Many investors assume periodic reporting applies only to projects holding an Investment Registration Certificate. That is a common — and costly — misunderstanding. Under Article 47 of the Investment Law 143/2025/QH15 (effective 1 March 2026, replacing Investment Law 61/2020/QH14 in full), investors and business organizations implementing investment projects must report quarterly and annually — including projects that are not subject to Investment Registration Certificate issuance.
1. Who must report — not only certificated projects
Article 47, Clauses 1 and 2(a) of the 2025 Investment Law require investors and business organizations implementing investment projects to report quarterly and annually, covering:
- Implemented investment capital;
- Results of investment and business operations;
- Labor information;
- Payments to the state budget;
- Investment in research and development (R&D);
- Environmental treatment and protection;
- Sector-specific indicators.
Crucially, Article 47, Clause 5 provides: for projects not subject to Investment Registration Certificate issuance, the investor reports to the investment registration authority before implementing the project. No certificate does not mean no reporting duty.
2. Report to whom — two parallel recipients
Article 94, Clause 1 of Decree 96/2026/ND-CP requires the investor to report simultaneously to two authorities:
- The investment registration authority; and
- The state statistical authority in the locality.
Filing with only one of the two does not discharge the duty toward the other. Businesses should identify both authorities in the project locality from the very first period.
3. Two deadlines with different content
Decree 96/2026/ND-CP (effective 31 March 2026, replacing Decrees 31/2021, 19/2025 and 239/2025) distinguishes two regimes:
Quarterly report — before the 10th day of the first month of the following quarter (Article 94, Clause 2):
- Implemented investment capital;
- Net revenue;
- Exports and imports;
- Labor;
- Taxes and state budget payments;
- Land and water surface usage.
Annual report — before 31 March of the following year (Article 94, Clause 3): the quarterly indicators, plus:
- Profit;
- Employees income;
- Science and technology spending and investment;
- Environmental treatment and protection;
- Origin of technologies used.
4. How to report — online through the National Investment Information System
Article 47, Clause 3 of the 2025 Investment Law: reports are made in writing and through the National Investment Information System. Article 96 of Decree 96/2026 elaborates:
- Business organizations file reports online via the National Investment Information System;
- The investment registration authority files in writing and online;
- The Ministry of Finance prescribes the reporting forms.
Important distinction: this periodic investment-activity reporting regime runs in parallel with and independently of the investment monitoring and evaluation reporting regime (forms prescribed by the Ministry of Finance). The two systems have their own deadlines, content and forms; check the requirements of the local investment registration authority so no duty is missed.
5. Penalties for violating the reporting regime
Article 15 of Decree 122/2021/ND-CP (administrative penalties in planning and investment, still in force) provides:
- Clause 1 — fine of VND 20 to 30 million: preparing monitoring/evaluation reports late or with incomplete content; failing to implement the periodic monitoring/evaluation reporting regime;
- Clause 2 — fine of VND 30 to 50 million: failing to implement the investment-activity reporting regime or reporting late; untruthful or inaccurate reports; failing to notify project termination or suspension;
- Clause 3 — remedial measure: compulsory implementation of the reporting regime.
These fines apply to organizations; individuals are fined at half the level (Article 4 of Decree 122/2021). Two citations to avoid absolutely: Article 72 of the 2020 Investment Law as current law (now Article 47 of Law 143/2025) and Decree 31/2021 for deadlines and content (now Article 94 of Decree 96/2026).
Frequently asked questions
Must projects without an Investment Registration Certificate report?
Yes. Under Article 47, Clause 5 of the 2025 Investment Law, the investor reports to the investment registration authority before implementing the project.
What are the quarterly and annual deadlines?
Quarterly: before the 10th day of the first month of the following quarter; annual: before 31 March of the following year (Article 94 of Decree 96/2026).
Which authorities receive the reports?
Simultaneously the investment registration authority and the local state statistical authority.
What is the fine for late reporting?
VND 30 to 50 million for organizations, plus compulsory implementation of the reporting regime (Article 15 of Decree 122/2021).
Legal references
- Investment Law 143/2025/QH15 (effective 1 March 2026): Article 47 (reporting regime).
- Decree 96/2026/ND-CP (effective 31 March 2026): Article 94 (deadlines, content); Article 96 (reporting method).
- Decree 122/2021/ND-CP: Article 15 (penalties); Article 4 (organization/individual fine levels).
Running an investment project in Vietnam and need a review of your periodic reporting duties under the 2025 Investment Law? Contact FLAT Law Firm via the Contact page.
The information above is for reference only and does not constitute legal advice.
Transparency note: This article was drafted by FLAT Law Firm’s AI content production system and will be reviewed by the internal review board (AI Legal Council) before publication; it has not been reviewed by a human lawyer.