Among the legal obligations of an FDI project in Vietnam, one is known to nearly every company yet performed properly by far fewer: periodic investment activity reporting. Unlike one-off procedures such as obtaining the Investment Registration Certificate (IRC) or the Enterprise Registration Certificate (ERC), periodic reporting is a recurring duty — quarterly and annually — for the entire life of the project. Missing a few reporting periods may seem harmless, but when the company later needs to adjust the project, extend its timeline, increase capital or renew its operational term, gaps in the reporting record become the first thing the investment registration agency notices.
This article sets out the full periodic reporting regime for FDI projects under the 2025 Investment Law (effective 1 March 2026): who must report, what to report, to whom, how often, in what form, and what sanctions apply for non-compliance.
Contents
- 1. Why periodic reporting is the most neglected FDI obligation
- 2. Current legal framework: Article 47 of the 2025 Investment Law and Circular 55/2026/TT-BTC
- 3. Who must report: three groups under Article 47(1)
- 4. What to report, to whom, and how often
- 5. Form of reporting: written reports and the National Investment Information System
- 6. A practical annual reporting calendar for an FDI project
- 7. Sanctions for failure to report or inaccurate reporting
- 8. Five common mistakes by FDI enterprises
- 9. Compliance checklist for in-house legal and accounting teams
- 10. Frequently asked questions
- 11. When to work with counsel
1. Why periodic reporting is the most neglected FDI obligation
Three reasons explain why periodic reporting usually sits at the bottom of an FDI company's priority list.
First, it is an obligation with no reminder. Unlike tax duties, for which the tax authority issues notices, or social insurance, whose payment schedule is tied to payroll, investment reporting has no unified automatic reminder mechanism nationwide. Companies must track the calendar themselves.
Second, the consequences of non-reporting do not arrive immediately. Missing the Q2 report does not get a project suspended in Q3. The consequences accumulate silently: when the company later files to amend the IRC, the investment registration agency reviews the compliance history, finds multiple blank reporting periods, and the amendment file may face requests for supplementation, explanations, or closer scrutiny of the investor's seriousness.
Third, many companies confuse investment reporting with tax, statistics or labour reporting. These are four distinct reporting systems, addressed to different agencies, on different forms. Filing financial statements with the tax authority does not discharge the duty to report project implementation to the investment registration agency.
From 1 March 2026, the 2025 Investment Law (No. 143/2025/QH15) replaces the 2020 Investment Law, and the investment reporting regime is consolidated in Article 47. Operating FDI enterprises should review their entire internal reporting process against the new framework.
2. Current legal framework: Article 47 of the 2025 Investment Law and Circular 55/2026/TT-BTC
Article 47 of the 2025 Investment Law structures the reporting regime in five paragraphs:
- Paragraph 1 identifies three groups subject to the reporting regime.
- Paragraph 2 sets out periodic reporting — quarterly and annually — with specific contents and recipients for each group.
- Paragraph 3 prescribes the form: in writing and through the National Investment Information System.
- Paragraph 4 covers ad-hoc reporting at the request of competent state agencies.
- Paragraph 5 addresses projects not subject to IRC issuance: the investor reports to the investment registration agency before implementing the project.
On forms, the Ministry of Finance has issued Circular 55/2026/TT-BTC prescribing investment activity reporting templates. Companies must use the latest forms, not the templates from the 2020 Investment Law era.
Decree 96/2026/ND-CP, detailing and guiding implementation of several articles of the 2025 Investment Law, is the general guiding instrument companies should consult when carrying out related procedures.
3. Who must report: three groups under Article 47(1)
Article 47(1) of the 2025 Investment Law lists three groups:
Group 1: Ministries, ministerial-level agencies, and provincial People's Committees. These state management bodies report on investment management within their functions.
Group 2: Investment registration agencies. They report to the Ministry of Finance and provincial People's Committees on the receipt, issuance, amendment and revocation of IRCs and on the operation of projects under their management.
Group 3: Investors and business organisations implementing investment projects under the 2025 Investment Law. This is the group this article focuses on — every FDI enterprise implementing an investment project in Vietnam, including foreign-invested business organisations.
A point to note: the reporting subjects are not limited to companies holding an IRC. Domestic investors' projects subject to investment policy approval, or projects of foreign-invested business organisations not subject to IRC issuance, all fall within scope. For projects not subject to IRC issuance, Article 47(5) requires the investor to report to the investment registration agency before implementing the project — a "report before" duty, not only periodic reporting afterwards.
4. What to report, to whom, and how often
Article 47(2)(a) states the core duty of investors and business organisations:
Quarterly and annually, investors and business organisations implementing investment projects report to the investment registration agency and the local statistics office on project implementation.
The report covers seven groups of information:
- Implemented investment capital — capital actually disbursed in the period, against registered capital and the capital contribution schedule in the IRC.
- Investment and business results — revenue, profit, and production or business performance of the project.
- Labour information — headcount and the split between Vietnamese and foreign employees.
- Payments to the state budget — taxes, fees and land rentals paid.
- Research and development investment — R&D spending, if any.
- Environmental treatment and protection — implementation of the project's environmental protection measures.
- Sector-specific indicators — depending on the project's line of business.
The two recipients of an investor's report are the investment registration agency (typically the industrial park or economic zone management board for in-zone projects, or the Department of Finance for off-zone projects) and the local statistics office.
The remaining groups report up a consolidation chain: investment registration agencies report to the Ministry of Finance and provincial People's Committees; provincial People's Committees consolidate to the Ministry of Finance; ministries and ministerial-level agencies report to the Ministry of Finance; annually, the Ministry of Finance reports to the Prime Minister on nationwide investment.
Beyond periodic reporting, Article 47(4) imposes ad-hoc reporting at the request of competent state agencies — for example during project inspections or following serious environmental or labour accidents.
5. Form of reporting: written reports and the National Investment Information System
Article 47(3) requires reports to be made in writing and through the National Investment Information System. This is a dual requirement, not a choice between two options.
In practice this means:
- The company prepares the report on the Circular 55/2026/TT-BTC templates, signed and sealed as required.
- It files the written report (in person, by post or via the public service portal) with the investment registration agency and the statistics office.
- It simultaneously enters or attaches the report on the National Investment Information System.
A common mistake is filing only the paper report with the investment registration agency while never logging into the electronic system, or vice versa. When the regulator cross-checks, a period counts as unreported if either channel is missing. Digital maturity of the National Investment Information System varies by locality, so companies should confirm the electronic filing method directly with the investment registration agency where the project is located.
6. A practical annual reporting calendar for an FDI project
The law prescribes "quarterly, annual" cycles without fixing calendar dates; detailed deadlines follow Circular 55/2026/TT-BTC and each investment registration agency's guidance. Below is a reference calendar that an FDI company's legal or accounting department should build internally:
| Reporting period | Internal data cut-off | Filing (reference) | Recipients |
|---|---|---|---|
| Q1 | End of March | April | Registration agency + Statistics office |
| Q2 | End of June | July | Registration agency + Statistics office |
| Q3 | End of September | October | Registration agency + Statistics office |
| Q4 + annual | End of December | Q1 of following year | Registration agency + Statistics office |
Important: this is an internal reference calendar. Companies must cross-check the specific deadlines required by the local investment registration agency, as some localities require quarterly reports within 15–20 days of the following quarter. The good practice of "closing internally earlier than the legal deadline" leaves room to fix figures when adjustments are needed.
Companies should also keep investment reporting distinct from other reporting calendars: annual financial statements, CIT finalisation, labour usage reports, periodic environmental monitoring reports — each with its own recipient and deadline.
The legal basis for those dates sits in the notes to each form itself: Form I.3.1 (Quarterly Report on Investment Project Implementation) sets the filing deadline as “before the 10th day of the first month of the quarter following the reporting quarter”; Form I.3.2 (Annual Report) sets it as “before 31 March of the year following the reporting year” (form notes, Appendix I, Circular 55/2026/TT-BTC of 15 May 2026). Both forms are filed exclusively through the National Investment Information System, addressed simultaneously to the investment registration agency and the local statistics agency. Note: monthly reporting duties apply only to state management agencies, not to investors. Late or missed filings correspond to “reporting behind schedule” or “failure to implement the investment activity reporting regime” under Article 15(2) of Decree 122/2021/ND-CP, carrying a fine of VND 30,000,000–50,000,000 together with an order to complete the reporting. Companies with projects in multiple provinces should also check the guidance of each investment registration agency, or contact FLAT Law Firm for a compliance calendar tailored to their project.
7. Sanctions for failure to report or inaccurate reporting
Breaches of the investment reporting regime are administrative violations in the planning and investment sector, sanctioned under Decree 122/2021/ND-CP. Sanctionable conduct includes failure to report, late reporting, incomplete reporting, or reporting untruthful contents.
Beyond fines, companies should weigh indirect consequences that are often more serious:
- Closer supervision. Investment registration agencies track each project's reporting compliance history. Projects with chronic late or missing reports attract more attention during inspections.
- Difficulties in project amendment. When a company files to amend the IRC (capital increase, objective change, timeline extension), the agency may require supplementation and explanations for missing reporting periods before considering the amendment.
- Risks in term renewal. A project nearing the end of its operational term and seeking renewal must demonstrate serious implementation; a complete reporting history is part of that evidence.
- Grounds for considering project termination. Where a project has long suspended operations and the agency cannot contact the investor, a prolonged absence of any reports may become one factor in considering termination of project operations under Article 36 of the 2025 Investment Law.
In other words, the cost of non-reporting is not the administrative fine — it is the compliance history, which cannot be bought back when the company needs the regulator to decide in its favour.
8. Five common mistakes by FDI enterprises
Mistake 1: Confusing investment reporting with tax reporting. Filing financial statements and tax returns with the tax authority does not discharge the investment reporting duty to the investment registration agency. Two independent systems.
Mistake 2: Filing only on paper, skipping the electronic system. Article 47(3) requires both forms. Many companies file paper reports diligently but have never logged into the National Investment Information System.
Mistake 3: Using outdated templates. The 2020 Investment Law-era templates have been replaced by Circular 55/2026/TT-BTC forms. Filing on the wrong form may trigger a redo request.
Mistake 4: Not reporting because the project has no revenue yet. Projects under construction, not yet operational, must still report — covering implementation progress, disbursed capital and construction status. "Nothing to report" is not a ground for exemption.
Mistake 5: Losing the calendar when the responsible staff changes. In-house legal or accounting staff leave, handovers are incomplete, and the reporting calendar breaks. The duty attaches to the company, not to the individual in charge.
9. Compliance checklist for in-house legal and accounting teams
- [ ] Identify the correct investment registration agency for the project (industrial/economic zone management board or Department of Finance) and the local statistics office.
- [ ] Build an internal annual reporting calendar: 4 quarterly + 1 annual report, with internal data cut-off at least 10 working days before filing.
- [ ] Download and use the latest templates under Circular 55/2026/TT-BTC.
- [ ] Assign clear ownership for each content group: investment capital (accounting), labour (HR), state budget payments (tax accounting), environment (HSE), sector indicators (operations).
- [ ] File through both channels — written report and the National Investment Information System — and keep filing receipts for each period.
- [ ] Review consistency of figures across periods and between investment reports, tax reports and statistics reports (capital implemented, labour, budget payments).
- [ ] On staff changes, hand over the full reporting history and electronic system accounts.
- [ ] For pre-revenue or suspended projects: keep filing reports stating the actual status, with a suspension notice where applicable.
- [ ] Archive reporting files at least for the statutory retention period for accounting vouchers and project legal records.
- [ ] Annually review new legal instruments on the reporting regime to update templates and deadlines.
10. Frequently asked questions
Does an FDI project that is not required to obtain an Investment Registration Certificate still have to file periodic reports? Yes. Article 47(5) of the 2025 Investment Law provides that for projects not subject to IRC issuance, the investor reports to the investment registration agency before implementing the project. Once operational, such projects remain subject to the same quarterly and annual periodic reporting as other projects.
What are the exact filing deadlines for quarterly and annual reports? The 2025 Investment Law prescribes quarterly and annual cycles but does not fix calendar dates in the law itself; detailed deadlines and forms follow Circular 55/2026/TT-BTC of the Ministry of Finance. In practice, companies should close quarterly reports within the first month of the following quarter and annual reports within the first quarter of the following year, while confirming the specific requirements of the local investment registration agency.
Which agencies receive the reports? Under Article 47(2) of the 2025 Investment Law, investors and project-implementing business organisations report to the investment registration agency and the local statistics office on project implementation. The investment registration agency then reports to the Ministry of Finance and the provincial People's Committee; ministries report to the Ministry of Finance for consolidation to the Prime Minister.
Are there penalties for failing to file periodic reports? Yes. Breaches of the investment reporting regime are administrative violations in the planning and investment sector, sanctioned under Decree 122/2021/ND-CP. Beyond fines, companies risk closer supervision and difficulties when seeking project adjustments, timeline extensions or term renewals.
Must reports be filed both on paper and electronically? Article 47(3) of the 2025 Investment Law requires reports to be made in writing and through the National Investment Information System. Companies should complete both channels as instructed by the investment registration agency, keeping filing receipts for each period.
Does a project that has suspended operations still have to report? In principle, the reporting duty attaches to the investor's status rather than to whether the project is operating. When a project suspends operations, the investor should continue filing reports (stating the suspension) and complete the suspension notification procedures, to avoid being treated as having abandoned the investment location.
11. When to work with counsel
Periodic reporting is work an in-house legal department can run itself once the process is established. Counsel's involvement becomes necessary in these situations:
- Compliance health-checks before key milestones — IRC amendment, capital increase, timeline extension, project term renewal, project transfer — to detect and remedy missing reporting periods before filing.
- Handling breaches that have occurred: a company facing an administrative violation record on reporting needs an assessment of the sanction decision and complaint options where warranted.
- Complex project structures: multiple locations, multiple phases, partly inside and partly outside industrial zones — identifying the correct investment registration agency and reporting scope should be clarified from the outset.
- Figure discrepancies: when investment report figures diverge from tax or statistics figures, a consistent explanation should be prepared before the regulator asks.
FLAT Law Firm helps FDI enterprises review and build investment reporting compliance systems: internal reporting calendars, standardised templates under Circular 55/2026/TT-BTC, compliance history reviews before project amendment procedures, and representation before investment registration agencies when issues arise. Contact us for an assessment of your project's current compliance level.
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