Since mid-2026, the entire form system for investment procedures has been replaced, and the legal framework for electronic filing has been fully codified. The two central documents are Circular 55/2026/TT-BTC (issued 15/5/2026, effective from signing) on investment procedure forms, and the electronic-dossier provisions in Articles 41 to 43 of Decree 96/2026/ND-CP. Enterprises should update immediately to avoid filing on old forms.
New form system: Circular 55/2026/TT-BTC replaces all 3 old circulars
Circular 55/2026/TT-BTC simultaneously replaces 3 old circulars: Circular 03/2021/TT-BKHDT, Circular 25/2023/TT-BKHDT and Circular 06/2025/TT-BKHDT. The replaced circulars are no longer valid bases — dossiers prepared on their forms will not be accepted.
An institutional note: Circular 55/2026 being issued by the Ministry of Finance (TT-BTC) instead of the Ministry of Planning and Investment (TT-BKHDT) marks the transfer of state management over investment from the Ministry of Planning and Investment to the Ministry of Finance following the apparatus reorganization. When looking up documents, enterprises must search for the TT-BTC symbol and not confuse them with the old MPI circulars.
The main form groups in the new system include: forms for applying for and amending the investment registration certificate; investment reporting and monitoring forms; forms related to investment policy approval; and other professional forms in state management of investment. When preparing a dossier, enterprises must use the Circular 55/2026 form corresponding to each specific procedure.
Circular 38/2026/TT-BTC: 13 forms for outbound investment
Alongside the domestic investment form system, Circular 38/2026/TT-BTC (effective from 15/4/2026) provides 13 forms from I.1 to I.13 for outbound investment activities. This is the unified form set for procedures such as applying for the offshore investment registration certificate, reporting on overseas project operations, and project amendment or termination procedures.
Vietnamese enterprises investing abroad should note the 15/4/2026 effective date: dossiers filed from that date must use Circular 38/2026 forms. Mixing in old forms is one of the common reasons dossiers are sent back for rework.
Electronic filing: 2 modes under Articles 41–43 of Decree 96/2026
Decree 96/2026/ND-CP, in Articles 41 to 43, sets the legal framework for filing investment dossiers electronically, with 2 modes:
- Electronic filing with digital signature: the dossier is digitally signed by the authorized person and carries legal validity equivalent to a paper dossier;
- Electronic filing without digital signature: the investor declares and submits the dossier through the electronic system, then must complete the comparison step as regulated.
Codifying both modes means enterprises not yet equipped with digital signatures can still begin filing online, instead of being shut out of the electronic channel entirely.
The 30-day trap: paper comparison after electronic filing
The most commonly overlooked point: after electronic filing (especially without a digital signature), the investor must compare the paper version within 30 days. Missing the 30-day comparison may halt further processing of the electronic dossier. This is a classic deadline trap — enterprises file online and forget the follow-up comparison obligation.
Practical advice: as soon as the system confirms receipt of the electronic dossier, schedule the paper comparison and prepare the corresponding paper set, rather than waiting until near the 30-day deadline.
Online issuance of the investment registration certificate: 10 working days
Under Article 43 of Decree 96/2026, online issuance of the investment registration certificate has a processing time of 10 working days from receipt of a complete and valid dossier. This matches the in-person timeline, showing the online channel is not a secondary option but a fully valid official method.
To benefit from the 10-day timeline, the electronic dossier must be complete and valid on first submission — each supplementation request restarts the clock.
Paper vs electronic discrepancies: paper prevails
A conflict-resolution rule to remember: where the paper and electronic versions differ, the paper version carries final legal validity. This demands absolute consistency between the two versions — enterprises must not treat the paper copy lightly on the assumption that electronic filing suffices.
In practice, the safest approach is to finalize the paper version first, then digitize each document accurately to create the electronic version, rather than preparing two independent versions and comparing afterwards.
Distinct from the step-by-step online filing guide
This article covers the new form system and the legal framework of electronic filing. Step-by-step operational guidance on the National Investment Information System (account creation, uploading dossiers, tracking status) belongs to a separate practical guide. Enterprises should read both: this article for which forms and which legal framework, the practical guide for how to operate.
FAQs
Can Circular 03/2021 forms still be used?
No. Circular 55/2026/TT-BTC has replaced Circular 03/2021 (along with Circulars 25/2023 and 06/2025/TT-BKHDT). The new forms must be used.
Can I file electronically without a digital signature?
Yes, under the no-digital-signature electronic filing mode (Articles 41–43 of Decree 96/2026), but the paper comparison must be completed within 30 days.
Which prevails if electronic and paper versions differ?
The paper version carries final legal validity.
Applicable legal sources
- Circular No. 55/2026/TT-BTC — issued 15/5/2026, effective from signing. Replaces Circulars 03/2021/TT-BKHDT, 25/2023/TT-BKHDT and 06/2025/TT-BKHDT.
- Circular No. 38/2026/TT-BTC — effective from 15/4/2026; 13 forms I.1 to I.13 for outbound investment.
- Decree No. 96/2026/ND-CP — Articles 41 to 43 (electronic filing).
Need to review your investment plan under the new 2026 legal framework? Reach us via the Contact page of FLAT Law Firm.
The legal content of this article was reviewed by the FLAW AI Legal Council of FLAT and submitted to the owner for approval; it is not the opinion of a human lawyer and does not replace legal advice for specific cases.
For reference only; not legal advice.