CIT Finalization, Financial Statements, Mandatory Audit: Deadlines

Three accounting milestones are packed into the same period of the year — corporate income tax (CIT) finalization, submitting financial statements (BCTC), and for some businesses completing the audit — but these three tasks have three different deadlines and do not automatically wait for one another. Filing late on any milestone triggers its own fine or late-payment interest.

Short answer: the annual CIT finalization dossier must be filed no later than the end of the third month after the end of the fiscal year (usually 31 March for a calendar year). Annual financial statements are submitted to the competent state authority no later than 90 days from the end of the annual accounting period. The tax deadline does not wait for the audit report to be completed — a business subject to mandatory audit (including large-scale domestic businesses, not only businesses with foreign capital) needs to sign the audit engagement early to have the audited report in time for the filing deadline.

By what date must annual CIT finalization be filed?

Under Article 21 of Circular No. 89/2026/TT-BTC (guiding Law on Tax Administration No. 108/2025/QH15 and Decree No. 252/2026/NĐ-CP), the annual corporate income tax finalization dossier must be filed no later than the last day of the third month from the end of the calendar year or fiscal year. For a business whose fiscal year coincides with the calendar year (1 January–31 December), the deadline is 31 March of the following year.

Four tasks to complete before this deadline:

• Finalize revenue, deductible expenses and depreciation — cross-checking against invoices and contracts, not estimating.
• Correctly determine any tax incentive (if any, for example the 3-year CIT exemption for newly established small and medium enterprises under Resolution No. 198/2025/QH15 and Decree No. 20/2026/NĐ-CP) — record it on the right line, and only if the conditions are met.
• Complete the return and appendices in the current form; pay the remaining tax due (if any) within the same deadline.
• Keep the electronic data file (XML or the prescribed format) of the filed dossier, not only a printed copy.

Being in a loss or exempt from tax does not mean being allowed to skip filing. The tax authority cross-checks revenue recorded through e-invoices against the figures on the finalization return. Failing to file the return on time is still counted as late filing of a tax return, even if the tax payable is zero.

An extension is an administrative decision, not a habit. An extension of the deadline for filing the finalization dossier (if within a case eligible for extension under the Law on Tax Administration) must have a document or decision of the tax authority; the filing date is not automatically pushed back for reasons internal to the business.

How long does a business have to file annual financial statements?

Annual financial statements (BCTC) are prepared under Law on Accounting No. 88/2015/QH13 (clause 3, Article 29: submitted to the competent state authority no later than 90 days from the end of the annual accounting period). From fiscal year 2026, financial statements are prepared under Circular No. 99/2025/TT-BTC (replacing Circular No. 200/2014/TT-BTC), and Article 25 of this circular keeps the same milestone: a business must submit its annual financial statements no later than 90 days from the end of the annual accounting period, applying to all types of enterprises, without distinction by form of ownership.

A parent company or general corporation must also set the deadline for its subsidiaries and affiliated units to submit financial statements, so that the group’s reports can be consolidated or aggregated in time for the 90-day deadline above.

For a business subject to mandatory audit, the dossier submitted to the managing authority must be audited financial statements, not a draft or a version without the auditor’s opinion.

The tax deadline does not wait for the audit signature. This is the point that most often causes late filing: a business waits for the audit report to be completed before starting the tax finalization dossier, while the CIT finalization deadline (the end of the third month) may arrive before the auditor issues the report. A business subject to mandatory audit should sign the audit engagement early, right after closing the annual accounting books, so as not to be caught between the two milestones.

How much is the fine for filing a tax return late?

The Law on Tax Administration clearly separates two kinds of obligation for late filing: an administrative fine for the act of late filing of a tax return, and late-payment interest calculated on the tax actually payable — these are two independent amounts and do not replace each other.

The administrative fine for late filing of a tax return (under Decree No. 125/2020/NĐ-CP, as amended and supplemented by Decree No. 310/2025/NĐ-CP, effective 16 January 2026), the common levels applied to organizations:

• 1–5 days late, with mitigating circumstances: a warning.
• 1–30 days late: fine of 2,000,000–5,000,000. VND
• 31–60 days late: fine of 5,000,000–8,000,000. VND
• 61–90 days late: fine of 8,000,000–15,000,000. VND
• Over 90 days late, with the tax and late-payment interest fully paid before the tax authority announces a tax inspection or examination decision: fine of 15,000,000–25,000,000. VND

Late-payment interest on tax is calculated at 0.03% per day on the late tax amount, continuously by the actual number of days late, with no “grace period” unless there is a valid extension decision.

A common mistake: paying into the wrong budget sub-item, or thinking “paying two months’ worth next month makes up for it” — while late-payment interest has been running since the overdue date, and a payment into the wrong sub-item may not yet be recorded as the correct obligation, leaving the tax debt outstanding even though the money has been transferred.

Which businesses must have their financial statements audited?

Not every business must have its financial statements audited every year — this is a separate rule under the Law on Independent Audit, applying to certain specific groups. Under Decree No. 17/2012/NĐ-CP (as amended and supplemented, most recently by Decree No. 90/2025/NĐ-CP, effective 14 April 2025), the main groups subject to mandatory annual audit of financial statements include:

• Enterprises with foreign investment capital (FDI).
• Credit institutions established and operating under the Law on Credit Institutions, including foreign bank branches in Vietnam.
• Financial institutions, insurance enterprises, reinsurance enterprises, insurance brokerage enterprises, and branches of foreign non-life insurance enterprises.
• Public companies, issuers and securities business organizations.
• State-owned enterprises, except state-owned enterprises operating in fields classified as state secrets under regulations.
• Audit firms and branches of foreign audit firms in Vietnam (auditing their own financial statements).
• Enterprises and organizations carrying out projects of national importance and group A projects using state capital (except projects in fields classified as state secrets) — auditing the completed project settlement report.
• Enterprises and organizations in which a state group or general corporation, or a listed, issuing or securities business organization, holds 20% or more of the voting rights at the end of the fiscal year — auditing annual financial statements.
• Large-scale enterprises — a group newly added by Decree No. 90/2025/NĐ-CP, applying also to domestic enterprises without foreign capital: those meeting at least 2 of the following 3 criteria (determined from the immediately preceding year’s financial statements) — an average of over 200 employees participating in social insurance in the year; total annual revenue over 300 billion VND; total assets (at the end of the fiscal year) over 100 billion VND. The rule took effect from 14 April 2025; enterprises meeting the criteria for 2024 have been subject to mandatory audit from the 2025 financial statements.

An enterprise required to prepare consolidated or aggregated financial statements has the audit carried out on that consolidated or aggregated financial statements.

Mandatory audit under the law is different from an audit requirement in a loan dossier or bidding dossier, and different from “whether there is foreign capital or not”. Since Decree No. 90/2025/NĐ-CP took effect, a domestic limited liability company or joint stock company with no foreign capital may still be subject to mandatory audit if it meets the large-scale criteria above — this is the group of large businesses with many employees that many business owners have not noticed are already subject to mandatory audit. A business not in the main groups above (including the large-scale group) is usually not subject to mandatory audit under the law; Article 15 of Decree No. 17/2012/NĐ-CP also has a provision leaving room for cases where other sector laws require mandatory audit, so a business operating in a sector with its own rules should ask its audit and accounting partners to be sure. A lending bank or a bid inviter may also set its own additional condition of submitting audited financial statements — this is a requirement of the receiving party, not a legal obligation applying to every business.

For a business subject to mandatory audit, it is advisable to sign a contract with a qualified independent audit firm early in the year, rather than starting to look for an auditor only near the financial statements filing deadline — the audit process needs real working time with the books and cannot be shortened to meet the deadline.

A common mistake in this group: business owners only remember that “having foreign capital means audit is required” but forget that this obligation applies from the very first fiscal year with foreign investment capital, not only once the business is large enough or has stable revenue. The opposite mistake, which has appeared only since the “large-scale enterprise” group was added: a domestic, 100% Vietnamese-owned business with many employees or large revenue/total assets assumes by default that it is not subject to mandatory audit because it has “no foreign capital” — when in fact, having met 2 of 3 large-scale criteria from 2024 onward, audit is still mandatory. Some small domestic limited liability companies worry unnecessarily because they confuse “mandatory audit under the law” with “audit required by the lender or the bid inviter” — two matters with different legal bases and purposes, which need to be clarified with accounting and audit partners before concluding whether the business is subject to mandatory audit.

How Thái Tín supports you

Thái Tín is the coordinating point that reviews the tax and accounting milestones through the year and connects the right accounting and audit partners suited to the business’s scale and type:

• Setting up the calendar of CIT finalization and financial statements filing milestones by the business’s own fiscal year, so as not to be caught between two different deadlines.
• Reviewing the three scale criteria (labor, revenue, total assets) to determine whether the business has newly become subject to mandatory audit under Decree No. 90/2025/NĐ-CP, even without foreign capital.
• Connecting a qualified independent audit firm early in the year, so that the audited report is ready by the financial statements filing deadline.
• Reviewing filed dossiers if there was ever a late filing, to compute the correct fine and the late-payment interest still to be handled.

The tax authority and the independent audit firm review and carry out the professional part under their authority; Thái Tín coordinates the dossier and connects the right partner for each task.

Not sure whether your business is subject to mandatory audit, or close to the finalization deadline? Send the business type, the number of employees and the latest annual revenue so Thái Tín can connect the right partner for a review.

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