Investment reporting duties in 2026 comprise two entirely separate obligations that businesses often confuse: (a) investment supervision and evaluation reporting under Decree 19/2026/ND-CP (effective 14/01/2026) and Circular 44/2026/TT-BTC; and (b) project implementation status reporting under point (a), clause 2, Article 47 of the 2025 Investment Law and Circular 55/2026. This article distinguishes the two duties, their forms and their deadlines.
1. Duty (a): Investment supervision and evaluation reporting
Investment supervision and evaluation reporting is governed by Decree 19/2026/ND-CP (effective 14/01/2026), in which Article 64 and clauses 8 and 11 of Article 94 set the reporting milestones: 10 July, 10 February, 20 February and 1 March.
On forms, Circular 44/2026/TT-BTC (effective 22/4/2026) issues Forms 13, 16 and 17 for supervision and evaluation reporting. A notable new point: Circular 44/2026 provides for online reporting, with a 7-working-day deadline and the 25th of each month as the monthly periodic reporting date.
Distinguishing note: Forms 14, 15 and 18 are forms of state management agencies, not enterprise reporting obligations — enterprises do not prepare these forms. Confusing them can lead to preparing the wrong forms, wasting time while still failing the actual duty.
2. Duty (b): Project implementation status reporting
The second duty — project implementation status reporting — is based on point (a), clause 2, Article 47 of the 2025 Investment Law (Law 143/2025/QH15, effective 1/3/2026) and detailed in Circular 55/2026 with Forms I.3.1 and I.3.2.
Deadlines for project implementation status reporting:
- Quarterly reports: before the 10th of the first month of the following quarter (Q1 by 10 April, Q2 by 10 July, Q3 by 10 October, Q4 by 10 January of the next year);
- Annual report: before 31 March of the following year.
Note: the effective date of Circular 55/2026 is cited from secondary sources — verify against the original text before citing it in files or internal documents.
3. Comparing the two reporting duties
| Criterion | (a) Supervision and evaluation reporting | (b) Project implementation status reporting |
|---|---|---|
| Legal basis | Decree 19/2026 (Art. 64; clauses 8, 11 Art. 94); Circular 44/2026/TT-BTC | Point (a), clause 2, Art. 47, 2025 Investment Law; Circular 55/2026 |
| Enterprise forms | Forms 13, 16, 17 | Forms I.3.1, I.3.2 |
| Submission mode | Online reporting (per Circular 44/2026) | Per guidance in Circular 55/2026 |
| Key deadlines | 7 working days; 25th monthly; milestones 10/7, 10/2, 20/2, 1/3 | Quarterly: before the 10th of the first month of the following quarter; Annual: before 31 March of the following year |
4. The most common enterprise compliance failures
- Mixing the two duties: filing the project implementation report but missing the supervision and evaluation report (or vice versa) — the two duties have different bases, forms and deadlines and must be performed in parallel;
- Wrong forms: preparing Forms 14/15/18 (state agency forms) instead of Forms 13/16/17 or Forms I.3.1/I.3.2;
- Missing quarterly/annual deadlines: especially the 10th-of-first-month and 31 March marks — build them into the internal compliance calendar;
- Not switching to online reporting: Circular 44/2026 already requires online reporting for supervision and evaluation reports — set up accounts and online filing procedures.
Note: penalties for reporting violations have no established basis in the research scope — this article makes no assertion about sanctions. Enterprises should meet all deadlines and check the current penalty instruments when assessing risk.
FAQ
How many types of investment reports must an enterprise file?
Two separate types: (a) investment supervision and evaluation reporting (Decree 19/2026, Circular 44/2026) and (b) project implementation status reporting (Art. 47.2(a), 2025 Investment Law; Circular 55/2026).
Must enterprises file Forms 14, 15 and 18?
No. These are state management agency forms, not enterprise obligations. Enterprises use Forms 13/16/17 (supervision and evaluation) and Forms I.3.1/I.3.2 (implementation status).
What are the quarterly and annual reporting deadlines?
Quarterly: before the 10th of the first month of the following quarter; annual: before 31 March of the following year.
How are supervision and evaluation reports filed?
Under Circular 44/2026/TT-BTC, by online reporting, with a 7-working-day deadline and the 25th of each month for periodic reports.
Legal sources cited
- Decree 19/2026/ND-CP (effective 14/01/2026) — Article 64, clauses 8 and 11 of Article 94 (supervision and evaluation reporting);
- Circular 44/2026/TT-BTC (effective 22/4/2026) — Forms 13/16/17, online reporting;
- Investment Law 143/2025/QH15 (effective 1/3/2026) — point (a), clause 2, Article 47;
- Circular 55/2026 — Forms I.3.1/I.3.2 (effective date to be verified against the original text).
See also: FLAT Law Firm
Need reporting compliance support? FLAT Law Firm helps enterprises build investment reporting compliance calendars: duty classification, form preparation under Circulars 44/2026 and 55/2026, and online reporting workflows: Contact us.
This article is for general reference only and does not constitute legal advice for your specific situation.
Transparency note: Content reviewed by the FLAW AI Legal Council; it does not replace advice from a licensed lawyer.
