “Weak auditing service quality, serious errors” from the second time onwards.

3. An auditing practitioner shall be suspended from practicing auditing for a period of six months when the competent authority concludes that the auditing practitioner signed audit reports containing one to two audit files classified as Level 4 “Weak audit file quality, serious errors.”

4. An auditing practitioner shall be suspended from practicing auditing for a period of twelve months when the competent authority concludes that the auditing practitioner signed audit reports containing more than two audit files with technical inspection results classified as Level 4 “Weak audit file quality, serious errors.”

5. If an auditing firm or auditing practitioner conducting audits for entities with public interest commit violations stipulated in Clauses 1, 2, 3, and 4 of this Article, the suspension period will be doubled."

Article 4. Effective date

This Circular takes effect from the date of signature.

Article 5. Responsibilities for Implementation

The Director of the Accounting and Auditing Management and Supervision Department, the Heads of relevant units under the Ministry of Finance, and related organizations and individuals are responsible for implementing this Circular./.