Against the backdrop of Vietnam’s rapidly evolving economy in 2026 and the implementation of the Law on Investment 2025, which took effect on 1 March 2026, the Ministry of Finance issued Circular No. 55/2026/TT-BTC, effective from its signing date of 15 May 2026, providing detailed guidance on forms and reports related to investment activities. This Circular serves as an essential legal reference for FDI enterprises, domestic investors, and state management authorities.
In this article, Law Plus provides an overview of the key updates introduced under Circular No. 55/2026/TT-BTC.
1. Background and Scope of Application of Circular No. 55/2026/TT-BTC
The enactment of the Law on Investment 2025 has fundamentally reformed the procedures for appraisal, supervision, and evaluation of investment projects. To facilitate the implementation of these new regulations, Circular No. 55/2026/TT-BTC was promulgated to replace previous provisions and establish a nationwide standardized system of forms. The Circular governs:
– Standard forms for investment procedures, including investment project registration, amendment, and termination;
– Periodic reporting forms on the implementation status of investment projects;
– Forms used by competent state authorities in the appraisal process and the issuance of Investment Registration Certificates (“IRCs”).
The uniform application of these forms not only enhances the transparency and consistency of administrative procedures but also serves as a basis for integrating investment-related data into the National Investment Information System in accordance with Article 7 of Circular No. 44/2026/TT-BTC.
2. Key Changes to the Investment Reporting Forms System
Compared to previous regulations, Circular No. 55/2026/TT-BTC focuses on simplifying administrative procedures while enhancing the level of detail required in financial reporting and investment monitoring.
2 .1. Forms for Special Investment Procedures
For investment projects subject to special investment procedures, investors should pay particular attention to the financial appendices prescribed under Circular No. 55/2026/TT-BTC. These requirements are intended to ensure closer supervision of high-tech projects and large-scale investment projects, particularly with respect to capital disbursement progress and the utilization of investment funds.
2 .2. Investment Monitoring and Evaluation Reports
One notable development is the integration between investors’ reporting obligations under Circular No. 55/2026/TT-BTC and the monitoring and evaluation activities conducted by state authorities under Circular No. 44/2026/TT-BTC.
Investors are required to submit quarterly and annual reports on the implementation status of their investment projects in accordance with Forms I.3.1 and I.3.2 of Circular No. 55 through the National Investment Information System.
In addition, indicators relating to environmental protection, labor compliance, and social responsibility are no longer confined to initial project commitments. Instead, these factors will be continuously monitored through periodic evaluation reports and community-based investment supervision reports (Form No. 19 of Circular No. 44).
3. Reporting Obligations and Submission Deadlines Under the New Regulations
Investors should pay close attention to the applicable reporting deadlines to avoid being subject to administrative sanctions for non-compliance. Pursuant to Decree No. 96/2026/ND-CP guiding the implementation of the Law on Investment and Circular No. 55/2026/TT-BTC, the reporting regime is prescribed as follows:
| Report Type | Submission Deadline | Applicable Form (Circular No. 55/2026/TT-BTC) |
| Quarterly Report | Before the 10th day of the first month of the quarter following the reporting quarter | Form I.3.1 |
| Annual Report | Before 31 March of the year following the reporting year | Form I.3.2 |
| Ad hoc reporting | Upon receipt of a written request from a competent state authority | As specified in the request |
| Pre-Implementation Report | Prior to the commencement of the investment project (applicable to projects not subject to the issuance of an Investment Registration Certificate) | Form I.3.3 |
Failure to comply with reporting obligations or submission deadlines may result in administrative penalties and may adversely affect the investor’s ability to carry out subsequent investment procedures.
4. Digital Transformation and Online Reporting
In 2026, paper-based reporting is gradually being replaced by fully electronic reporting mechanisms. Once a report has been authenticated through a digital signature on the relevant information system, investors are no longer required to submit a hard-copy version of the report (Article 10 of Circular No. 44/2026/TT-BTC).
In addition, clause 1 Article 7 of Circular No. 44/2026/TT-BTC expressly provides that:
“Investors must update project information on the National Investment Information System within seven (07) working days from the date on which any change occurs, in accordance with Article 7 of Circular No. 44/2026/TT-BTC.”
Failure to update project information, or the submission of inaccurate or incomplete information on the system, may be deemed a failure to comply with reporting obligations and may result in administrative sanctions in accordance with regulations governing administrative violations in the field of planning and investment.
5. Key Considerations for Enterprises
To enhance compliance and minimize legal risks under Circular No. 55/2026/TT-BTC, enterprises should take the following steps:
Step 1: Review and Update Reporting Forms
Enterprises should review all forms and templates currently in use to ensure that applications for investment registration, project amendments, and other investment-related procedures have been updated in accordance with the appendices issued together with Circular No. 55/2026/TT-BTC.
Step 2: Establish the Legal Validity of Electronic Records
Enterprises are encouraged to prioritize the use of electronically signed documents when submitting reports. Under the applicable regulations, electronically authenticated information is recognized as the “original information” and carries the highest evidentiary value when dealing with inspection, examination, and audit authorities.
Step 3: Establish a Dedicated Compliance Function
Enterprises should assign dedicated personnel responsible for investment monitoring and evaluation in order to regularly update information relating to capital disbursement, construction progress, and labor utilization throughout the implementation of the investment project.
Step 4: Maintain Proper Record Retention
In addition to fulfilling online reporting obligations, enterprises should retain original records, whether in hard-copy form or electronic form bearing valid digital signatures, to facilitate inspections and examinations in accordance with Article 45 of the Law on Investment 2025.
Step 5: Align Industry-Specific Reporting Obligations
For specialized investment projects, such as overseas petroleum investment projects, enterprises should ensure compliance with the reporting requirements set out in Article 24 of Decree No. 132/2024/ND-CP. This will help maintain consistency in the procedures relating to outbound capital transfers and the repatriation of profits to Vietnam.
6. Legal Risks Associated with Non-Compliance with Reporting Obligations
Failure to comply with the reporting requirements prescribed under Circular No. 55/2026/TT-BTC, whether through delayed submissions or inaccurate reporting, may expose investors and enterprises to significant legal risks, including:
– Administrative Penalties: Failure to submit reports or the submission of false or misleading information may result in administrative sanctions in accordance with Decree No. 19/2026/ND-CP. Penalties imposed on organizations are generally twice the amount applicable to individuals and may be accompanied by additional measures, including the suspension of project operations in cases of continued non-compliance.
– Impact on Investment Incentives: Investors are entitled to tax and land-use incentives only when they maintain ongoing compliance with applicable laws and regulations. Projects that fail to satisfy reporting obligations may be subject to review, suspension, or revocation of previously granted financial incentives and investment support policies.
– Difficulties in Project Amendment Procedures: Before submitting an application for amendment of an investment project, investors are required to complete and submit investment monitoring and evaluation reports regarding the implementation status of the project. Investment registration authorities may reject applications for project amendments where investors have failed to fulfill their investment monitoring and evaluation reporting obligations for previous reporting periods.
7. Conclusion
Circular No. 55/2026/TT-BTC is not merely a set of administrative forms and templates; it serves as an important regulatory instrument enabling the State to effectively monitor and manage investment capital flows. Enterprises and investors should proactively review, update, and strictly comply with the new reporting requirements to ensure legal compliance and support the sustainable operation of their business activities in Vietnam.