When an FDI project changes — IRC amendment, capital increase, location change, partial transfer — many companies focus on completing the amendment but forget to update investment reports. The result: data on the National Information System on Investment mismatches the new license, and the mismatch surfaces exactly when the company needs the next procedure (extension, incentives, profit repatriation). Investment reporting is not a “formality”: it is the only channel through which regulators see the project’s real status.
This article systematizes the FDI reports to file, deadlines, filing places, and how to update when a project changes. See also the overview of FDI companies’ investment reporting obligations.
Quick summary
| Topic | Updating reports when an investment project changes: report types, deadlines, filing places, update contents |
|---|---|
| Key point | Every project change (IRC, capital, location, investor) must be reflected in the nearest reporting period so management data matches the license |
| Filing place | The investment registration authority via the National Information System on Investment |
| Biggest risk | Late/missing reports — administrative penalties and trouble in subsequent procedures |
Three report types to know
| Report type | Main contents | Frequency |
|---|---|---|
| Project implementation status report | Implemented capital, progress, labor, financial obligations, operating status | Quarterly and annually |
| Change update report | Reflecting project contents changed during the period (IRC amendments, investor changes…) | The nearest reporting period after the change |
| Ad-hoc/other required reports | As required by the state investment management authority | When required |
When the project changes: what to update, where
- List the changes: enumerate every IRC-amended content (objectives, capital scale, location, schedule, investor) — line-by-line against the approved project amendment dossier.
- Update in the nearest reporting period: fully reflect the changes in the next quarterly/annual report; capital and progress figures must match the new IRC.
- File through the system: file with the investment registration authority via the National Information System on Investment; keep filing receipts/evidence.
- Cross-check: verify report data matches the new IRC, the new enterprise registration and accounting books — all three sources must “tell the same numbers”.
Deadlines and filing method
Quarterly reports are filed within the statutory period of the first month of the next quarter; annual reports in Q1 of the following year (check the specific deadlines in the guiding instrument in force at filing time, as deadlines may be adjusted through amending instruments). Companies should set internal reminders at least 2 weeks before deadlines, as compiling implemented capital and progress data usually takes longer than expected. In a project transfer, the transferee must continue the reporting obligation from the next period.
Report contents must match the new license
- Capital: charter capital, actually contributed capital, total investment capital — matching the amended IRC and enterprise registration.
- Progress: capital contribution progress and construction/implementation progress per new commitments (if the IRC amended the schedule).
- Location, objectives: updated per the new IRC contents.
- Labor and financial obligations: headcount, taxes and obligations performed during the period.
Legal basis
- Law on Investment No. 143/2025/QH15 (investment reporting regime);
- Decree 96/2026/ND-CP and guiding instruments on investment project implementation reporting;
- Law 76/2025/QH15 amending the Law on Enterprises;
- Decree 29/2025/ND-CP on the functions and tasks of the Ministry of Finance;
- Administrative sanction law in the investment sector.
Sanctions for reporting violations
Failing to file, late filing or filing inaccurate reports may be administratively sanctioned in the investment sector at the fine levels in the sanction instrument in force. Beyond fines, the heavier practical consequence: the investment registration authority may refuse or delay subsequent procedures (IRC amendments, schedule extensions) until the company completes outstanding reporting obligations.
FAQ
What reports must an FDI project file?
Periodic investment project implementation status reports (quarterly, annually) and change update reports, filed with the investment registration authority via the National Information System on Investment.
Must a report be filed right after an IRC amendment?
There is no separate “immediate” report, but the amended contents must be fully reflected in the nearest reporting period after the change takes effect.
Where are reports filed?
With the investment registration authority (the IRC issuer) through the National Information System on Investment; keep filing evidence.
What is the fine for late reporting?
Fines follow the administrative sanction instrument in the investment sector in force at the violation time; check the current instrument as levels may change.
Must a suspended project still report?
Yes. Periodic reporting obligations still apply; report contents reflect the project’s suspended status.
When should lawyers/accountants coordinate?
When report data is complex (multiple IRC amendments, partial capital transfers) — the three sources (reports, IRC, books) must be reconciled before filing.
