Update on Regulations on Beneficial Ownership from 23 July 2026
The Ministry of Finance has issued Decree No. 296/2026/ND-CP dated July 23th, 2026, which amends, supplements, and tightens regulations concerning the beneficial ownership of enterprises. 1. Definition and Identification of “Beneficial Owner” A beneficial owner of an enterprise is one or more individuals who directly or indirectly ultimately own or exercise actual control over such enterprise, excluding individuals representing state capital in the enterprise. A beneficial owner is one or more individuals identified as follows: An individual who directly or indirectly, or both directly and indirectly, owns 25% or more of the charter capital or 25% or more of the total voting shares of the enterprise. An indirect beneficial owner is an individual who owns 25% or more of the charter capital or 25% or more of the total voting shares of the enterprise through organizations or other legal arrangements. Where a group of individuals who have a family relationship as pre...