Ms. Dung was recruited and appointed to the accountant position by the Director of the Department of Internal Affairs since 2004.

According to Appendix VII of Circular No. 12/2022/TT-BNV dated December 30, 2022 by the Minister of Internal Affairs guiding job positions for accountant positions, educational requirements state: "Graduated from university or higher education with majors or disciplines relevant to the field of work"; based on Clause 4, Article 7 of Circular No. 29/2022/TT-BTC dated June 3, 2022 by the Minister of Finance, the educational and training requirements for accountants are "holding a university degree or higher in accounting, auditing, or finance".

Ms. Dung only holds a Bachelor's degree in Business Administration and does not possess a Bachelor's degree in Accounting, thus not meeting the accountant standards.

However, according to Clause 1, Article 25 of Circular No. 29/2022/TT-BTC, in cases where civil servants do not hold a specialized degree in accounting but were authorized to be appointed to the accountant position before January 1, 2014, they are still allowed to continue working as accountants according to the provisions in Article 7, Clause 18 of Decree No. 174/2016/NĐ-CP dated December 30, 2016 by the Government and can retain their appointed position.

According to Clause 3, Article 25 of Circular No. 29/2022/TT-BTC, for civil servants who were appointed to the accountant position before the effective date of this Circular, they are considered to meet the professional standards and requirements for the accountant profession.

Ms. Dung inquired whether, based on legal regulations, she can continue to work as an accountant at the public sector entity.

The Ministry of Finance responded as follows:

Based on the information provided by Ms. Truong Dung, she was appointed to the accountant position by the Director of the Department of Internal Affairs since 2004.

Clause 7, Article 18 of Decree No. 174/2016/NĐ-CP stipulates certain provisions of the Accounting Law as follows:

"7. For individuals without a specialized degree in finance, accounting, or auditing but were authorized to be appointed to the accountant or chief accountant position at state accounting units before January 1, 2014, they may continue to work as accountants but cannot be appointed as chief accountants until they meet all standards and conditions required for chief accountants, except for those who are still appointed as chief accountants according to the provisions in Clause 6 of this Article."

Based on Clause 3, Article 25 of Circular No. 29/2022/TT-BTC issued by the Minister of Finance concerning codes, professional standards, qualifications, and salary rankings for civil servants in specialized fields such as accounting, taxation, customs, and reserves:

"In cases where civil servants do not hold a specialized degree in finance, accounting, or auditing but were authorized to be appointed to the accountant or chief accountant position before January 1, 2014, they may continue to work as accountants according to the provisions in Article 7, Clause 18 of Decree No. 174/2016/NĐ-CP dated December 30, 2016 by the Government and retain the appointed position; in cases of promotion to higher ranks, they must satisfy the conditions stipulated in this Circular."

Based on the aforementioned legal provisions, Ms. Truong Dung meets the requirements to continue working as an accountant at the public sector entity.