Accounting and Medical Record Retention Under Vietnamese Law

Retaining accounting records and medical records is a legal obligation for businesses and healthcare facilities in Vietnam, with retention periods set separately for each type of document: accounting records carry minimum terms of 5 years, 10 years or permanent retention under the Law on Accounting 2015 and Decree 174/2016/ND-CP; medical records carry terms of 10, 20 or 30 years under Circular 33/2025/TT-BYT, effective 01/07/2025. The two groups fall under different bodies of law, with distinct requirements for confidentiality, access rights and conditions of use, so they cannot be managed under a single process. For ordinary administrative paperwork that is no longer consulted daily, a business can free up office space with MyStorage self-storage in Ho Chi Minh City.

This article is based on legislation in force as of 2027, including Consolidated Document on the Law on Accounting 41/VBHN-VPQH dated 16/03/2026, Decree 174/2016/ND-CP, the Law on Medical Examination and Treatment 15/2023/QH15 and Circular 33/2025/TT-BYT. It is for orientation only and does not replace professional legal advice. Before setting a retention period or destroying any document, an organisation should check directly against the legislation currently in force.

1. Why Records Must Be Retained Correctly

Retaining accounting records and medical records correctly helps businesses and healthcare facilities, including those using outsourced document storage services, ensure legal validity, retrievability and continuity of operations. Each type of document serves a different purpose and falls under its own body of law, so the same retention process cannot be applied to both.

The Role of Accounting Record Retention

Accounting records are the legal foundation of a company's entire financial system. Keeping them complete and systematic directly supports core functions:

• They are the basis for bookkeeping, preparing financial statements and answering tax authorities, auditors and financial inspectors.
• They support tax finalisation, internal control and the resolution of commercial contract disputes.
• They reduce the risk of losing, distorting or being unable to reconcile past financial figures when an authority requests the file.
• Under Article 41 of the Law on Accounting 2015 (consolidated in document 41/VBHN-VPQH of 2026), an accounting unit is responsible for retaining accounting documents completely and safely for the prescribed period and handing them to state archives when due.

The Role of Medical Record Retention

A medical record is not only a clinical document but also a safeguard for both the patient and the facility. Its specific legal and professional roles include:

• Recording the full course of admission, examination, diagnosis, treatment and care, supporting continuity of treatment and clinical quality review.
• Serving as the basis for resolving complaints, medical disputes, occupational accidents, traffic accidents and other legal requirements.
• Protecting the patient's privacy and sensitive health information under Article 69 of the Law on Medical Examination and Treatment 2023.
• Supporting scientific research, health statistics and public health policy planning.

Why One Retention Process Cannot Cover Both

This is the key point many organisations overlook when building a records management system. The fundamental differences are:

2. Accounting Record Retention Periods Under Current Law

Under Decree 174/2016/ND-CP guiding the Law on Accounting, accounting documents fall into three retention groups: minimum 5 years, minimum 10 years and permanent. Which group applies depends on the document's function in the accounting process, not on what it is called.

Documents Retained for at Least 5 Years

This group serves management and administration but is not used directly for bookkeeping or financial statements. Even with a shorter term, this group still needs storage conditions that prevent damp and mould like any other paper document. The 5-year term applies to:

• Accounting documents not used directly for bookkeeping and financial statements, such as copies of receipts, payment vouchers, goods received notes and goods issued notes kept by operating departments rather than by accounting.
• Documents supporting the unit's management and administration with no bookkeeping or reporting function.
• Documents kept outside the accounting department but related to economic and financial transactions.

Documents Retained for at Least 10 Years

This is the most important group in the accounting system. The 10-year term is mandatory for:

• Accounting documents used directly for bookkeeping and financial statements, including all receipts, payment vouchers, goods received and issued notes held by accounting, VAT invoices, acceptance minutes and tax payment receipts.
• Detailed ledgers, general ledgers, account ledgers and voucher journals.
• Monthly, quarterly and annual financial statements; budget settlement reports (for units using the state budget).
• Files on liquidation and sale of fixed assets, periodic asset stocktaking and valuation files.
• Settlement files for completed construction works.

Documents Retained Permanently

Some accounting documents carry special economic, historical, security or defence significance and must be kept with no end date:

• Accounting documents of historical value, significant for the economy, security and national defence as assessed by the competent authority.
• Certain state budget settlement files and files on particularly important projects created and held by state accounting units.
• Classifying a document as permanent requires a decision by the competent level; it does not happen automatically.

When the Retention Period Starts

Fixing the start date matters, so that files are neither destroyed too early nor left unprocessed long after expiry:

• For most accounting documents and ledgers: from the end of the annual accounting period (usually 31/12 of the financial year).
• For documents relating to completed tasks: from the date the related accounting work ends.
• An accounting unit must place documents into archive within 12 months of the end of the annual accounting period or the end of the accounting work.
• For investment project accounting documents, the start date may differ and the corresponding rules must be checked.

3. Medical Record Retention Under Circular 33/2025/TT-BYT

From 01/07/2025, Circular 33/2025/TT-BYT replaced Circular 53/2017/TT-BYT and became the binding legal basis for medical record retention periods at all examination and treatment facilities. Facilities should check the full list in the Appendix to the circular rather than applying one blanket period to every type of record.

Circular 53/2017/TT-BYT ceased to have effect on 01/07/2025 and is no longer a valid legal basis. Any medical record retention table based on it is out of date. Facilities should use Circular 33/2025/TT-BYT as the single reference.

Retention Periods for Typical Groups of Medical Records

Circular 33/2025/TT-BYT sets retention periods by specific record type. The table below cites some typical groups as an illustration and does not replace the full list in the Appendix:

Note: this table cites a few typical groups only. Facilities should consult the full Appendix to Circular 33/2025/TT-BYT to determine the exact period for each specific record type.

What a Medical Record Contains

Under current rules, a medical record is the set of documents recording the whole course of care. Mandatory components include:

• Identification and administrative information: full name, date of birth, address, ID or citizen identification number, health insurance details.
• Clinical examination results, laboratory tests, diagnostic imaging and functional assessment results.
• Treatment orders, prescriptions, treatment progress and daily monitoring.
• Surgery and procedure records, nursing care sheets and discharge summaries.
• Summary record or discharge certificate in the form prescribed by the Ministry of Health.

Confidentiality and Access Rights

Medical records contain personal health data, classified as sensitive data under Decree 13/2023/ND-CP on personal data protection. Under Article 69 of the Law on Medical Examination and Treatment 2023, the mandatory confidentiality principles are:

• Medical records must be kept confidential; a patient's health information must not be disclosed to unauthorised third parties.
• Patients and their legal representatives may read, view, copy and take notes from the record following the prescribed procedure.
• Investigation, prosecution, trial, health inspection bodies and social insurance organisations may access records within their remit and following due legal process.
• Facilities must keep a register of lending, copying and use of medical records to ensure traceability.

4. Building a Safe and Efficient Records System

An effective system does more than meet retention periods: it must preserve the integrity of documents, allow quick retrieval and control access tightly. For electronic records, add requirements for authenticity, backup and data security throughout the retention period.

Standardised Classification and Indexing

The first and most important step is classifying documents by consistent criteria:

• Classify by function (accounting, administration, HR, contracts) and by year, combined with a split by department or responsible unit.
• Assign a unique file code recording the sequence number, the date retention started, the end of the retention period and the confidentiality level.
• Keep an electronic index tracking files approaching expiry so you can act in time (extend, destroy under the rules, or transfer to state archives).
• Separate ordinary files from files with special confidentiality requirements, such as medical records, both physically and logically.

Procedure for Paper Accounting Records

Paper records need a standard procedure from intake checks through to formal storage:

1. Check that each document is complete and formally valid (signatures, seals and dates as prescribed).
2. Reconcile documents against ledgers, financial statements and related papers to catch discrepancies before filing.
3. Arrange by financial year, transaction type or account; number the pages consecutively within each bundle.
4. Bind each bundle in a hard cover labelled with its name, period and classification code; create a bundle index.
5. Set aside a storage area with controlled access, sturdy shelving, damp protection and fire safety equipment.
6. Record every request to borrow, copy or return a file on a standard form.

Procedure for Paper Medical Records

Medical records need a stricter procedure because of their confidentiality and longer retention:

1. Complete the record immediately after the treatment episode ends, with the prescribed components, content and authorised signatures.
2. Check that all components are present, that patient identification is correct and that documents within the record are consistent.
3. Classify by record group and corresponding retention period under Circular 33/2025/TT-BYT; label the retention term clearly.
4. Store in a dedicated area under strict control, with security locks, camera surveillance and suitable fire protection.
5. Maintain an access log recording every removal, return and copy with the reason and the authority given.

Electronic Records and Digitisation

Electronic storage is becoming inevitable, but not every form of digitisation carries the same legal weight as paper:

• Two different things: a document created electronically from the outset (with a digital signature as prescribed) and a paper document scanned to PDF are legally distinct. Scanning paper does not automatically allow you to destroy the original.
• Mandatory technical requirements: electronic records must ensure integrity (no alteration after signing), authenticity (an electronic or digital signature under the Law on Electronic Transactions 2023) and retrievability throughout the retention period.
• Electronic medical records: facilities deploying them should also check the requirements in Circular 13/2025/TT-BYT on technical conditions, access rights and backup methods.
• Permissions and control: the system must set access rights by job role, log every read and edit, and provide periodic backups and recovery in case of incident.

5. Legal Points When Renting External Storage

Many organisations consider renting outside storage to solve a shortage of space for paper files. However, moving files off site does not transfer legal responsibility, and not every type of record suits this model.

Criteria for Choosing an External Store

Before signing with any provider, assess these criteria carefully:

• Security control: continuous camera surveillance, access control by card or personal PIN, guards on duty, and no access for unauthorised third parties to the storage area.
• Physical conditions: damp protection (humidity kept below 60%, following how to keep paper documents free of mould), ventilation, isolation from heat sources, no sign of water ingress, and measures against insects and rodents.
• Fire safety: automatic fire alarms, compliant extinguishers and an evacuation plan inspected periodically.
• Records management: coding, numbered boxes, an electronic index allowing remote lookup, and the ability to produce a file within the committed time.
• A clear contract: terms setting out each party's responsibility for loss, damage, fire or data breach; compensation levels and a complaints mechanism.

Should You Store Accounting Records Off Site?

For paper accounting records, external storage is worth considering under specific conditions:

• Suitable only for completed files that are rarely consulted, typically from accounting periods closed 2 to 3 years or more ago, which makes them a good fit for a dedicated document storage facility.
• The company still retains control and must be able to produce files within a reasonable time when the tax authority, auditors or inspectors ask.
• Before handover, review the list of documents transferred, the retention period of each type, and who is responsible for notifying and returning them when action is due.
• The storage site must be geographically convenient enough to produce files at short notice for a competent authority.

Should You Store Medical Records Off Site?

This needs far more caution than accounting records:

• Not a default option: medical records contain personal health data classified as sensitive under Decree 13/2023/ND-CP, requiring confidentiality, access control and legal responsibility beyond the scope of ordinary storage.
• If you do consider it: the facility must assess the provider's information security capability rigorously, sign a full non-disclosure agreement, retain legal responsibility and keep control over access to the records.
• No substitute for a specialist system: ordinary storage does not replace a dedicated medical records system meeting healthcare legal requirements. This is not a category of document to place in ordinary self-storage.

Self-Storage for Ordinary Business Documents

For businesses, offices and organisations that need to free up office space by storing ordinary administrative documents, closed contract files, old HR files or internal papers outside the sensitive categories, personal self-storage offers a flexible option worth considering.

MyStorage provides units with temperature-controlled storage, humidity control, closed-circuit security and personal access codes, suitable for ordinary paper files that need a stable environment. To be clear, though: MyStorage is an ordinary physical storage solution and is not marketed as a legally certified accounting records depository or a medical records store under healthcare regulations, unless the specific conditions required are met and confirmed.

Not sure how many cubic metres your files need? Use the AI estimator below:

6. Reference Prices for Records Storage

For businesses and organisations looking to expand space for ordinary paper documents, the table below gives reference costs in the Ho Chi Minh City market in 2027:

Note: prices are indicative for the Ho Chi Minh City market in 2027. Actual costs depend on volume, rental term and specific service requirements. For ordinary administrative documents you can check the exact price for your size with the tool below; for accounting records and specialist medical files, contact a provider with the professional capability and legal commitments required.

7. Correct Retention Is the Foundation of Compliance

Retaining accounting and medical records is not mere administration but a legal duty that protects the organisation, its staff, its patients and other parties. The fundamental differences in retention period, confidentiality and access conditions mean each organisation must build a separate classification and management system suited to its operations and the specialist law in force.

For accounting records, the starting point is matching each document type against Decree 174/2016/ND-CP to establish whether the term is 5 years, 10 years or permanent. For medical records, the only valid basis is Circular 33/2025/TT-BYT, which replaced the earlier rules on 01/07/2025. For both groups, electronic storage must sit within the legal framework for electronic transactions and personal data protection.

For offices and businesses needing space for ordinary administrative documents in a safe, controlled environment, business storage is a flexible, lower-cost alternative to expanding the office. See the MyStorage locations in Ho Chi Minh City to pick the nearest site, or contact MyStorage for advice on the right solution for each group of records.

8. Frequently Asked Questions About Record Retention