Critical changes regarding investment supervision and evaluation reporting obligations under new regulations effective from march 31, 2026

The legal framework for investment in Vietnam is undergoing significant transitions with the implementation of the Law on Investment 2025 and its latest guiding documents. Notably, the reporting and supervision regime for investment projects has been tightened and fully digitalized. To assist Investors using other capital sources (non-state budget capital) in proactively managing administrative risks and maintaining compliance, this article provides a detailed summary of mandatory reports, submission deadlines, and critical legal notes. 

1. Investment Reporting Regime in Vietnam 

Pursuant to Point c, Clause 1, Article 47 of the Law on Investment No. 143/2025/QH15 (“Law on Investment 2025”), Investors and Economic Organizations Implementing Projects are subject to the mandatory investment reporting regime. Accordingly, Point a, Clause 2, Article 47 of the Law on Investment 2025 dictates that periodic reports by Investors and Economic Organizations Implementing Projects must be submitted quarterly and annually to the Investment Registration Authority and the local Statistical Authority regarding the project implementation status. The reporting content encompasses core indicators, including implemented investment capital, business performance results, labor information, state budget contributions, research and development (R&D) investments, environmental treatment and protection, and sector-specific indicators. 

Notably, a major highlight under Articles 10 and 11 of Circular No. 44/2026/TT-BTC regulating forms for investment supervision and evaluation reports; the online reporting regime; and the management and operation of the investment supervision and evaluation information system (“Circular No. 44/2026/TT-BTC”) is the comprehensive digitalization of management. Under these provisions, traditional hard-copy reporting has been officially replaced by online declarations directly on the Investment Supervision and Evaluation Information System. Consequently, enterprises are required to proactively register, open, and manage their accounts on the System to fulfill their data update obligations accurately and timely. 

2. Mandatory Investment Supervision and Evaluation Reports 

Pursuant to Clause 8, Article 94 of Decree No. 19/2026/ND-CP on the sequence and procedures for evaluating national important projects and investment supervision and evaluation (“Decree 19/2026/ND-CP”), investors of projects using other capital sources must prepare and submit the following reports to the Investment Registration Authority and the local focal agency in charge of investment supervision and evaluation where the project is implemented: 

  • Quarterly report on the investment project implementation status. 
  • Periodic supervision and evaluation reports for the 6-month period and the whole year: Form No. 13 of Circular No. 44/2026/TT-BTC shall be utilized to declare data regarding both the implementation status and the exploitation/operation of the investment project. 
  • Supervision and evaluation report prior to project adjustment: Form No. 16 of Circular No. 44/2026/TT-BTC shall be utilized to declare data before adjusting the project. At the Department of Finance of Ho Chi Minh City, when submitting an application for the amendment of the Investment Registration Certificate (IRC), in addition to the statutory documents, Investors and Economic Organizations Implementing Projects must enclose this Form No. 16 to serve as a basis for the Department’s review and processing. 
  • Terminal evaluation report: Form No. 17 of Circular No. 44/2026/TT-BTC shall be utilized to declare data upon the termination or completion of the investment project. 

3. Reporting Deadlines 

Regarding reporting deadlines, investors must strictly monitor the specific schedule to ensure accurate data declaration and mitigate legal risks arising from delays. Pursuant to Clause 11, Article 94 of Decree No. 19/2026/ND-CP (as amended and supplemented by Point d, Clause 6, Article 99 of Decree No. 96/2026/ND-CP), the deadlines for submitting investment supervision and evaluation reports are clearly delineated as follows: 

  • Quarterly reports: To be submitted prior to the 10th day of the first month of the quarter immediately following the reporting quarter; 
  • 6-month reports: To be submitted prior to July 10th of the reporting year, with data accumulated from January 1st to the end of June 30th of the reporting year; 
  • Annual reports: To be submitted prior to February 10th of the following year, with data accumulated from January 1st to the end of December 31st of the reporting year; 
  • Reports prior to project adjustment: To be submitted prior to the official submission of the application for the adjustment of the program or investment project. 

4. Legal Consequences for Non-Compliance 

Investors and Economic Organizations Implementing Projects must pay special attention to the strict administrative sanctions prescribed under Article 15 of Decree No. 122/2021/ND-CP as follows: 

Violations  Administrative Fines  Remedial Measures 
Preparing investment supervision and evaluation reports past the deadline or with insufficient contents as prescribed.  VND 20,000,000 to VND 30,000,000  Compulsory addition of missing contents in the report. 
Failing to comply with the periodic investment supervision and evaluation reporting regime as prescribed.  Compulsory compliance with the periodic investment supervision and evaluation reporting regime. 
Failing to comply with the investment reporting regime or reporting past the deadline as prescribed.  VND 30,000,000 to VND 50,000,000  Compulsory compliance with the investment reporting regime. 
Submitting untruthful or inaccurate reports on investment activities.  Not applicable. 

Date written: 20/05/2026

Disclaimers:

This article is for general information purposes only and is not intended to provide any legal advice for any particular case. The legal provisions referenced in the content are in effect at the time of publication but may have expired at the time you read the content. We therefore advise that you always consult a professional consultant before applying any content.

For issues related to the content or intellectual property rights of the article, please email cs@apolatlegal.vn.

Apolat Legal is a law firm in Vietnam with experience and capacity to provide consulting services related to Business and Investment and contact our team of lawyers in Vietnam via email info@apolatlegal.com.



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