Among all grounds for refusing an Investment Registration Certificate (IRC), “financial capacity not proven” frustrates investors the most, because it sounds vague: the money sits in the account, so why is capacity still judged insufficient? In reality, the investment registration authority does not audit the investor’s wealth — it tests the coherence between the project’s scale and funding sources proven by valid documents. This article explains the actual financial appraisal criteria and the supplementary dossier capable of reversing a refusal.
Appraisal criteria: what does the registration authority examine?
Under the Law on Investment No. 143/2025/QH15 and Decree No. 96/2026/ND-CP dated 31 March 2026, the IRC application must include documents proving the investor’s financial capacity corresponding to the capital committed to the project. Appraisal cross-checks three layers of evidence: the investor’s own capacity (available balances and cash flow), the capacity of the organisation behind it (the parent company, where the investor is newly formed or thinly capitalised), and bank credit commitments for the mobilised portion. Weaknesses usually lie not in the amount of money but in how “readable” the papers are: a stale balance confirmation, unaudited financial statements, or a parent letter that merely expresses intent instead of a binding funding commitment.
The supplementary dossier that fixes the problem
Rebuild the evidence in the order appraisers read it
- A recent bank balance confirmation of the investor, showing funds ready for the first-phase capital contribution; foreign-issued papers must be consular-legalised and notarised in translation.
- Audited financial statements of the investor or the parent company for the most recent years, with an explanation of how capital will be allocated to the Vietnam project.
- A parent company funding commitment or guarantee letter with binding content on amount and timing, replacing a generic letter of introduction.
- A bank loan commitment or credit line confirmation for the mobilised portion, if the project includes borrowed capital.
- A project funding balance table: contributions phased in line with the implementation schedule stated in the project proposal.
One important note: the law sets no universal “minimum balance” for all projects. The yardstick is proportionality — proven funds must cover the committed contributions according to the schedule. So instead of asking “how much money is enough”, investors should ask “does my paper set close the funding chain phase by phase”.
Why supplementation can still end in refusal
Adding documents is necessary but not sufficient. If the project’s capital structure is itself unbalanced — for example, contributed capital is a tiny fraction of total investment while the borrowing portion has no commitment at all — the appraiser may still find the project financially unfeasible. Likewise, an investor with a record of late capital contribution or a terminated project in Vietnam will have that compliance history weighed. Before resubmitting, enterprises should therefore revisit the whole project proposal: shrinking phase one to match provable capacity, or raising the equity ratio, usually works better than merely adding papers to an unchanged capital structure.
Recurring errors in financial proof files
Repeated mistakes include: using a balance confirmation for an account not held by the investor named in the project; submitting unaudited parent financial statements although the project is large; a parent commitment letter lacking an authorised signature or company seal; and figures that disagree across the explanation letter, the project proposal and the bank documents in decimals or currency. Each such slip makes the appraiser doubt the entire dossier.
When a refusal notice cites financial grounds, ask the investment registration authority to state in writing exactly which evidence layer fell short, then supplement precisely that layer together with a phased funding balance table. This turns a vague refusal ground into a concrete task list — the shortest route to approval at the next examination round.
What a convincing funding narrative looks like
Appraisers read financial files the way lenders read credit files: they look for a story in which sources and uses meet at every phase. A convincing dossier therefore opens with a one-page funding map — phase one requires this much, equity covers this portion, the parent commitment covers that portion, the bank line covers the remainder — and every number on that map traces to a document behind it. Where investors most often undersell themselves is timing: a balance confirmation proves a stock of money on one day, but a project consumes money over years, so pairing the confirmation with the parent’s audited cash-flow history and a phased disbursement plan answers the appraiser’s real question, which is durability rather than a snapshot. Currency discipline matters too: commitments expressed in a foreign currency should state the currency consistently across the commitment letter, the proposal and the bank papers, because unexplained switches between currencies are a classic trigger for supplementation requests. Finally, if part of the funding depends on a future event — an asset sale, a capital raise, a shareholder loan — say so openly and document that event as far as it can be documented; an appraiser who discovers a hidden dependency loses trust in the whole file, while one who sees the dependency disclosed and managed treats it as ordinary project finance.
Investors who have been through one financial-capacity refusal rarely repeat it, because the remedy teaches a permanent habit: build the funding evidence at the same time as the project design, not after the design is finished. When the capital structure and its proof set grow together, the appraisal conversation changes from whether the investor can pay to how the project will be phased — which is exactly where a serious investor wants it to be.
Frequently Asked Questions
What documents must be supplemented after a refusal for unproven financial capacity?
Supplement in three layers: a recent bank balance confirmation of the investor; audited financial statements of the investor or parent company with a binding funding commitment letter; and a bank credit commitment for the mobilised portion, plus a funding balance table matching the project schedule.
How large a bank balance counts as sufficient capacity?
The law fixes no common minimum balance. The test is proportionality: proven funds must cover the committed contributions according to the schedule in the project proposal. An unbalanced capital structure can still be refused despite a large balance.
Must the parent company’s financial statements be audited?
For a project of significant scale, appraisers expect independently audited financial statements for reliability. Unaudited statements are usually treated as weak evidence and are a common cause of supplementation requests or refusals.