On July 1, 2026, the Ministry of Finance in Vietnam introduced Circular 94/2026, which replaces the previous Circular 31/2021. This new regulation transitions the tax management approach from a focus primarily on risk management to a combined strategy of compliance management alongside risk management. This shift aligns with the Tax Management Law No. 108/2025 and international best practices.

The Ministry emphasizes that the previous Circular 31 concentrated mainly on risk management through three core components: information collection and processing, compliance assessment, and risk classification. In contrast, Circular 94 expands this framework to include a distinct compliance management mechanism, which assesses and categorizes compliance levels and implements measures to enhance compliance among taxpayers.

Under the new regulations, the classification of compliance will play a crucial role in determining risk levels in tax management operations. This dual approach aims to encourage higher compliance rates while simultaneously preventing and addressing potential risks. The circular also integrates compliance management with planning for inspections, debt management, tax refunds, and electronic invoicing to improve tax management efficiency and reduce compliance costs for taxpayers.

Moreover, Circular 94 mandates the use of advanced technology, establishing a digital compliance and risk management architecture that includes risk registers and clear criteria. It expands data sources for management purposes, incorporating information from government agencies, organizations, individuals, and international data, while also leveraging big data, machine learning, and artificial intelligence for compliance assessment and risk classification.

The circular maintains a four-tier compliance structure: good compliance, average compliance, low compliance, and non-compliance. However, compliance classification will not only inform risk classification but also aid in developing strategies to enhance compliance through collaboration with relevant agencies, increased outreach, and simplification of administrative procedures.

Additionally, the circular introduces mechanisms to support taxpayers based on compliance evaluation results and risk classification. The tax authority will enhance early warning systems, compliance recommendations, and assist taxpayers in self-correcting errors to improve voluntary compliance levels. Resources for inspections will focus on cases showing signs of risk or tax law violations.

Overall, Circular 94 represents a significant modernization of Vietnam's tax management system, aiming to improve compliance and efficiency in tax administration.