⚖️ Decree 228/2025/ND-CP • Mandatory Audited Financial Statements
Enterprises subject to mandatory annual audit of financial statements – “Heavy” penalties
Effective from 18/08/2025, Decree 228/2025/ND-CP tightens mandatory audits. Violations may incur administrative fines of up to VND 400 million.
Effective date: 18/08/2025
Maximum penalty: VND 400 million
Maximum penalty: VND 400 million
1️⃣
Wrong selection of audit firm (Article 27)
VND 20–30 mil
Hiring an audit firm without legal eligibility.
VND 30–40 mil
Hiring an audit firm without professional capacity.
VND 40–50 mil
Failure to conduct the mandatory audit of FS.
👉 A common mistake: selecting a small firm without proper license → audit report rejected.
2️⃣
Audit contract non-compliance (Article 28)
VND 5–10 mil
Contract missing mandatory contents.
VND 10–20 mil
Contract signed late.
VND 30–40 mil
Contract signed after audit work has been performed.
VND 40–60 mil
No contract signed but audit still conducted.
⚠️ Tax authorities & the SSC will review contracts. Any deficiency = immediate fine.
3️⃣
Violations during the audit process (Article 29)
VND 20–30 mil
Explanations incomplete or late.
VND 40–60 mil
Failure to explain upon request.
VND 60–80 mil
Engaging a person not qualified to sign the audit report.
VND 80–100 mil
Refusal to provide necessary information/documents.
VND 100–200 mil
Bribery, collusion, concealment, obstruction, misrepresentation.
VND 200–400 mil
Repeat violations (from the second time onwards).
✅ Prevention checklist
- ✓Select audit firms fully eligible (per MOF list).
- ✓Ensure complete terms and sign before the engagement starts.
- ✓Prepare support files: contracts, vouchers, minutes, significant transactions.
- ✓Archive digital & hard copies for at least 10 years.
- ✓Train in-house accountants: “5-minute check – avoid fines”.
🎯 Expert message
“Compliance with Decree 228/2025/ND-CP is a legal shield and a trust key for capital markets, banks, and regulators.”
Need a Decree-228 compliant audit contract & process checklist?
MBA Audit offers a free first-session review of contract templates, SOP archiving, and explanation scenarios.
✨ MBA Audit Firm – Prestige • Integrity • Professionalism
Hotline/Zalo: 0984 844 099 • Email: kinhdoanh@mba-au.com
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