ANALYZING INTERNAL CONTROL REQUIREMENTS UNDER CIRCULAR 99/2025/TT-BTC AND PROPOSING THE APPLICATION OF THE COSO 2013 FRAMEWORK

Abstract

TThis study examines the new governance and internal control requirements introduced by Circular No. 99/2025/TT-BTC (TT99), with a focus on the establishment of internal governance regulations and control mechanisms. Based on legal analysis and theoretical synthesis, the study highlights that increased managerial autonomy is accompanied by higher demands for accountability, risk management, and financial reporting transparency. Inadequate design or operation of the internal control system (ICS) may expose enterprises to significant compliance risks.

The 2013 COSO Internal Control–Integrated Framework is identified as an appropriate methodological foundation for operationalizing TT99’s principle-based requirements. Its five components and seventeen principles provide a comprehensive structure for designing an effective ICS. The study proposes aligning TT99’s requirements with the COSO principles and incorporating technology, particularly ERP systems, to enhance monitoring effectiveness and reduce compliance risks