Vietnam 2024

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Actual Central Budget expenditure deviated from the initially approved amount by less than 5% in two of the three years analyzed (-1.88% in 2017; -4.04% in 2018; and - 7.88% in 2019).

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The calculated composition variance by the administration was more than 5% in two of the last three years: - The year 2017: 6.18 %,- The year 2018: 4.51%,- The year 2019: 6.97%

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The budget estimates are not classified with detailed economic content. Therefore, it is impossible to calculate variance in expenditure composition by economic type.

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The contingency provision is subsequently allocated to particular programs in the year: - 201 7: 1.75% - 2018: 1.67% - 2019: 1.57%; i.e. on average less than 3% of expenditure.

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Actual revenue as a percentage of budgeted revenue in the last three years was: - 2017: 99.6%; - 2018: 104.6%; - 201 9: 104.3%

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The variance in revenue composition outturn was less than 10% in two of the last three years, and was: - 2017: 7.3%; - 2018: 9.9%; - 2019: 10.7%.

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Authorities have not used the budget classification to consistently present budget documents, from budget preparation to execution and final account reporting. In addition, the budget estimates are not given a detailed economic classification.

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Budget documentation fulfils four elements, including the two basic elements and two additional elements.

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Assuming PSDUs’ total off -budget expenditure is equal to their off- budget revenue, the total expenditure of extrabudgetary funds and PSDUs outside the state budget, its share in total BCG expenditure in 2019 was 62.5%, far beyond the threshold of 10% for a C score.

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Total revenue of extrabudgetary funds and centrally managed PSDUs outside budget reports in 2019 was 61.5% of total BCG revenue, which is much higher than the limit of 10% for C score.

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Budget reports from EBUs presented information on their revenue, expenditure, and balance. However, they were not as detailed as required. EBUs must submit reports to line ministries for consolidation transmittal to MOF/SAV. But it took more than nine months after the end of the fiscal year for MOF/SAV to receive them.

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98% of horizontal transfers, including balancing and targeted transfers from BCG to SNG, were determined in a transparent and rule-based system. The BCG only made Ad hoc targeted transfers in case of emergencies, including natural disasters, an outbreak of diseases, and other unexpected urgent tasks under BCG responsibilities.

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The budget sets 54% of horizontal transfers to SNGs for the duration of the fiscal stability period and 44% based on a yearly, rule-based system. Only after the NA decides the overall state budget plan do the SNGs have complete information on the rule-based horizontal transfer. In 2019, such information was provided by the NA’s Resolution No. 87/2019/QH14 on November 14, 2019, leaving four weeks for SNGs to complete their budget planning, which is required by the SBL 2015 to be available on December 10 at the latest.

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For most ministries, performance plans include only overall development objectives and some output indicators, not other performance indicators such as outcome indicators. Performance information is not disaggregated by program and/or function and is not published.

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Performance reports are not available, except for some ad hoc information on performance. Annual work completion reports are publicly available internally in the organization and/or posted on the website of the spending units, but they are not specifically performance-focused.

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The SBL 2015 requires line ministries to publish budget plans, execution reports, and budget outturn reports of subordinate PSDUs. In all ministries, frontline PSDUs must submit their reports to their line-ministries, who in turn, prepare the consolidated reports to submit to MOF. However, compliance with the regulation on publishing the reports varies among sample ministries. MOH complies the best since its information is consolidated annually in the ministry’s outturn reports and disaggregated by sources of funding and by individual PSDUs, but information is made publicly available for only two (2017 and 2018) out of three years.

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The SAV conducted performance audits in 2017, 2018 and 2019 on 3, 2 and 3 out of 42 central government units and projects, respectively. It implies that less than 25% of ministries were subject to performance auditing annually. The audit covers such dimensions as operational economy, efficiency, and effectiveness. Several findings were made and submitted to the NA. However, there lacks of information on whether they cover all or juts a part of service delivery functions.

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Fiscal information is made available to the public for six elements, including three basic element and three additional elements, under the specific time frames.

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Only about half of SOEs disclosed their financial statements on their websites. The legal framework requires that SOEs submit their financial statements to their owners, and the MPI, before May 31 st of the following year. The MOF collects financial data of the SOEs through the management information system regularly and consolidates the financial supervision report annually. The MOF submits the financial supervision report to the NA nine months after the end of the financial year and discloses it on the MOF website.

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The SBL 2015 requires that provinces submit their financial execution report to the MOF by October every year. However, only half of the provinces submitted their budget reports before October. The final execution reports are published annually, twelve months after the financial year. Also, the reports do not contain information on fiscal risks.

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The (MTEF) 2020-2022 has a risk section, but the information is limited and only qualitative. This is because the GOV does not yet prepare a fiscal risk statement during the assessment period.

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Authorities conduct the economic analysis of nationally important projects as stipulated in the PIL and guiding regulations. However, there are no standard appraisal methodology guidelines to assess the social and economic return for these investment projects. The NA approves the projects but does not disclose the result of economic analysis to the public.

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Before being included in the annual budget, the MTIP must indicate approval of the projects. In addition, the MPI will allocate annual budget for projects. there is no clear criteria for prioritizing budget allocation to investment projects.

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Even though the investment project's pre-feasibility study (PFS) estimates the cost of the project's whole life, budget allocation for capital expenditure and recurrent expenditure is done separately, and there is a disconnection between the capital investment and operating and maintenance costs.

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The implementing agency monitors significant investment projects and submits reports to the MPI. The MPI consolidates the progress of all investment projects in one report and presents it to the PM. This report is disclosed but does not provide detailed information about individual nationaly important projects' physical and financial progress.

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The government financial statement reports all financial assets. However, the financial statement is not publicly disclosed.

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The GOV has a public asset registry at the MOF, which currently monitors four types of assets with a value of VND 500 million and above. The asset registry only records land belonging to government administrative agencies and PSDUs. It does not include other land monitored separately by the Ministry of Natural Resources and Environment - MONRE. Before 2018, the MOF consolidated the assets report and submitted it to the NA. Starting in 2019, the GOV includes information on assets in the government financial statement, which is not published. The GOV also reports non-financial assets in the government financial statement.

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Transfer and disposal of assets follow the procedures regulated in the Public Assets Management Law and guiding decrees. When there is a change in asset, the managing agency has to report within 30 days to the higher authority within the GOV. The budget execution report includes the revenue/expense from the transfer/disposal of an asset.

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Public debt includes GoV direct debt, GOV-guaranteed debt, and SNG debt. Debts are recorded through the Debt Management and Financial Analysis System (DEMFAS) and reported to the GOV monthly. In addition, the debt bulletin board is updated bi-annually and disclosed to the public via the MOF’s portal. Reconciliation is not done on a timely basis.

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The MOF prepares the five-year and three-year debt management plans, which are updated annually. Annually, the MOF also organizes the annual borrowing plan, which details the new borrowing and guarantees to be issued in the year. The NA approves the five-year plan. Likewise, the PM approves the three-year and annual debt plans

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The MOF prepares a five-year debt management plan. The five-year plan sets out the objectives and prudential debt ratios. This undisclosed strategy also lists the cost-risk and composition of different debt instruments.

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Medium-term macroeconomic forecasts are made and included in formulation of three-year MTEF. This document is sent to the Economic Committee of the NA for review before sending the official submission to the NA. The forecasts are made only for GDP growth rates and inflation (GDP deflators), but not of exchange rates and interest rates. Underlying assumptions of those forecasts are stated and included in the submission to the NA.

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Fiscal forecasts are made for three years, including revenues (by type), aggregate expenditure and the budget balance, which are reflected in three-year MTEFs. As stipulated in Article 17 of SBL 2015, MTEFs are referencing documents, which are sent, together with annual budget plans, to the Finance and Budgetary Committee for review prior to submission to the NA. Major changes in assumptions and corresponding adjustments in fiscal forecasts are stated and included in annual budget documentation submitted to the NA, but the explanation of the main differences of the forecasts between MTEF 2019-2021 and MTEF 2018-2020 was lacking.

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Macro fiscal (revenue) forecast is prepared by GDT, in coordination with General Department of Custom, for three years. The forecast is adjusted when big changes in its key assumptions occur, following three scenarios: optimistic, central, and conservative scenarios corresponding to change in fundamental macroeconomic assumptions. GDT provides a report in which qualitative assessment of the impact of big changes of macroeconomic assumptions is made. The report is sent to the MOF for internal use, not for publication. While sensitivity analysis in the sense of calculating elasticity of revenue to 1% change in macroeconomic assumption is not made, different revenue scenarios are developed.

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All new policy proposals must do regulatory impact assessment (RIA), including fiscal impact analysis as required by law. A report on consolidated fiscal impact of all policy proposals made for the budget year and two outer years, with different levels of specificity, is available and submitted to the NA. This practice envisaged by law was strictly followed in the period of analysis.

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Five-year MTBP serves as fiscal strategy, in which time-based numerical fiscal targets and qualitative objectives are set for a period of five years. Those objectives and targets then are translated into more concrete three-year targets in rolling MTEFs. However, neither MTBP nor MTEFs presents changes in the stock of financial assets and liabilities. Those strategies are adopted by the GOV and submitted to the NA. Only five-year plan is enacted by the NA, while MTEFs are used as reference for annual budget determination. The latter is attached to the annual budget proposal submitted to the NA and publicly made available since the first MTEF 2018-2020 onwards.

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Mid-term and End-term reports on progress in implementing MTBP are available. Annual review of previous MTEF performance is included in the first chapter of the next MTEF. Brief explanation of deviation between implementation and plan is presented, and corrective actions are proposed. All such reports are submitted to the NA but not made available to the public.

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National medium-term expenditure estimates, as reflected in the national MTEF, are allocated only by economic categories at 1 digit GFS (recurrent vs. Capital and interest payment), not by administrative classification. In ministerial expenditure estimates (ministerial MTEFs), medium- term appropriation of recurrent expenditure is made by 13 functions and programs. Capital expenditure is disaggregated by programs and projects for the entire 5-year period in MTIP), which gradually enter to Annual Public Investment Plan (APIP) depending on annual funding availability.Thus, capital estimates have not been incorporated into ministerial MTEF’s yet.

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Recurrent budget, not capital budget ceilings are available for the fiscal year and two outer years. Recurrent budget ceilings are not approved by the GOV.

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Ministries are obliged to formulate their medium-term strategic plans, which are so-called five-year sector development plan. The strategic plans are not costed, (except its medium-term capital budget in the form of MTIP) Thus, there is no evidence for this alignment of strategic plans and medium-term budgets.

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Reconciliation of estimates between the corresponding years in two consecutive medium-term budget plans is not made. Thus, deviation if any is not shown and explanation is not made, even for big changes and at the aggregate level.

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Annual budget calendar year exists, ministries only have less than 4 weeks to prepare budget proposal, only some ministries submitted on time in 2019

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Budget circular covers all revenues and expenditures for full year in aggregation form. Only recurrent budget ceiling for each ministry is provided in MOF's circular. MPI’s circular only provides guidance on principles for formulating, and the outline of, the annual capital budget proposal.

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Annual budget proposals were submitted more than 2 months before the start of fiscal year for 3 years

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The NA’s budget scrutiny covers fiscal policies, medium-term forecasts as well as details of expenditures and revenues

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Procedures for the NA ’s scrutiny of the budget are provided in Resolution 343/2017/UBTVQH14 and strictly adhered to, however does not include public consultation

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Always before the start of the financial year.

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Rules for budget adjustments by the executive are provided in the Laws and adhered to.

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Tax payers’ rights and obligations are clearly defined in the Law on Tax Administration, Law on Complaints, and its implementation guiding documents. Information on their obligations and rights including tax complaint procedures and process are fully and comprehensively disclosed in various forms (website, publications, mass media). Tax authorities at all levels have dedicated departments for handling complaints. However, the self-help information (in English language) available online is not entirely up-to-date and easy for taxpayers to get the information they need.

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The Law on Tax Administration of 2013 has some provisions on risk management in tax administration. A comprehensive and systematic step-wise approach to risk management has been applied at tax and customs offices. Risk management at tax authorities is operated on software that analyzes taxpayer risk information (TPR). However, risk management has only been implemented for a number of operations such as formulating tax audit and inspection plan to organizational taxpayers (for CIT, VAT, excise tax, etc.), piloting risk assessment in classification of VAT refund applications and management of invoices and documents. The set of risk assessment criteria is also maintained in a rigid way, so it is difficult to choose criteria that are adjusted to the assessment objective15. Only a few revenues use partially structured and systematic approaches to assess and prioritize compliance risks for certain revenue streams (17% VAT and 5% customs duties). In 2019, the Law on Tax Administration was enacted, introducing Article 9, which establishes provisions for risk management in tax administration.

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At the GDT, the inspection function is performed by the Tax Inspection and Investigation Department. Inspection and investigation plans are made in advance with clear risk assessment criteria issued by the MOF. In 2019, complete all on-plan auditing and inspection activities of the entire tax administration system, reaching 109.72% of the target for 2019. On-enterprise-site checking and inspection covered 19.5% of total registered businesses. At-tax-office checking 100% VAT records via software. Tax authorities do not have the function of investigating and prosecuting tax affairs. Post-checking findings and corrective actions must be made available to the public. Entities collecting the majority of revenue undertake audits and fraud investigations managed and reported on according to a documented compliance improvement plan and complete all planned audits and investigations.

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Total Arrears as of end 2019 was less than 10% of total revenue for the year, and outstanding debts over 12 months were less than 25% of total outstanding receivables for that year.

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Collection reports are made monthly and disaggregated by revenue types. However, the extrabudgetary revenues such as that of VSS have not been aggregated monthly. Total non-budget revenue including VSS revenue and its share in total central government revenue was 38% in 2019

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All budget revenues are deposited directly into the Treasury accounts on a daily basis.

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Tax and Customs Offices make full conciliation of revenue collections to the Treasury in a monthly basis.

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The entire treasury balance is consolidated daily into the State Treasury's general current account at the SBV.

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Every year, before December20 of the previous year, the State Treasury prepares and submits the the MOF a Cash Management Scheme for the next year. The the MOF approves it before January 1 of next year. Quarterly, before the 20th of the last month of the quarter, the State Treasury develops and submits to the MOF a Cash Management Scheme for the next quarter. The MOF approves prior to 01 of the first month of the next quarter. Since May 2020, this process is conducted monthly.However, cash planning is currently mainly based on calculation formulas combined with experience and historical data information, instead of aggregating detailed information from expenditure units.

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Spending units received their approved budget plans prior to 31 December of the previous year. Spending units are able to make detailed plans and cash commitments in alignment with assigned budget plans.

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Major in-year budget adjustments must be proposed by the GOV and submitted to the NA for approval. In emergency cases relevant to national defense and security where adjustments are a must or when revenue collection is below the NA’s target, the NA’s Standing Committee can decide adjustment and report to the NA at the next meeting session. In 2019, there was no adjustment to the allocated budget subject to the NA’s decision.

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There are no payment arrears recorded through the Treasury offices. There was a large stock of capital arrears accumulated prior to 2014. Spending units are requested to pay off the arrears by the end of 2020. The stock of arrears was less than 2% of the total expenditure in the last three years.

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Payment on expenditure arrears are not monitored or reported by the State Treasury because there is none. Capital arrears are reported in the public investment monitoring report annually. However, the stock of capital arrears are reported at aggregate level, without detailed information such as the age of the arrears.

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Integration between personnel, payroll and budget data is strictly managed at different levels of management. At macro level, the PM controls the total number of public servants (excluding public officers working for political apparatus) while Ministry of Home Affairs (MOHA) is obliged to appropriate that number to different ministries and provinces. Based on the staff number managed by the MOHA, the MOF allocates a lump-sum administration budget to each ministry, in which its total payroll is secured exactly in alignment with its appropriated staff numbers. Each ministry is responsible for managing its own staff quota (as far as it does not exceed the staff quota appropriated by MOHA) and payroll, which finance is managed by MOF. The conciliation between personnel and payroll records is made monthly at spending unit level. However, there are no electronic links between personnel and payroll databases in most ministries, with changes in the payroll (reflecting appointments, promotions, etc.) entered manually by payroll staff in accordance with paper-based decisions of changes in personnel records.

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Within a CG agency, any change in personnel records is informed immediately to the payroll accounting unit, who will enter changes into the payroll management system, and send updated information to Treasury. Updated salaries are paid directly by the Treasury to the agency’s banking account, then to personal accounts. The entire updating and payment process occurs within a month. Retroactive adjustments are rare, usually to comply with the existing procedures rather than to correct errors. The most delayed retroactive payment is made for early salary pay as reward for outstanding performer. Since the current regulation limits the number of early pay increases not to exceed 10% of the unit’s total staff, retroactive adjustments account for less than 3% of total payroll.

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Personnel records are strictly managed by CG agenc y’s personnel management unit. The financial management unit can adjust individuals’ pay and allowances only when it receives formal and eligible decisions for changes made by the competent personnel management authorities. All changes are made in the unit’s financial accounting software, which allows audit trail and integrity of data.

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Prior to 2020, internal audit unit was not established in most of CG agencies, except six agencies including the MOF, MPI, Ministry of Defense, Ministry of Public Security, SBV and VSS. Overseeing internal affairs of a public agency is responsible of People’s Inspectorate and Trade Union, but more from controlling than systematic auditing perspective. From 2020, establishment of internal audit function is required for all CG agencies by Decree 05/2019/ND-CP on Internal Audit. However, so far only six BCG agencies have their own internal audit function, in which payroll audit is combined with other expenditure audit issues. The audit is conducted every year. In remaining agencies, the oversight function was still assigned to People’s Inspectorate in conjunction with Trade Union. External payroll audit was partially conducted by SAV in 2017, and it wasintergated in recurrent expenditure audits in 2018 and 2019 auditing missions. However, only 13 ministries were audited in 2017, 1n 2018 and 14 in 2019. Thus, not all ministries were audited at least once in the course of three years 2017-2019. For example, MOHA was not audited in those years.

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Databases or records are maintained for all contracts including data on what has been procured, value of procurement and who has been awarded the contracts by both electronically and paper-based method. Procurement Plans are published at the Public Procurement Agency’s (PPA) website 17 and compare good to factual plans. VNEPS (Vietnam’s e-GP system) collects procurement data based on the requirement to publish procurement information from both paper-based procurements and those conducted through e-GP. Information collected includes procurement plans and the procurement process including the successful Provider and contract amount. Information on contract implementation following award is not collected by the system and performance reports are not generated.

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All agencies follow open competitive method by default as per the law. However, single source contracting (non-competitive method) represents 8.7% of the total value of all public contracts concluded in 2019 according to the MPI report 18 . The non-competitive method is often used to fill the needs of contracting authorities before budget appropriation. Open competition is the default procurement method in the law and there are thresholds below which direct selection is permitted. <1billion VND for construction and goods contracts and <500million VND for consulting services contracts. Direct selection is also permitted in law for cases as stipulated in Article 22, PPL and Article 54, Decree 63/2014/ND-CP. Contract award information is published in VNEPS and in the Procurement Newspaper.

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The legal framework for procurement, procurement plan for 2020, realization of procurement operation for 2019 as well as bidding opportunities and contract awards are available on the PPA website 19 in a timely manner. The posting of information on to the VNEPS is well managed and avails the public with free access to information on the conduct of the procurement of public contracts. Information is accessible in the technical format from this one source for all registered/interested parties.

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Procurement complaints may be reviewed by the central/ministerial/local complaints resolution committee (CRC). The CRC is set up by Decree 20 , are independent of the procurement process, follow laid down procedures in handling complaints and issue binding decisions. Complainants have to pay fees for logging complaints.

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Accounting Law 2015 and its guiding Decree 174/2016/ND-CP has stipulated the segregation duties between head of the unit or executive (authorization), chief accountant (recording), and audit. This segregation is required throughout the entire spending process. However, this segregation has not been legally required for custody of assets.

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Expenditure control has been made in two forms: (i) commitment to approved budget appropriations; and (ii) making expenditure commitment control procedure. The former is applied to all spending units. Their payments are limited within approved appropriation plans, which are sent to the State Treasury for control. The latter, however, is applied only for a recurrent spending item valued from VND 200 million and capital from VND 1 billion. In these cases, expenditure commitment control must be made and strictly managed by the State Treasury.

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Clear rules and procedures are laid down in Decree 11/2020 and MOF’s Circular 62/2020, which are applied to all beneficiary agencies getting funds from the state budget, including CG agencies. After receiving legitimate and valid supporting documents attached with a payment request, the State Treasury makes the payment within 1-3 days to the requesting unit. Unqualified payment request is rejected, and a notice letter is sent to the requester. Thus, 100% of actual outlays complied with expenditure control rules and procedures, either via budget appropriation plans or expenditure commitment control. The ratio to budgeted gross expenditure was 83% on average.

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Internal audit is performed at only the MOF and other 5 central agencies, among more than 20 agencies

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Legal documents issued in 2020 provide for audit manual in accordance with international standards. The current practice in 2019 however are not yet risk-based and focus on financial compliance only

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Annual audit program exists. All plans are implemented. Reports are not publicly disclosed.

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No legal requirement for the period to respond, in current practice the management respond in 30 days in the MOF.

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Effective daily reconciliation. All Treasury sub-accounts transfer balances to Treasury Single Account (TSA) at the end of the day.

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Accounting suspense accounts are cleared within 3 working days and have zero balance at year end. “Account waiting for decisions” of Authorities are reconciled monthly and cleared immediately when the decision is made.

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Reconciliation of advance accounts is performed quarterly within one month from the end of each quarter. Advances to staff are cleared within a month. Advances to contractors are cleared upon work in progress.

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Access to data is restricted to authorized persons. Historical data change is not permitted. Data correction is made in the form of new accounting entries and has audit trail. The role of verifying financial data integrity is embedded in each recording and reporting entity instead of being independent.

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The in-year budget reports allow direct comparison with the original budget with partial aggregation by each ministry, sector, locality and by field of expenditure.

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Budget execution reports are prepared monthly, and issued within 2 weeks from the end of each month.

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The data is consistent and useful for analyzing the budget implementation. Analysis of the budget implementation is done quarterly. Expenditure is only shown in the payment stage. Exploiting budget data from the Tabmis, however, there is no independent data integrity verifier.

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Budget execution report is on a cash basis and does not contain information on assets, liabilities. Unspent budget carried forward from the previous year is recorded as revenue, causing confusion. The GOV starts to prepare accrual accounting financial statement, which is not disclosed yet for assessment.

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Law requires ministries to submit budget execution report within 10 months after year end. SAV’s information showed ministries were late in submitting 2019 reports.

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The local guidelines are used consistently and transparently but with significant deviation from IPSAS.

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All revenues are audited. Only 50% ministerial agencies are audited for expenditures. Audit opinion is not yet provided for the truth and fairness of GOV or any ministry’s budget execution report. The audit report highlights all material issues of compliance, ineligible expenditures and internal controls.

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SAV performed most of audit work before the official submission of Government Budget Execution Report by the MOF, and submit audit report to the NA within 3 – 4 months

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The follow up and enforcement of audit recommendations is provided by State Audit Law and SAV decision. Implementation rate is more than 70% every year.

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SAV independence institutionally, operationally and financially from the Executive as provided by Constitution 2013 and State Audit Law 2015.

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The Budget and Finance committee of the NA scrutinizes the audited budget report. It usually takes les than one week from the time they receive the report.

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Hearings are organized in NA annual meeting with serious discussions on audit findings and PM’s conclusion

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The NA’s Resolutionon budget execution approval requires the GOV to implement audit recommendations and report on the status. The NA works with SAV to review the implementation status.

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The NA isues report scrutinizing the audited reports. The scrutinizing report is disclosed for financial year 2017 but not for 2018 and 2019.