👉 An accountant’s responsibility is NOT to “Take on all risks” for the enterprise.

📌 Summary of Key Regulations – Article 3 of Circular 99

Article 3. Internal Governance and Control

1. The establishment, implementation, management and control of arising economic transactions of enterprises must comply with the provisions of law, relevant mechanisms and policies.

2. Enterprises shall have to formulate their own internal management regulations (or equivalent documents) and organize internal control in order to:

• Clearly delineate the rights, obligations and responsibilities
• For departments and individuals related
• To the establishment, implementation, management and control of economic transactions arising at enterprises

➡️ Purpose:

⚠️ The Most Important Message of Circular 9

• ✅ Circular 99 is not intended to “tighten accounting controls”
• ✅ This aims to clearly define the responsibilities of the accounting department and other departments within the company
• ❌ No more old ways: “All burdens fall on one person” – all mistakes fall on the accountant.

🎯 Management perspective in line with the spirit of Circular 99

📘 Accountants are only responsible within the scope of their assigned functions:

• Recording accounting books
• Preparing financial statements
• Preparing tax reports
• Perform tasks as specified in:
  • Internal regulations
  • Assignment decisions
  • Labor contracts

🚫 Accountants do not replace the responsibilities of:

• The person proposing the transaction
• The Sales and Marketing Department
• Approvers – Executive Managers
• The business owner

👉 If enterprises want to ensure proper risk management, they must establish clear regulations — not “push everything onto the accountant”.

💡 What should enterprises do immediately?

• ✔️ Review the internal governance regulations
• ✔️ Clearly define authority and responsibilities in writing
• ✔️ Standardize approval, documentation, and record-keeping processes
• ✔️ Position accounting in its proper role of recording and control — not “carrying risks for the entire system”

📄 Do you need an Internal Regulation template compliant with Circular 99?

If you need a full PDF version of the Internal Governance and Internal Control Regulation to apply immediately at your enterprise:

👉 Leave comment saying “I need” or provide your email/phone number – we will send the full PDF version for your reference.