GUIDANCE ON INVESTMENT MONITORING REPORTS

FOR FDI ENTERPRISES IN VIETNAM

Pursuant to Circular No. 44/2026/TT-BTC

INTRODUCTION

Investment monitoring reports are a mandatory legal obligation for foreign direct investment (FDI) enterprises operating in Vietnam. In the context of continuous reforms to the investment legal framework, on 22 April 2026, the Minister of Finance issued Circular No. 44/2026/TT-BTC prescribing templates for investment monitoring and evaluation reports; the online reporting regime; and the management and operation of the Investment Monitoring and Evaluation Information System. This instrument supersedes Circular No. 05/2023/TT-BKHDT and comprehensively updates requirements arising from Decree No. 19/2026/ND-CP, the Law on Investment 2025, and related legislation. This document presents the core provisions of Circular 44/2026/TT-BTC that FDI enterprises must understand in order to comply with the investment monitoring reporting regime in Vietnam.

LEGAL BASIS

• Law on Investment No. 143/2025/QH15 dated 11 December 2025 (Law on Investment 2025), effective from 1 March 2026;
• Decree No. 19/2026/ND-CP dated 14 January 2026 of the Government prescribing procedures and processes for the appraisal of national important projects and for investment monitoring and evaluation (as amended and supplemented by Decree No. 96/2026/ND-CP);
• Circular No. 44/2026/TT-BTC dated 22 April 2026 of the Minister of Finance prescribing templates for investment monitoring and evaluation reports; the online reporting regime; and the management and operation of the Investment Monitoring and Evaluation Information System;
• Decree No. 122/2021/ND-CP dated 28 December 2021 of the Government on administrative penalties in the fields of planning and investment.

I. OVERVIEW OF CIRCULAR 44/2026/TT-BTC

1.1. Scope of Regulation

Circular 44/2026/TT-BTC governs two principal subject matters:

• Templates for investment monitoring and evaluation reports in accordance with Article 94 of Decree No. 19/2026/ND-CP, as amended and supplemented by Decree No. 96/2026/ND-CP;
• The investment monitoring and evaluation reporting regime conducted through the Business Information System, pursuant to Article 95 of Decree No. 19/2026/ND-CP as amended and supplemented by Clause 7, Article 99 of Decree No. 96/2026/ND-CP.

Circular 44/2026/TT-BTC also applies to projects funded by official development assistance (ODA) and concessional loans from foreign donors. For this category of projects, the relevant parties shall use the reporting templates prescribed in the Circular; special issues shall be governed by the applicable regulations on ODA and concessional loan utilisation (Decree No. 242/2025/ND-CP).

1.2. Subjects of Application

Circular 44/2026/TT-BTC applies to all agencies, entities, organisations, and individuals involved in the preparation and submission of investment monitoring and evaluation reports, ensuring comprehensive and systematic coverage.

Specifically, the following parties are required to prepare and submit investment monitoring and evaluation reports under the Law on Investment 2025:

• Programme owners and investors in public investment projects;
• Users of public investment projects;
• Investors in projects utilising state capital other than public investment capital;
• Investors implementing PPP projects;
• Investors in projects utilising other sources of capital.

Accordingly, FDI enterprises (foreign-invested enterprises) fall within the scope of entities obligated to submit investment monitoring and evaluation reports.

Note: The Circular does not apply to outbound investment projects. Projects funded by ODA shall comply with the templates prescribed in this Circular, while specific matters shall be governed by Decree No. 242/2025/ND-CP.

II. REGULATION ON INVESTMENT MONITORING AND EVALUATION REPORT TEMPLATES

2.1. Report Templates Required of FDI Enterprises

Pursuant to Clause 4, Article 4 of Circular 44/2026/TT-BTC, FDI enterprises are required to prepare and submit the following investment monitoring and evaluation reports:

Template No.	Report Title	Applicable Entity
Template No. 13	Investment monitoring and evaluation report on project implementation status (comprising implementation progress and operational performance)	Investor (FDI enterprise)
Template No. 14	Investment monitoring and evaluation report on overall investment situation (submitted to the business registration authority and the provincial People’s Committee)	Investment registration authority; Provincial People’s Committee
Template No. 15	Ad hoc evaluation report	Investor (upon request)
Template No. 16	Pre-amendment investment monitoring and evaluation report (submitted prior to any project adjustment)	Investor
Template No. 17	Project completion evaluation report	Investor (upon project completion)
Template No. 18	Impact assessment report	Upon occurrence, as required

Accordingly, Template No. 13 is the mandatory template for periodic submission (quarterly and annually). Templates No. 15, 16, 17, and 18 arise on a case-by-case basis depending on the specific circumstances of each project. Template No. 14 is not an obligation of the FDI enterprise itself but falls within the responsibility of the competent state management authority.

2.2. Reporting Deadlines

Decree No. 19/2026/ND-CP — the primary instrument referenced by Circular 44/2026/TT-BTC — sets out specific deadlines for investment monitoring and evaluation reporting under Point (a), Clause 11, Article 94 (as amended by Point (d), Clause 6, Article 99 of Decree No. 96/2026/ND-CP). The following table summarises the applicable reporting deadlines for investors:

Report Type	Submission Deadline	Reporting Data
Quarterly Report	By the 10th day of the first month of the quarter following the reporting quarter	Data by quarter
Semi-Annual Report	By 10 July of the reporting year	1 January to 30 June of the reporting year
Annual Report	By 10 February of the following year	1 January to 31 December of the reporting year
Pre-Amendment Report	Prior to submission for project adjustment approval	—

III. REPORTING PROCEDURES FOR FDI ENTERPRISES

1.     Investment Monitoring and Evaluation Information System

Circular 44/2026/TT-BTC establishes the Investment Monitoring and Evaluation Information System, which comprises:

• The National Information Portal (for public disclosure of investment information);
• The Business Information System, accessible at: https://nghiepvugiamsatdautu.mof.gov.vn
• The Account Management System, accessible at: https://taikhoan.mof.gov.vn

FDI investors are required to conduct all reporting activities online through the System. Electronic reports bearing a valid digital signature carry the same legal effect as paper-based reports.

2.     Online Submission Procedure

Circular 44/2026/TT-BTC specifies the procedures for data entry, reporting updates, and investor reporting obligations on the Investment Monitoring and Evaluation Information System. The procedure consists of the following steps:

2.1.         Step 1 – System Account Registration and Activation

FDI enterprises (investors or project companies) are required to:

• Obtain a valid digital signature (a recognised public digital certificate) for use on the System;
• Access https://taikhoan.mof.gov.vn and complete the investor/project company registration;

Proceed by one of the following methods:

• Option 1: Contact the line authority or investment registration authority to confirm account registration on the System; or
• Option 2: Print the Account Registration Form, have it signed and stamped by the legal representative, scan it in colour, and submit by email to the Ministry of Finance as instructed.

The Ministry of Finance will activate accounts within one (1) working day of receiving complete and valid information; credentials will be delivered to the registered email address.

2.2.         Step 2 – Initial Data Entry Upon Selection as Investor

Upon being selected as an investor or upon issuance of an Investment Registration Certificate (IRC), the FDI enterprise must update project information in the System within seven (7) working days from whichever of the following occurs first:

• The date of the decision approving the investment policy and simultaneously approving the investor; or
• The date of the decision selecting the investor to implement the project; or
• The date of issuance of the Investment Registration Certificate (IRC).

Supporting legal documents must be attached (investment policy decision, investor selection decision, IRC, etc.) in the form of colour scans or digitally signed electronic documents.

2.3.         Step 3 – Periodic Updates During Project Implementation

During the implementation of an FDI project, the investor is required to fulfil two primary reporting obligations:

• Quarterly periodic reports:

• Capital disbursement status;
• Construction, procurement, and installation progress;
• Operational indicators (if part of the project has commenced operations).

Submit the investment project implementation status report (Template No. 13) via the System to:

• The investment registration authority (the Department of Planning and Investment or the Industrial Zone/Economic Zone Management Authority); and
• The investment monitoring and evaluation focal point authority.
  • Annual consolidated reports:

On an annual basis, compile full-year data (capital disbursed, business results, workforce, state budget obligations, research and development expenditure, environmental performance, etc.) and prepare the annual investment monitoring and evaluation report (Template No. 13) for submission via the System to the competent authorities.

2.4.         Step 4 – Reporting Upon Project Completion

Upon completion of the FDI project, after the project’s financial settlement has been approved by the competent authority (if applicable), the investor must:

• Update the project settlement data in the System within seven (7) working days;
• Prepare the Project Completion Evaluation Report (Template No. 17) and submit it via the System to the competent authority.

2.5.         Step 5 – Reporting During the Operational Phase

After the FDI project commences operations, the investor must periodically (quarterly and annually) update information and data in the System, and prepare investment monitoring and evaluation reports on operational performance, covering:

• Capital investment (supplemental or expansion);
• Business and investment performance (revenue, profit, etc.);
• Workforce size and composition;
• State budget contributions;
• Research and development (R&D) expenditure;
• Environmental management and protection;
• Sector-specific performance indicators relevant to the enterprise’s field of activity.

Where a more in-depth assessment of the project’s effectiveness and impact (economic, social, environmental, etc.) is required, the investor shall prepare an Impact Assessment Report (Template No. 18).

IV. LEGAL CONSEQUENCES FOR NON-COMPLIANCE WITH INVESTMENT MONITORING REPORTING OBLIGATIONS

Clause 3, Article 10 of Circular 44/2026/TT-BTC explicitly provides that: investors, project owners, or component project owners who fail to fulfil their reporting obligations in full shall be subject to penalties pursuant to Article 97 of Decree No. 19/2026/ND-CP.

Under Article 97 of Decree No. 19/2026/ND-CP, violations in investment monitoring and evaluation are subject to the following sanctions:

• Agencies, organisations, and individuals found to have concealed violations shall, depending on the nature and severity of the conduct, be subject to disciplinary action, administrative penalties, or criminal prosecution; if damage has been caused, compensation shall be made in accordance with applicable law.
• Administrative penalties shall be imposed in accordance with the legislation on administrative penalties in the fields of planning and investment.

Specific administrative penalty levels applicable to FDI enterprises for non-compliance with investment monitoring reporting obligations (Art.10 of Decree No.122/2021/ND-CP) are as follows:

Violation	Administrative Fine	Remedial Measure
Submission of report outside the prescribed deadline or with incomplete content	VND 20,000,000 – 30,000,000	Compulsory supplementation of report with complete and accurate content
Failure to upload report to the National Information System	VND 20,000,000 – 30,000,000	Compulsory upload to the System
Failure to comply with the periodic investment monitoring reporting regime	VND 30,000,000 – 50,000,000	Compulsory compliance with the prescribed periodic reporting regime
Preparation of inaccurate or misleading reports	VND 30,000,000 – 50,000,000	—

 

CONCLUSION

Circular 44/2026/TT-BTC marks a significant advancement in the regulatory framework governing investment monitoring reports in Vietnam. For FDI enterprises, a thorough understanding of the scope of application, the system of reporting templates, submission deadlines, and online update obligations is a prerequisite for ensuring compliance and maintaining stable investment operations. With a comprehensive structure of 19 reporting templates classified in detail by project type, the Circular requires FDI enterprises to accurately identify the applicable templates corresponding to the nature of their respective projects. In cases of uncertainty regarding the application of investment monitoring reporting regulations, enterprises are advised to seek guidance from qualified legal professionals or the relevant investment registration authority.