An FDI enterprise was fined and had a violation recorded in its project file not for breaching investment rules, but for forgetting to file a quarterly supervision report — a small administrative lapse that leaves a mark on every later project adjustment appraisal. The investment reporting regime is tightening alongside the national investment information system, and reporting compliance is the cheapest yet most commonly missed part of FDI corporate governance.
Which investment reports must be filed, and when
The first layer is the investor’s investment supervision and evaluation reporting: the FDI enterprise reports periodically on project implementation (contributed capital, progress, revenue, labour, financial obligations) on quarterly and annual cycles, plus reports when the project ends or terminates, under the framework of Investment Law 143/2025/QH15 and guiding Decree 96/2026/ND-CP. The second layer is investment statistics reporting under statistics law, alongside sector reports (tax, customs, labour) outside this article’s scope.
Specific deadlines for each report type sit in guiding documents and notices of the investment registration authority — the governance principle is not to wait for reminders: the reporting calendar must enter the enterprise’s annual compliance calendar from the start of the fiscal year, because violations run from the expiry date, not the discovery date.
Sanctions: fines plus remedial measures and file consequences
Investment reporting violations draw administrative sanctions in the planning and investment field under Decree 122/2021/ND-CP: fines scale with the conduct (failure to file, late filing, incomplete or incorrect content) applied to organisations, plus the remedial measure of compelled complete filing. Enterprises should check the penalty instrument in force at the time of application, as this field’s penalty framework is on an update path following the 2025 Investment Law.
Heavier than the fine is the compliance file: reporting violations are recorded on the system and weighed when the enterprise seeks project adjustment, term extension or new projects; some procedures may require completing outstanding reports first. Reporting compliance is therefore an investment protecting the speed of every future procedure.
Online filing via the national investment information system
Investment reports are filed online through the National Investment Information System (the online investment portal of the Ministry of Finance — the authority inheriting planning and investment functions), using the enterprise account and digital signature. The system records the electronic submission time as the basis for timeliness, progressively replacing paper filing at local investment registration authorities.
Practice points: the system account should be administered by the legal/compliance function rather than one individual; each period’s submission confirmation must be archived with the project file; and data on the system must match financial statements and tax returns — discrepancies between reporting channels are the first cross-check regulators run.
Organising internal reporting compliance: calendar, people, data
An effective compliance model has three parts: a consolidated compliance calendar of all reporting duties (investment, statistics, tax, labour, customs) with deadlines and owners per item; an internal data-closing process a few working days before deadlines allowing accounting–legal cross-checks; and early-warning mechanisms for event-driven reports when the project changes (schedule, capital, investor).
For groups with many projects across provinces, reporting failures typically occur at small, low-attention projects — a quarterly cross-portfolio review, reconciling the certificate project list against the system’s filed list, is a cheap measure catching most omissions before they become violations.
Frequently Asked Questions
Which investment reports must FDI enterprises file, and by when?
Two main layers: periodic quarterly/annual investment supervision and evaluation reports, plus end-of-project reports, under Investment Law 143/2025 and Decree 96/2026/ND-CP; and investment statistics reports under statistics law (besides tax, customs and labour). Deadlines per type follow guiding documents and the registration authority — put them in the annual compliance calendar, never wait for reminders.
What are the fines for not filing or filing incorrectly?
Administrative sanctions under Decree 122/2021/ND-CP in planning and investment: fines scale by conduct (non-filing, lateness, incompleteness or incorrect content) for organisations, plus compelled complete filing as the remedy. The penalty framework is being updated after the 2025 Investment Law, so verify the instrument in force at application time; project-file consequences usually outweigh the fine.
Through which system are investment reports filed online?
Through the National Investment Information System — the Ministry of Finance’s online investment portal, using the enterprise account and digital signature; the electronic submission timestamp determines timeliness. Archive each period’s submission confirmation and keep figures consistent with financial statements and tax returns, as regulators cross-check between channels.
How should internal reporting compliance be organised?
Three parts: a consolidated compliance calendar for all reporting duties with deadlines and owners; an accounting–legal cross-checked data-closing process a few days before deadlines; and early warning for event-driven reports when projects change. Multi-province groups should run a quarterly cross-portfolio reconciliation of certificates against the filed list on the system.
This article has been quality-reviewed by the FLAW AI Legal Council