Reviewing regulations to ensure legal consistency
According to the Ministry of Finance, the development of the new Circular stems from the need to improve institutions, reform administrative procedures, and enhance the effectiveness and efficiency of state management in the field of public investment.
In recent years, the Government and the Prime Minister have issued numerous directives requiring ministries and sectors to review and amend outdated regulations to remove institutional bottlenecks, strengthen decentralisation and delegation of authority, and unlock resources for development. Resolution No. 01/NQ-CP of 2026 sets out the task of further improving the legal framework and enhancing the investment and business environment, while Resolution No. 122/NQ-CP calls for accelerating the issuance of implementing regulations to ensure consistency and timeliness.
In addition, Decree No. 193/2026/ND-CP on the settlement of investment capital for projects, together with draft decrees guiding the implementation of the 2025 Construction Law, assigns the Ministry of Finance the responsibility for providing detailed regulations on the revenue and expenditure mechanisms applicable to project owners and project management boards using state budget funds. Changes to the financial autonomy mechanism of public non-business units under Decree No. 111/2025/ND-CP, which amends and supplements Decree No. 60/2021/ND-CP, have also necessitated updating relevant guiding documents.
According to the Ministry of Finance, Circular No. 70/2024/TT-BTC provides a legal foundation for the financial management of project management boards. However, practical application indicates several provisions are no longer fully aligned with practical requirements.
In particular, regulations concerning the use of funds lack sufficient flexibility for units to exercise autonomy and accountability. Guidance is also lacking for project management activities financed through other lawful revenue sources as stipulated under public investment legislation for state agencies. Certain provisions are no longer compatible with newly issued legal regulations, especially those relating to district-level administration and the functions of the State Treasury system.
Furthermore, the current system of forms remains relatively extensive, with some indicators lacking clarity. Certain provisions are also overlapping or insufficiently specific, hindering implementation at the operational level.
On this basis, the Ministry of Finance considers the issuance of a new Circular necessary to address emerging shortcomings while ensuring consistency with existing regulations governing the state budget, public investment, construction, and financial autonomy mechanisms.
Expanding financial autonomy in project management
The draft Circular aims to reduce overly detailed procedural provisions while granting project owners and project management boards greater flexibility in carrying out their responsibilities.
Under the draft, the scope of application includes project owners, project management boards established by project owners, project management boards operating as public non-business units, and related organisations and individuals. The regulations are designed to cover the entire project financial management process, from determining revenue sources and organising accounting activities to budget preparation, cost management, and annual financial settlement.
One of the most notable directions of this revision is the strengthening of autonomy and accountability for project management boards. The draft proposes removing the separate provisions on fund utilisation currently in force. This new approach is intended to enable units to take greater initiative in organising operations and managing financial resources, while linking expanded authority with stronger accountability requirements.
At the same time, numerous provisions have been reviewed to ensure compatibility with the current legal framework. Regulations relating to district-level administration have been removed in line with the restructuring of local government institutions. Several concepts and terms have also been revised to align with the current functions and responsibilities of the State Treasury system.
The draft further expands guidance for project owners and project management boards that utilise other lawful revenue sources in accordance with public investment legislation. Although these entities are not directly subject to the Circular, they are encouraged to apply its procedures for budget preparation, appraisal, and financial settlement to ensure consistency in project financial management.
In addition to streamlining existing provisions, the draft introduces several new regulations arising from practical experience. These include guidance on identifying additional revenue sources related to compensation, support, and resettlement activities, as well as provisions governing investment monitoring and evaluation costs. In cases where independent consultants are hired to carry out investment monitoring and evaluation tasks, the associated costs will be accounted for separately under the category of external consultancy expenses in accordance with the regulations.
The Ministry of Finance stated that the new Circular ensures consistency with the current legal framework while addressing issues encountered during implementation. The proposed regulations also aim to create more favourable conditions for project owners and project management boards in the management of project finances.