Beyond periodic project implementation reports, investors must file another report type: investment monitoring and evaluation reports. Many FDI enterprises confuse the two, missing deadlines or using wrong forms. This article clarifies: which investors must file, when, and where — under the law in force as of 15 October 2026.
1. Applicable legal framework
- Investment Law 143/2025/QH15 (effective 1 March 2026) — Article 47 (reporting regime for investment activities);
- Decree 96/2026/ND-CP (effective 31 March 2026) — Article 99 (investment monitoring and evaluation);
- Circular 44/2026/TT-BTC (issued 22 April 2026, effective from signing; replacing Circular 05/2023/TT-BKHDT) — 19 monitoring/evaluation report forms; online reporting regime and management of the Investment Monitoring and Evaluation Information System.
2. Which investors must file monitoring and evaluation reports?
Under Clause 1, Article 47 of Investment Law 2025, the reporting regime applies to investors and business organizations implementing investment projects — including foreign investors with projects in Vietnam. Thus every FDI project under implementation or in operation must carry out investment monitoring and evaluation reporting, regardless of capital size or sector.
For projects not subject to Investment Registration Certificate issuance, the investor reports to the investment registration authority before implementing the project (Clause 5, Article 47).
3. Filing deadlines
Under Point d, Clause 6, Article 99 of Decree 96/2026/ND-CP, investor deadlines for project monitoring and evaluation reports are:
| Report type | Deadline |
|---|---|
| Semi-annual report | Before 10 July of the reporting year |
| Annual report | Before 10 February of the year following the reporting year |
| Pre-IRC-amendment report | Before amending the Investment Registration Certificate |
Practical note: some localities require quarterly monitoring and evaluation reports. Contact the local investment registration authority for specific guidance before filing.
4. Report contents
Monitoring and evaluation reports cover: implemented investment capital; investment/business performance (revenue, profit, exports, imports); labour and employee income; taxes and state budget contributions; land use; R&D and technology development spending; environmental treatment and protection; and sector-specific indicators.
The pre-IRC-amendment report adds to the annual indicators: the amendment contents, reasons, and a re-assessment of project efficiency after amendment.
Forms follow Circular 44/2026/TT-BTC (19 report forms and annexes), which replaced Circular 05/2023/TT-BKHDT — do not use the old forms.
5. How to file
File with the investment registration authority (IP/economic zone management board for in-zone projects; Department of Finance for off-zone projects) and update the National Information System on Investment / Investment Monitoring and Evaluation Information System. Under Circular 44/2026/TT-BTC:
- Project information must be updated on the system within 07 working days of the investment decision date;
- Uploaded documents must be colour scans of originals or electronic documents with a valid digital signature;
- Online reporting fully replaces periodic paper reports.
6. The two FDI report types at a glance
| Criterion | Periodic (implementation) reports | Monitoring & evaluation reports |
|---|---|---|
| Basis | Article 47, Law 143/2025; Article 94, Decree 96/2026 | Article 99, Decree 96/2026; Circular 44/2026/TT-BTC |
| Nature | Reflects implementation status | Evaluates efficiency; serves project amendment |
| Frequency | Quarterly (before the 10th of the first month of the next quarter); annual (before 31 March) | Semi-annual (before 10 July); annual (before 10 February of the next year) |
| Special case | Ad hoc on request | Before IRC amendment |
FDI enterprises must file both types — they are not interchangeable.
7. Frequently asked questions
Must an FDI project still under construction file monitoring and evaluation reports?
Yes. The obligation covers investors implementing investment projects — including the implementation phase. Report the actual status (construction progress, disbursed capital, etc.).
What if the pre-amendment report is missed before an IRC amendment?
The amendment dossier may be asked to supplement the monitoring and evaluation report, delaying processing. Complete the report before filing the amendment dossier.
Can a consulting firm prepare the reports?
Yes, but the investor remains responsible for data accuracy and timely filing.
This article was prepared by the FLAW AI Legal Council — the AI legal council of FLAT Law Firm, based on legislation in force as of 15 October 2026. It is general reference only and not legal advice for your specific case.
For tailored advice on your project’s reporting obligations, please contact FLAT Law Firm.
Article status: pending QA council review.