Investment reporting obligations in Vietnam now run on two parallel tracks for any company that implements an investment project. The first is the project implementation report under Article 47 of the Law on Investment No. 143/2025/QH15 and Article 94 of Decree 96/2026/ND-CP: a quarterly report before the 10th of the first month of the next quarter and an annual report before 31 March of the following year, on Forms I.3.1 and I.3.2 of Circular 55/2026/TT-BTC, filed only on the National Investment Information System. The second is the investment supervision and evaluation report under Decree 19/2026/ND-CP: a quarterly investment report, half-year (before 10 July) and annual (before 10 February) reports plus a report before any project adjustment, on Forms No. 13 and 16 of Circular 44/2026/TT-BTC, filed on the Ministry of Finance's supervision and evaluation system.
This guide to investment reporting obligations in Vietnam covers projects that do not use state capital, which Decree 19/2026 calls "projects using other capital" (Article 3(18)). That is the normal position of a foreign-invested company. Public investment, PPP projects and community supervision follow separate rules. If you are reading older guidance, note that the previous framework (Article 72 of the 2020 Investment Law, Decree 31/2021/ND-CP, Decree 29/2021/ND-CP, the A.III forms of Circular 03/2021/TT-BKHDT and the forms of Circular 05/2023/TT-BKHDT) is no longer in force.
Investment reporting obligations in Vietnam at a glance#
| Report | Deadline | Form | Recipient and channel | Legal basis |
|---|---|---|---|---|
| Quarterly project implementation report | Before the 10th of the first month of the next quarter | Form I.3.1, Circular 55/2026 | Investment registration authority and local statistics office; National Investment Information System only | Law on Investment Art. 47(2)(a); Decree 96 Art. 94(1), (2) and Art. 96(1)(a) |
| Annual project implementation report | Before 31 March of the following year | Form I.3.2, Circular 55/2026 | Same | Decree 96 Art. 94(3) |
| Quarterly supervision and evaluation report | Before the 10th of the first month of the next quarter | Form No. 13, Circular 44/2026 | Investment registration authority and the provincial supervision focal point; supervision and evaluation system | Decree 19 Art. 94(8)(a1) and (11)(a), added and amended by Decree 96 Art. 99(6)(c) and (d) |
| Half-year supervision and evaluation report | Before 10 July (data 1 January to 30 June) | Form No. 13 | Same | Decree 19 Art. 94(8)(a) and (11)(a) |
| Annual supervision and evaluation report | Before 10 February of the following year | Form No. 13 | Same | Same |
| Report before a project adjustment | Before submitting the adjustment | Form No. 16 | Same | Decree 19 Art. 94(8)(b) and (11)(a) |
| Closing evaluation report | At project completion, for projects that required investment policy approval | Form No. 17 | Same | Decree 19 Art. 94(8)(c) and Art. 68(1)(a) |
| Ad hoc report | On request | As requested | Requesting authority | Law on Investment Art. 47(4) |
"Before the 10th" means the 9th is the last day. The investment registration authority is the provincial Department of Finance for projects outside industrial parks, export processing zones, high-tech zones and economic zones, and the management board of the zone for projects inside one (Article 27(1) and (2) of the Law on Investment).
Who is subject to investment reporting obligations in Vietnam#
Article 47 places the obligation on "investors and economic organisations implementing investment projects" (Article 47(1)(c)). Decree 19/2026 places the supervision and evaluation duty on investors in projects using other capital (Article 90(2) and Article 94(8)). In practice:
- A foreign-invested company with a project under an Investment Registration Certificate (IRC): files under both regimes, one form per project (instruction on Forms I.3.1 and I.3.2). See the handbook on the IRC.
- A business cooperation contract (BCC): Form I.3.1 has a field for "project name / BCC contract name", so BCC projects report too. See business cooperation contracts in Vietnam.
- A company in which foreign investors hold 50% or less: it follows the procedures for domestic investors (Article 20(2)), so its new projects do not need an IRC (Article 26(2)(b)). For a project without an IRC, the investor reports to the registration authority before implementing it (Article 47(5)), using Form I.3.3. In our reading, Article 47(2)(a) does not carve these projects out of quarterly and annual reporting, and Form I.3.1 itself tells domestic-investor projects to report in VND millions.
- A foreign investor that only buys capital or shares: a capital contribution or share purchase is not an IRC procedure (Article 26(2)(c)). In our reading, buying into a company does not by itself create a project for the buyer to report; the target company reports its own projects. See buying shares in a Vietnamese company.
- A representative office: it has no investment project and is outside both regimes. It sends its own annual activity report to the licensing authority before 30 January (Article 32(1) of Decree 07/2016/ND-CP); see representative office in Vietnam.
Project implementation report: Forms I.3.1 and I.3.2#
Circular 55/2026/TT-BTC of 15 May 2026 took effect on signing and replaced Circulars 03/2021/TT-BKHDT, 25/2023/TT-BKHDT and 06/2025/TT-BKHDT (Article 5(1)). The A.III.1 and A.III.2 forms that many compliance calendars still mention are gone.
The quarterly Form I.3.1 has three parts: general project and company data; figures, each shown for the quarter, year to date and cumulatively since the IRC; and difficulties and requests. The figures cover implemented investment capital split into each investor's contribution (cash, machinery, other assets), loans (domestic, from the foreign parent, other foreign) and reinvested profit; net revenue; exports and imports; Vietnamese and foreign headcount; energy use; taxes and budget payments; and land and water surface used. Amounts are in USD and loans are reported net (drawdowns less repayments in the period). The annual Form I.3.2 adds average monthly employee income, after-tax profit, research and development spending, environmental spending and the origin of technology used, matching the list in Article 94(3) of Decree 96.
Keep the annual figures consistent with the audited financial statements and tax finalisation. The Ministry of Finance itself compiles the annual financial statements of foreign-invested companies to report on trade, finances and budget payments (Article 93(3)(a) of Decree 96).
Investment supervision and evaluation report: Forms No. 13, 16 and 17#
Decree 19/2026/ND-CP of 14 January 2026 (Official Gazette No. 65 of 29 January 2026) took effect on signing and replaced Decree 29/2021/ND-CP (Article 99(1) and (2)). It is not limited to state money: investors in "projects using other capital" must prepare supervision and evaluation reports and keep the system updated (Article 90(2) and Article 94(8)). Decree 96 then amended it in three ways that matter to investors: it added a quarterly project implementation report to the list of reports for projects using other capital, added a quarterly deadline, and replaced the requirement for a "Government special-use" digital signature with a digital signature "as prescribed" (Article 99(6)(c), (d) and Article 99(7) of Decree 96). The forms are set by the Ministry of Finance (Article 94(13) of Decree 19), now in Circular 44/2026/TT-BTC of 22 April 2026, which replaced Circular 05/2023/TT-BKHDT.
What the investor monitors and reports is listed in Article 64 of Decree 19: project and objective progress, capital contribution progress, business results, labour, budget payments, R&D, financial position, environmental protection, land use, compliance with the IRC and any investment policy approval, conditions for conditional business lines, and investment incentives.
Form No. 13 (supervision and evaluation of project implementation, for investors, prepared per quarter) has four sections: project information (reported once, in the first period after construction starts or after an adjustment that changes the data), implementation (appendix 13.1.2a, which expressly includes FDI companies), operation, including a self-assessment of compliance with land, environment, fire safety, business conditions and the IRC, and requests to the authorities. Money figures in Form No. 13 are in VND millions, not USD as in Form I.3.1.
Form No. 16 is filed before a project adjustment and covers implementation to date, what is being adjusted and why, and a reassessment of the project's efficiency. Where a pre-adjustment review is mandatory, the authority may only amend the IRC after it has been carried out (Article 96(2) of Decree 19). For the amendment itself, see the IRC amendment procedure.
Form No. 17 is the closing evaluation. It is mandatory for projects that required investment policy approval (Article 68(1)(a) of Decree 19) and covers results against objectives, resources mobilised, timing and project benefits (Article 68(2)).
Investment reporting obligations in Vietnam: where the two regimes do not line up#
Three overlaps are worth knowing before you build your compliance calendar.
- The quarterly report appears in both regimes. Article 94(8)(a1) of Decree 19 refers expressly to "the quarterly report on project implementation under Article 47(2)(a) of the Law on Investment". In our reading, the quarterly investment report under Article 47 and the quarterly supervision report are the same obligation in substance, but no text yet says that filing Form I.3.1 on one system counts as filing Form No. 13 on the other.
- The half-year report falls on the same date as the Q2 report (both before 10 July). Answering a company's question of 16 July 2026, the Ministry of Finance said investors update quarterly data and prepare quarterly and annual reports on the supervision system, and that the authorities may compile the half-year data themselves (Ministry of Finance Q&A). It did not say the half-year report in Article 94(8) and (11) has been abolished.
- Two annual deadlines: 10 February for the supervision and evaluation report and 31 March for the project implementation report. If February figures are preliminary, label them as such and keep a reconciliation for any change by 31 March.
Local guidance, which is not legislation, also differs. The Lang Son Department of Finance (Official Letter 5021/STC-QLDTNNS of 9 August 2026) directs supervision reports to nghiepvugiamsatdautu.mof.gov.vn and Article 47 reports to the province's own software for non-state investment (letter). According to a 13 May 2026 notice on the website of the Ho Chi Minh City Export Processing and Industrial Zones Authority about its Official Letter 6856/BQL-DN of 12 May 2026, zone companies prepare Form No. 13 quarterly and annually, and FDI companies report investment activity online at fdi.gov.vn and also send a signed and sealed paper or scanned copy. The paper copy has some footing in Article 47(3) of the Law on Investment ("in writing and through the System"), while Decree 19 says reporting on the supervision system replaces paper reports (Article 95(2)(a)).
Our recommendation: until the Ministry of Finance issues guidance merging the two, file under both regimes by the earlier deadline, keep the quarterly figures in Form I.3.1 and Form No. 13 consistent (convert USD to VND at one documented rate), and ask your investment registration authority in writing which channel it expects and whether it wants a paper copy. A written answer is useful evidence if a late-filing question ever comes up.
Portals, accounts and digital signatures#
The supervision and evaluation information system is run centrally by the Ministry of Finance (Article 95(1) of Decree 19). Accounts are registered online at taikhoan.mof.gov.vn with details of the account manager and the organisation (Article 95(3)(c)). The initial password must be changed within one day, and when the responsible person changes, the successor must change the password and the account manager details (Article 95(3)(dd)). Reports are signed and sent with a digital signature (Article 95(2)(d), as amended by Article 99(7) of Decree 96).
The National Investment Information System includes a component for foreign investment into Vietnam (Article 46(1)(b) of the Law on Investment). Project companies receive an account for periodic reporting (Article 97(6) of Decree 96) and file online (Article 96(1)(a)); Forms I.3.1 and I.3.2 state that the report "is made only on the National Investment Information System", and a footnote to Form I.1.9 gives its address as fdi.mof.gov.vn. Project data held there is the original record with legal effect (Article 46(4) of the Law on Investment).
Meeting the investment reporting obligations in Vietnam therefore means two accounts on two systems: give one person responsibility for both, update the account manager when staff change and check the expiry date of the digital signature.
Ad hoc "status to date" reports in amendment and transfer files#
Beyond the periodic investment reporting obligations in Vietnam, many investment procedures require a report on project implementation up to the filing date. Circular 55/2026 uses one form, Form I.1.9, for: an IRC for a project already under way (Article 39(2) of Decree 96), project adjustments (Article 52(1)(b) and Article 56(2)), project transfers (Article 57(5)(b)), division, separation or merger of projects (Article 59(3)(a)), contributing or cooperating with the project's land use rights (Article 61(3)(b) and Article 62(3)(b)) and extending the project term (Article 64(2)(a)).
Form I.1.9 asks for each investor's capital contribution progress, other funding, construction progress, and whether the company has registered its project reporting account on the Ministry of Finance website. The business figures run from the last report filed on the National Investment Information System. An amendment or transfer file therefore shows the authority how far the company is up to date with its project reports. A buyer of a project should ask for copies of the reports filed during legal due diligence before an investment project transfer.
Penalties for breaching investment reporting obligations in Vietnam#
Decree 19 refers penalties to the rules on administrative penalties in planning and investment (Article 97(2)), currently Decree 122/2021/ND-CP, whose Article 15 covers investment information and reporting. Decree 288/2026/ND-CP amended Decree 122 but not Article 15. Press reports in June 2026 said the Ministry of Finance had submitted a draft decree to replace Decree 122; as of 12 October 2026 we have not seen a replacement issued.
| Violation | Fine | Legal basis |
|---|---|---|
| Supervision and evaluation report late or incomplete; failure to file periodic supervision and evaluation reports | VND 20 to 30 million | Decree 122/2021 Art. 15(1) |
| Failure to comply with investment activity reporting or late reporting; untruthful or inaccurate reporting | VND 30 to 50 million | Decree 122/2021 Art. 15(2) |
These are the fines for organisations; individuals pay half (Article 4(2) of Decree 122/2021). In our reading, skipping the Article 47 report ("investment activity reporting") falls under Article 15(2), the higher band. The authority will also order the missing reports to be filed (Article 15(3)). The limitation period is one year, but the Article 15(2) violations are treated as continuing, so it runs from the date of detection (Article 5(1) and (2)). Beyond fines, the registration authority monitors and inspects compliance with reporting, including statistical reporting (Article 65(1)(a) and (2)(d) of Decree 19), and inspects each project at least once (Article 63(2)). The reprimand and warning regime for missing two or three reporting periods (Article 97(3) of Decree 19) applies only to public investment and state-capital projects.
Reporting calendar to July 2027#
Applied to the coming year, the investment reporting obligations in Vietnam give the dates below. The Q3/2026 reports (Form I.3.1 and Form No. 13) were due before 10 October 2026. If yours is outstanding, file now: it will still be late under Article 15, but it ends the failure to report.
| Last day | What to file |
|---|---|
| 9 January 2027 | Q4/2026: Form I.3.1 and Form No. 13 |
| 9 February 2027 | 2026 annual supervision and evaluation report: Form No. 13 |
| 30 March 2027 | 2026 annual project implementation report: Form I.3.2 |
| 9 April 2027 | Q1/2027: Form I.3.1 and Form No. 13 |
| 9 July 2027 | Q2/2027 and the first-half 2027 supervision report |
| Before filing a project adjustment | Form No. 16 |
9 January 2027 is a Saturday and 9 February 2027 is the fourth day of the Lunar New Year (which starts on 6 February 2027). The reporting rules say nothing about moving a deadline that falls on a day off, so file before these dates.
Financial statements, tax filings and labour reports are separate obligations and do not replace the investment reporting obligations in Vietnam described here. See also the handbook on the corporate legal department and what is an FDI company.
LexData can run this calendar for you, prepare Forms I.3.1, I.3.2, No. 13 and No. 16 and reconcile them with your financial statements under a legal retainer; when a project needs changing, the pre-adjustment report is prepared together with the IRC amendment file.
