Many FDI companies in Vietnam still operate from outdated compliance checklists circulating online — containing as many as three obsolete items (business license tax, form 07/PLI foreign-labor reports, Decree 13/2023 on personal data) and missing four new 2026 legal instruments. This article provides a quarterly legal compliance checklist that has been “cleaned of legal deadwood”: seven current items, updated for the 2026 framework.
Seven Items in an FDI Quarterly Compliance Checklist
1. Investment project implementation reports
- Quarterly: file before the 10th of the first month of the following quarter.
- Annual: file before 31 March of the following year.
- Basis: Article 72, Investment Law 143/2025/QH15 (effective 1/3/2026) + Decree 96/2026/ND-CP (effective 31/3/2026 — replacing Decrees 31/2021, 19/2025, 239/2025).
- Forms: Circular 55/2026/TT-BTC (effective 15/5/2026 — replacing Circular 03/2021/TT-BKHDT).
- Do not cite Investment Law 61/2020, Decree 31/2021, or Circular 03/2021 as current authority.
2. Taxes
- Quarterly provisional CIT; VAT declared monthly/quarterly; foreign contractor tax (on payments to foreign contractors).
- Basis: Law on Tax Administration 108/2025/QH15 (effective 1/7/2026); CIT: Law 67/2025/QH15 (effective 1/10/2025) + Decree 320/2025; contractor tax: Circular 20/2026/TT-BTC and Article 9 of Circular 69/2025/TT-BTC.
- Do not cite Circular 103/2014/TT-BTC on contractor tax (superseded).
3. Labor
- Labor-use reports every 6 months and annually, filed with the Department of Home Affairs (Decree 145/2020/ND-CP).
- Work permits for foreign employees: track expiry, renew/reissue in time.
- Foreign labor framework: Decree 219/2025/ND-CP (effective 7/8/2025 — replacing Decree 152/2020).
- ⚠️ Form 07/PLI was abolished from 7/8/2025 — no longer required.
4. Social, health, and unemployment insurance
- Full monthly contributions on time; review contribution bases against new regional minimum wages and 2026 ceilings.
- Basis: Decree 158/2025/ND-CP (effective 1/7/2025).
5. Environment & fire safety
- Periodic environmental protection reports; keep environmental licences valid.
- Inspect and maintain fire-safety systems; conduct fire drills as prescribed.
6. Personal data
- Review personal data processing activities; prepare/update the Data Protection Impact Assessment (DPIA) when changes occur.
- Basis: Law on Personal Data Protection 91/2025/QH15 (effective 1/1/2026).
- Do not cite Decree 13/2023/ND-CP as current authority — superseded under the new framework.
7. Transfer pricing & global minimum tax
- Prepare transfer pricing documentation (local file, master file, country-by-country report) as required.
- Basis: Decree 255/2026/ND-CP (effective 1/7/2026 — replacing Decree 132/2020).
- Global minimum tax: Resolution 107/2023/QH15.
Deadline Summary
| Item | Frequency | Deadline | Filed with |
|---|---|---|---|
| Investment project report | Quarterly / Annual | Before the 10th of the first month of next quarter / before 31 March | Investment registration authority |
| Taxes (CIT, VAT, contractor tax) | Monthly / Quarterly | Per declaration period | Tax authority |
| Labor-use report | 6-monthly / Annual | Per Decree 145/2020 | Dept. of Home Affairs |
| Foreign work permits | Per permit term | Before expiry | Dept. of Home Affairs |
| SI/HI/UI contributions | Monthly | Monthly, on time | Social insurance agency |
| Environment & fire safety | Periodic | Per licence/regulation | Competent authorities |
| Personal data (DPIA) | On change | Update when changes occur | Kept at company, filed as required |
| Transfer pricing file | Annual | With annual tax finalization | Tax authority |
Three Abolished Items: Remove Immediately
- Business license tax — abolished from 1/1/2026 (Resolution 198/2025 + Decree 362/2025). Exclude from 2026 checklists.
- Form 07/PLI foreign-labor reports — abolished from 7/8/2025 (under Decree 219/2025).
- Decree 13/2023/ND-CP on personal data protection — no longer current authority; replaced by Law 91/2025/QH15.
Sanctions for Reporting Breaches
Depending on the field, late or missing filings may trigger administrative penalties (fines, remedial orders) and, in some cases, affect tax/customs risk ratings or eligibility for investment incentives. For personal data, fines are detailed in Decree 330/2026/ND-CP.
Start-of-Quarter Review Checklist
- ☐ Was last quarter’s investment project report filed before the 10th of this quarter’s first month?
- ☐ Are quarterly tax obligations (provisional CIT, VAT, contractor tax) complete?
- ☐ Which foreign employees’ work permits expire this quarter?
- ☐ Do SI contribution bases need adjusting for new regional minimum wages?
- ☐ Any personal-data processing changes requiring a DPIA update?
- ☐ Is last year’s transfer pricing documentation complete?
- ☐ Have the three obsolete items (license tax, form 07/PLI, Decree 13/2023) been removed from internal procedures?
Disclaimer: General summary of FDI compliance obligations under the legal framework as of 14 October 2026 (Investment Law 143/2025, Decree 96/2026, Circular 55/2026, Law on Tax Administration 108/2025, Decree 219/2025, Law 91/2025, Decree 255/2026, etc.). Specific article numbers and deadlines may vary per local authority requirements; please verify against original texts before applying.
Content reviewed by the FLAW AI Legal Council — an AI council with the mindset of seasoned lawyers. This is not the opinion of a human lawyer and does not replace direct legal advice.
This article has been reviewed by the QA Council.
For a comprehensive compliance review or building an internal compliance system, please contact FLAT Law Firm.
