The Law on Investment 2025 officially took effect on 31 March 2026, superseding numerous prior regulations governing investment activities in Vietnam. Concurrently, the Government promulgated Decree No. 96/2026/NĐ-CP providing detailed guidance on the implementation of the Law on Investment 2025, which sets out specific investment reporting obligations that investors and foreign-invested enterprises (FDIs) must fulfill in the course of project execution.

The following article consolidates the latest regulatory requirements on investment reporting that FDI enterprises should take note of in 2026.

1. Are foreign-invested enterprises required to comply with investment activity reporting obligations?

Yes.

Pursuant to Article 47 of the Law on Investment 2025, investors and economic organizations implementing investment projects are obligated to fulfill periodic investment activity reporting requirements in Vietnam on a quarterly and annual basis.

Through these reports, competent state authorities are able to monitor project implementation status, capital contribution progress, business performance, labor utilization, and other technical-economic indicators of the investment project.

2. Are investment activity reports and investment monitoring and evaluation reports the same?

No.

These are two distinct and independent categories of reports, each serving different regulatory purposes.

Investment activity reports reflect the status of project implementation and the enterprise’s operational performance during the reporting period, covering such matters as disbursed investment capital, revenue, profit, labor, import-export activities, and other relevant economic indicators.

Investment monitoring and evaluation reports, on the other hand, focus on assessing project implementation progress, the degree of attainment of investment objectives, investment efficiency, and compliance with applicable laws throughout the course of project execution.

3. What are the deadlines for submitting investment activity reports and investment monitoring and evaluation reports?

Under current regulations, FDI enterprises must observe the following key deadlines:

Investment activity reports (project implementation status reports):

• Quarterly report: On or before the 10th day of the first month of the immediately succeeding quarter.
• Annual report: On or before 31 March of the year immediately following the reporting year.

Investment monitoring and evaluation reports:

• Quarterly report: On or before the 10^th day of the first month of the immediately succeeding quarter.
• Semi-annual report: On or before 10 July of the reporting year.
• Annual report: On or before 10 February of the year immediately following the reporting year.
• In the event of project adjustment: The investor must submit the relevant report prior to filing the application for project adjustment in accordance with applicable regulations.

4. In what form must enterprises submit their reports?

Investment activity reports:

Enterprises shall complete and submit their reports online through the National Information System on Investment as directed by the investment management authority.

Investment monitoring and evaluation reports:

Investors shall submit their reports to the investment registration authority in the form prescribed by the competent authority at the applicable time.

Enterprises are advised to regularly consult with their local investment registration authority to ensure full compliance with the applicable submission procedures.

5. Are enterprises required to submit ad hoc reports?

Yes. In addition to periodic reporting obligations, competent state authorities may require enterprises to submit ad hoc reports when necessary.

Such requirements typically arise when the regulatory authority needs to verify project-related information, assess implementation progress, or conduct inspection and examination activities.

6. What are the potential consequences of non-compliance with reporting obligations?

Enterprises that fail to submit reports, submit reports late, or provide incomplete or inaccurate disclosures may be subject to administrative penalties in accordance with applicable law.

Under Decree No. 122/2021/NĐ-CP on administrative sanctions in the field of planning and investment:

• Failure to submit or late submission of an investment monitoring and evaluation report may result in a monetary fine ranging from VND 20,000,000 to VND 30,000,000 per violation.
• Failure to submit or late submission of an investment activity report may result in a monetary fine ranging from VND 30,000,000 to VND 50,000,000 per violation.

In addition, non-compliance with reporting obligations may adversely affect the enterprise’s ability to carry out subsequent investment procedures, including the adjustment of the Investment Registration Certificate (IRC) or other administrative procedures related to the project.

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