In this article
Changing accounting providers is not difficult; the hard part is not letting anything fall through the cracks: a return not filed, a provisional CIT payment forgotten, or the e-tax account password still held by the old provider. This article sets out an accounting handover process for FDI companies around a cut-over date, compiled by the accounting services team at ACCA Consulting Vietnam from our experience onboarding clients.
1. Choosing the right cut-over date
The cut-over date is the day from which the new provider takes full responsibility. Choose a date that coincides with a month-end or quarter-end whose books are already closed, and avoid peak periods such as March (the deadline for corporate income tax (CIT/TNDN) and personal income tax (PIT/TNCN) finalization and the annual financial statements is the last day of the third month after the financial year end, i.e. 31 March for a calendar year).
| Cut-over point | Advantages | Risks |
|---|---|---|
| Start of the financial year | The new provider handles the whole year; responsibility is easy to allocate | Coincides with finalization and the audit of the previous year |
| After the audited financial statements are issued | Opening balances have been audited | The old provider must continue for the first 3–4 months of the year |
| Start of a quarter | Aligns with quarterly tax filing and provisional CIT periods | Mid-year balances need more careful reconciliation |
| Mid-month | Not recommended | Splits one filing period between two providers |
2. A complete accounting handover checklist
- Accounting software data up to the cut-over date, with Excel exports of the trial balance and detailed ledgers for receivables/payables, fixed assets and inventory
- Financial statements, audit reports and finalization returns for prior years
- Tax returns, payment slips and notices received from the tax authority
- Original vouchers and archive listings (accounting records must be kept for at least 10 years under the Law on Accounting)
- Payroll, social insurance (BHXH) files, dependant registrations, files on foreign experts
- List of open items: returns not yet filed, provisional payments not yet made, official letters not yet answered
- Account mapping and the reporting package template sent to the group
- Related-party transaction files and intra-group contracts
E-accounts and digital signatures
This is the part most easily missed. The e-tax, e-invoice, e-social insurance and e-banking accounts and the digital signature belong to the company, not to the provider. At handover, the company should change the passwords itself, revoke the old provider's access and grant the new provider access on a least-privilege basis. Passwords should not be sent by email or ordinary messaging.
| System | Action | Who does it |
|---|---|---|
| E-tax | Change the password, update the notification email | The company's legal representative / authorized person |
| E-invoices | Revoke the old provider's user, create a user for the new provider | The company |
| Digital signature | Retrieve the device, change the PIN | The company |
| E-banking | The provider should have view-only access | The company, working with the bank |
| Accounting software | Back up the data, transfer the licence or export the data | Old provider in coordination with the new provider |
3. A 6-week cut-over schedule
- Week -4
Notify the old provider in line with the contract's termination clause and agree the handover list.
- Week -2
The new provider does a preliminary data review and lists questions and open items.
- Cut-over date
The old provider completes the final period, files the returns for that period and signs the handover minutes.
- Week +1
The company changes passwords and grants new access; the new provider reconciles the opening balances.
- Week +2
The new provider closes the first month and reports any differences found.
4. The risk of filing gaps and what it costs
The biggest risk is a return falling into the gap between the two providers. Under Decree 125/2020/ND-CP (Nghị định 125/2020/NĐ-CP) and its amending documents, penalties on organizations for late filing of tax returns increase with the number of days overdue, on top of late-payment interest of 0.03% per day if tax is paid late.
Upper limits of the penalty brackets under Decree 125/2020/ND-CP and its amending documents. For individuals, half the amount for organizations. VND 5,000,000 is approximately USD 196 (reference rate VND 25,500/USD).
View as table
| 1–30 days late | 5,000,000 VND |
| 31–60 days | 8,000,000 VND |
| 61–90 days | 15,000,000 VND |
| Over 90 days, no tax payable | 15,000,000 VND |
| Over 90 days, tax payable, paid in full before the violation record is made | 25,000,000 VND |
Prevention: state clearly in the handover minutes the last filing period handled by the old provider and the first period handled by the new provider. See also penalties for late filing of tax returns.
FAQ
What if the old provider refuses to hand over the data?
Check the handover clause in the contract and send a written request. In parallel, the company can still look up its returns and invoices on its own e-systems to rebuild the figures.
Is the new provider responsible for errors in prior periods?
Normally not, unless the contract includes a review and adjustment arrangement. Ask the new provider to review the opening balances and record its findings in writing.
Should we change providers during the audit season?
It is not advisable. If you must, agree that the old provider will complete the audit file for that year.
How long does a handover take?
For a small FDI company, typically about 4–6 weeks from notification until the new provider closes the first month, depending on data quality.
Switch to ACCA without filing gaps
ACCA Consulting Vietnam plans the cut-over, reconciles balances and takes over your records. Accounting services in Ho Chi Minh City for FDI companies.
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