Proposal for New Regulations on the Registration and Use of Identification Numbers for Entities Related to the Budget

The Ministry of Finance stated that the development of this Circular to guide the registration, issuance, and use of budget-related entity codes—which replaces Circular No. 185/2015/TT-BTC on the registration, issuance, and use of codes for budget-related entities (BREs) to improve a comprehensive and unified legal framework for the registration, issuance, management, and use of BRE codes.

The core objective is to establish a standardized legal basis for the unique identification and comprehensive management of all entities related to the state budget, including: state agencies, political organizations, and political-social organizations; political-social and professional organizations, social organizations, and social-professional organizations supported by the state budget in accordance with their assigned tasks; public service units; revenue collection agencies; agencies, organizations, and enterprises tasked with implementing public investment projects and public-private partnership (PPP) projects; project management boards; and state financial funds outside the budget.

The Circular provides detailed regulations on the documentation, procedures, and processes for registering, updating, managing, and using the National Public Sector Entity Code (ĐVQHNS), ensuring that all units, tasks, and investment projects from the central to the commune level are identified by a single, stable code throughout their operations.

At the same time, the Circular establishes a transparent legal framework for administrative agencies (financial agencies, tax agencies, customs agencies, the State Treasury) to coordinate the operation of the system and oversee public finances, as well as to facilitate the connection, sharing, utilization, and use of National Public Administration Unit ID data nationwide.

Several New Proposals

The Ministry of Finance stated that, in the draft, the Ministry has proposed several new provisions compared to Circular No. 185/2015/TT-BTC guiding the registration, issuance, and use of codes for units related to the budget, such as:

Expanding the scope of entities eligible for budget-related unit codes

The draft proposes adding investment preparation tasks, planning tasks, ODA projects, public-private partnership (PPP) investment projects, and other public investment projects to the scope of entities eligible for code assignment; and to include state-owned enterprises, agencies, organizations, and other enterprises that are formally assigned in writing to carry out public investment tasks and projects pursuant to Clause 4, Article 4 of the Public Investment Law. As a result, budget funds can be tracked from the pre-investment stage and the planning stage.

Establishing the Principles Governing Authority to Assign Codes to Investment Tasks and Projects

The authority to assign codes is determined based on the budget level of the agency approving the investment decision, regardless of the source of allocated funds or the supervising agency of the investor. This provision definitively resolves long-standing issues regarding projects of ministries and central agencies using local budget funds, as well as projects with independent component projects implemented by local authorities.

Codifying the Parent-Child Project Code Relationship

The draft circular defines “parent” and “child” national budget unit codes and stipulates the principles for declaring the parent code when registering codes for component projects and subprojects; the principles for declaring the total investment amount; principles for not aggregating data during consolidation; and the condition that a parent code may only be closed when all subordinate child codes have been closed or are no longer valid.

Transition from business software to the digital platform for assigning National Project Unit (NPU) codes

The term “Digital Platform for Issuing National Social Insurance Identification Numbers” replaces the previous separate concepts. All steps—submission, receipt, processing, and issuance of results—for online applications are carried out on the Digital Platform; entities are not required to submit paper applications. The Digital Platform is connected to the Electronic Identification and Authentication System and to the National Information System and Database on Public Investment; it allows users to log in using an electronic identification account.

Establishing the Legal Validity of Electronic Applications and Results

Online registration applications have the same legal validity as paper-based applications. The electronic certificate of the National Public Investment Unit (ĐVQHNS) code, digitally signed by the Financial Authority, has the same legal validity as the paper version and is embedded with a QR code for verification and cross-checking. Entities may choose to use digital signatures or not; if no digital signature is used, the documents are authenticated through the access account, and transactions conducted via that account are deemed to have been performed by the account holder.

Reducing Documentation Requirements and Processing Time

Entities are not required to resubmit information or documents already available on the digital platform and connected databases; the Financial Authority directly accesses this data. The processing time for issuing a tax identification number via the online method has been reduced from 2 days to 1 business day, and via the in-person method from 3 days to 2 business days; the deadline for supplementing application documents has been reduced from 10 business days to 3 business days.

Addition of the right for entities to request the cancellation of a national social insurance unit code

Entities with budgetary ties or their supervising agencies may proactively request the cancellation of a tax identification number using the form issued with this Circular; the Financial Authority must process the request within 2 working days and clearly state the reasons if there is insufficient grounds. Regarding the deactivation of codes based on the results of the annual review, the Finance Authority must notify the entity and the competent authority in advance; and may only proceed with deactivation after 15 working days if no response is received, to avoid mistakenly deactivating codes for ODA projects, projects behind schedule for which funds have not yet been allocated, or units that have recently been reorganized following a restructuring of their organizational structure.

Add provisions for handling registration codes during organizational restructuring

The Circular adds a separate article regulating the handling of national public sector unit codes in four cases—division, separation, merger, and consolidation of units—in accordance with the Accounting Law; it adds provisions for transferring the authority to manage unit codes when changes occur due to organizational restructuring, adjustments to the management hierarchy, or when a code was issued by an unauthorized financial authority; and it adds provisions for handling investment projects where the investor has changed.

Delegation of Authority to Receive and Enter Applications at the Commune Level

The Department of Finance is authorized to delegate to specialized agencies under the commune-level People’s Committee the authority to receive and enter registration documents for identification numbers related to tasks and investment projects funded by the commune budget. The time at which the specialized agency at the commune level receives the documents is deemed to be the time of receipt by the Department of Finance; the commune level is responsible for the completeness and accuracy of the entered data; the Department of Finance verifies, cross-checks, and issues the registration code.

Addition of a mechanism for handling incidents and ensuring data security

The Circular stipulates the obligation to announce the start and end times of an incident; the duration of a publicly announced incident is not counted toward the deadline for supplementing documents or the deadline for issuing codes; during an incident, the submitting entity must use the backup method, and documents submitted online remain valid. It also adds provisions regarding operation logs, data retention periods, the scope of data access by civil servants, and the grounds for providing and sharing data externally.

A backup mechanism for the registration number range and standardization of management indicators have been added

The National Public Finance Unit Code is divided into an identifier component and management indicators. When the sequential number range is exhausted, the character “X1” is used as a Latin uppercase letter from A to Z, thereby completely resolving limitations on the scale of code issuance. A portion of the code range with N = 2 is reserved for establishing the Budget Organization Code and the Territory-wide Budget Code, preventing code duplication during sequential assignment.

Standardization of the Form System

Appendices have been restructured by task type, investment project, and phase, replacing the previous general form system; additional forms have been included for investment preparation tasks, planning tasks, ODA projects, PPP projects, and other public investment projects, along with the corresponding certificates and the form for requesting the assignment of a budget unit code.

Standardization Based on the Two-Tier Local Government Model

All regulations related to the district level have been reviewed and repealed; the local budget now consists solely of the provincial-level budget and the commune-level budget. The terms “same level” and “equivalent level,” which no longer clearly identify the relevant entities since the State Treasury is organized by region, have been replaced with “the financial agency that issues the public finance unit code” and “the State Treasury where the unit maintains its transaction account.”