This article is for reference only and does not constitute legal advice. Content reviewed by the FLAW AI Legal Council.
Short answer: No separate re-filing obligation exists. FDI companies (like all companies) established before 1 March 2026 are not required to carry out a standalone procedure just to re-declare beneficial owner (BO) information.
1. The rule: supplement at the next change filing
Companies established before 1 July 2025 that have not yet supplemented BO information do so simultaneously with their nearest enterprise registration change filing or change notification — unless the company requests earlier supplementation. The law sets no standalone deadline; the trigger is the next change filing after 1 July 2025 (Article 3.1 of Law No. 76/2025/QH15 — transition provision, effective 1 July 2025). FDI companies established before 1 March 2026 (necessarily also before 1 July 2025) follow the same rule as all companies.
2. Already declared with no changes: no re-filing
Declared BO information with no changes → no re-filing, even though the BO identification criteria were amended by Decree 296/2026/ND-CP. Per the Ministry of Finance’s official guidance: the transition provisions of Decree 296/2026 impose no obligation or deadline on companies operating before 23 July 2026; there is no 10-day review/re-filing duty.
3. Actual changes: notify the change
Where BO information actually changes, file a change notification — dossier includes the enterprise registration change notice and the BO list (plus the corresponding identification-information list where identification information changes) (Article 52.1 of Decree 168/2025/ND-CP, effective 1 July 2025).
4. Three cases to distinguish (per Ministry of Finance)
| Case | Obligation |
|---|---|
| Declared + no changes | No re-filing (even after Decree 296/2026) |
| Actual BO information change | Notify change (Art. 52.1 Decree 168/2025) |
| Established before 1/7/2025, never supplemented | Supplement at nearest change filing (Art. 3.1 Law 76/2025) |
5. Legal framework
Decree 168/2025/ND-CP (effective 1 July 2025) replaced Decree 01/2021/ND-CP on enterprise registration and details BO declaration; Decree 296/2026/ND-CP (23 July 2026) amended Article 17 of Decree 168/2025 on BO identification criteria.
Contact FLAT Law Firm for support with beneficial owner declaration compliance.
