Every foreign-invested enterprise (FIE) operating in Vietnam must comply with two separate, parallel reporting regimes that are easy to confuse but are not interchangeable: the investment monitoring and evaluation report, and the investment project implementation status report. Filing one does not satisfy the other, and each carries its own forms, deadlines, and administrative fines. This guide sets out both regimes as they stand under Vietnam’s 2026 legal framework, based on the Investment Law No. 143/2025/QH15 and its 2026 implementing decrees and circulars.
Two Parallel Reporting Regimes, Not One
FDI companies frequently assume that a single periodic report covers their investment reporting obligations. In practice, Vietnamese law requires two independent tracks:
- Investment monitoring and evaluation report — tracks the progress and quality of project execution. Legal basis: Decree No. 19/2026/ND-CP, Article 94 (as amended by Decree No. 96/2026/ND-CP, Article 99.6), and Circular No. 44/2026/TT-BTC. Submitted through the Investment Monitoring and Evaluation Operations System (nghiepvugiamsatdautu.mof.gov.vn).
- Investment project implementation status report — statistical reporting on investment activity (capital, revenue, labor, etc.). Legal basis: Investment Law No. 143/2025/QH15, Article 47; Decree No. 96/2026/ND-CP, Articles 94 and 96; and Circular No. 55/2026/TT-BTC. Submitted through the National Investment Information System.
When a legal document is amended, the rule is to always apply the most recent version (Decree 19/2026, Article 99.3; Circular 44/2026, Article 15.3). The effective dates matter here: Law 143 took effect March 1, 2026 (with Article 7 and Appendix IV effective July 1, 2026), followed by Decree 19 (January 14, 2026), Decree 96 (March 31, 2026, with Articles 11-12 effective July 1, 2026), Circular 44 (April 22, 2026), and Circular 55 (May 15, 2026).
Investment Monitoring and Evaluation Reports
FDI companies are only responsible for preparing three of the forms in this framework — a point worth stressing, since two of the officially numbered forms are commonly mistaken for enterprise obligations (see below).
Quarterly and Annual Reports
Filed 5 times a year (4 quarterly reports plus 1 annual report) using Form No. 13 (for investors). Quarterly reports are due before the 10th of the first month of the following quarter; the annual report is due before February 10 of the following year. Both are filed with the investment registration authority and the local monitoring and evaluation focal point agency, online via the Operations System. Late or incomplete filing carries a fine of VND 20-30 million.
Semi-Annual Reports
Filed twice a year, also on Form No. 13, due before July 10 (covering data from January 1 to June 30). Note: Decree 19 (Article 94.8(a)) mandates a semi-annual report, but Circular 44 does not provide a distinct semi-annual variant of Form 13 — it only references “quarterly and annual” filing. This is a genuine gap in the current implementing rules that companies should flag with their local investment registration authority rather than assume away.
Pre-Adjustment Reports
Required before submitting a project adjustment application, with no fixed periodic schedule. Filed on Form No. 16. Same fine range applies for late or incomplete filing: VND 20-30 million.
End-of-Project Evaluation
A one-time report filed on Form No. 17 when a project concludes — but only for projects that received an investment policy approval decision. There is no fixed deadline; it is tied to the project’s actual completion date. Same VND 20-30 million fine range applies.
Forms That Are NOT Your Responsibility
Forms No. 14, 15, and 18 are frequently mistaken for enterprise filings, but they are not:
- Form 14 is prepared by the investment registration authority / provincial People’s Committee (Circular 44, Article 4.4(b)).
- Form 15 (ad-hoc evaluation) and Form 18 (impact evaluation) are prepared by state investment management agencies, not by enterprises (Decree 19, Article 68.1(b)). Both forms’ letterheads in Circular 44 are addressed to “investment registration authority / state investment management agency,” not to a company name.
Investment Project Implementation Status Reports
This is a distinct, statistics-oriented reporting track — separate forms, separate submission system, separate legal basis — even though one of its deadlines coincides with the monitoring and evaluation report deadline.
Quarterly Reports
Filed 4 times a year on Form No. I.3.1, due before the 10th of the first month of the following quarter. Submitted to the investment registration authority and the local statistics agency via the National Investment Information System. Fine for late or missing filing: VND 30-50 million.
Annual Reports
Filed once a year on Form No. I.3.2, due before March 31 of the following year. Same submission channel and fine range as the quarterly report.
Ad-Hoc Reports
Required only when requested by a competent authority, with no dedicated form identified in Circular 55 and no specified submission channel in the current implementing rules. Fine range: VND 30-50 million.
Pre-Implementation Reports
A one-time report on Form No. I.3.3, required only for projects that are not subject to an Investment Registration Certificate, due before project implementation begins. Unlike the quarterly and annual reports, this one is filed directly per the form’s addressee line rather than mandatorily through the National Investment Information System. Fine range: VND 30-50 million.
Forms I.3.4 and I.3.5 apply only to oil and gas sector projects and are not relevant to most FDI companies. Also worth noting: the quarterly deadline for this report track falls on the same date as the quarterly monitoring and evaluation report — but the two must still be filed separately, not combined into one submission.
Penalties for Late or Inaccurate Reporting
Under Decree No. 122/2021/ND-CP, Article 15 (administrative penalties in the planning and investment sector), which remains the governing penalty decree as of mid-2026 (its intended replacement is still in draft form and has not been issued):
- Clause 1 (monitoring and evaluation reports): VND 20,000,000-30,000,000 for late filing, incomplete content, or failing to file a periodic report.
- Clause 2 (investment activity reports): VND 30,000,000-50,000,000 for failing to report, late filing, or dishonest/inaccurate reporting.
These fines apply to organizations; individuals face half the organizational fine. This penalty information comes from a secondary legal research source rather than the five core legal documents underlying this article, so it’s worth confirming against the official Gazette text or your legal counsel before relying on it for a specific case.
How to Register an Account for the Monitoring and Evaluation System
Circular 44/2026/TT-BTC, Article 11 sets out the registration process for nghiepvugiamsatdautu.mof.gov.vn:
- Determine whether you already hold a digital signature (CKS). If not, declare your information at taikhoan.mof.gov.vn.
- If you have a CKS, register online at taikhoan.mof.gov.vn — an account is issued within 1 business day of completing registration.
- If you don’t have a CKS (Option 1): contact your managing authority to confirm your registration details — account issued within 1 business day of confirmation.
- If you don’t have a CKS (Option 2): print the registration form, have it signed and stamped by your legal representative, and email a scanned color copy to hotroungdung@mof.gov.vn — account issued within 1 business day of receipt.
- Receive your account credentials via the email address you registered.
- Change your initial password within 1 business day of receiving your account.
- Log in at nghiepvugiamsatdautu.mof.gov.vn to submit reports (Forms 13, 16, and 17).
A few operational details worth knowing: the registration system cross-checks personal information against the national population database; your account can be revoked on written or digitally-signed request from your managing authority, or locked immediately if it’s used for data destruction, attacks, or system scanning; passwords should never be shared, and if the person handling submissions changes, the new user must reset the password and update their information; and if you forget your password, recovery is based on the information you originally declared at registration.
Quick comparison of the two reports
| Criterion | Investment monitoring & evaluation report (Circular 44/2026) | Project implementation status report (Circular 55/2026) |
|---|---|---|
| Underlying basis | Articles 94 and 95 of Decree 19/2026/ND-CP (as amended by Decree 96/2026/ND-CP) | Point a, clause 2, Article 47 of Investment Law 143/2025/QH15; Articles 94 and 96 of Decree 96/2026/ND-CP |
| Who prepares it | The investor | The economic organisation implementing the project, signed by its legal representative |
| Main forms | Form 13 with sub-schedules 13.1.x; Form 16 before adjustment; Form 17 on completion | Form I.3.1 quarterly; Form I.3.2 annually |
| Filing system | Investment monitoring and evaluation information system | National investment information system |
| Receiving authority | Investment registration authority; the focal agency for investment monitoring and evaluation | Investment registration authority; the local statistics office |
| Filing deadline | The Circular gives no specific date; it refers to Decree 19/2026/ND-CP as amended | Quarterly: before the 10th of the first month of the following quarter. Annual: before 31 March |
| Main unit of measure | VND million | USD |
| Content focus | Project implementation, operation, and compliance with law on land, environment, business conditions and investment incentives | Statistical data: capital contributed by each investor, loans, revenue, imports and exports, labour, energy, budget payments |
| Penalty reference | Article 97 of Decree 19/2026/ND-CP | No penalty provision |
Three points companies most often miss
1. Projects already operating must also load their data
Under Article 16 of Circular 44/2026/TT-BTC, projects under the Investment Law that were already being implemented or already in operation before the Circular took effect must still enter their project information and data into the system.
Many long-established FDI companies assume the new rules apply only to newly licensed projects. They do not. Companies already operating are in scope, and back-loading historical data usually takes longer than expected.
2. Two different units of measure — where inconsistent figures come from
Form 13 under Circular 44 reports many indicators in VND million. Forms I.3.1 and I.3.2 under Circular 55 report mainly in USD.
For the same budget payment or the same revenue figure, if two teams prepare the two reports at two different times using two different exchange rates, the numbers will not match. When the authorities cross-check, an unexplained difference is an easy question to be asked. Agree a single source of truth — the accounting ledger, the financial statements and the tax returns — and record the exchange rate and conversion date used.
One calculation note: under the Circular 55 form’s guidance, “loan capital” is total borrowings in the period less repayments in the period, covering short, medium and long-term loans — not the closing loan balance.
3. Periodic reporting compliance is checked when you amend a licence
Form I.1.9 under Circular 55 — filed with the application when seeking an investment registration certificate for a project already under way, or when adjusting, transferring, contributing capital to or extending a project — contains an item requiring the company to report on its registration of a project implementation reporting account on the Ministry of Finance website.
In other words, your periodic reporting status can be reviewed at exactly the moment you need to amend your licence. That is the most practical reason not to let reporting arrears accumulate.
What the two Circulars do not make clear
To avoid speculation, the following cannot be concluded from the text of the two Circulars alone:
- The filing deadline under Circular 44. Clause 4 of Article 7 gives no specific date, referring instead to point a, clause 11, Article 94 of Decree 19/2026/ND-CP as amended. The Decree must be consulted directly.
- Do not confuse it with the authorities’ own deadline. Clause 3 of Article 13 of Circular 44 mentions “before the 20th of the first month of the following quarter, and before 15 February of the following year for the fourth quarter” — that is the deadline for the provincial People’s Committee to review and consolidate, not the investor’s deadline.
- Who signs Form 13 where the investor is a foreign legal entity. Circular 44 uses the term “investor”; Circular 55 uses “economic organisation implementing the project”. Circular 44 does not state whether the Vietnamese FDI company may sign on behalf of the foreign investor.
- Data sharing between the two systems. Circular 44 assigns a specialist unit to lead the interconnection of information between the Ministry of Finance’s systems, but it does not say that this exempts a company from filing either of the two reports.
- The specific form and level of penalties. Circular 44 refers only to Article 97 of Decree 19/2026/ND-CP; Circular 55 does not address penalties.
Frequently Asked Questions
What’s the difference between the two reporting regimes?
The monitoring and evaluation report tracks how well a project is being executed (progress, quality); the implementation status report is a statistical filing on investment activity (capital, revenue, labor). They have different legal bases, different forms, and different online submission systems.
Do I need to file both reports if their deadlines are the same date?
Yes. Both the quarterly monitoring and evaluation report and the quarterly implementation status report are due before the 10th of the month following the reporting quarter — but they must be submitted separately, through their own respective systems.
What happens if I miss a reporting deadline?
Under Decree 122/2021/ND-CP, Article 15, late or incomplete monitoring and evaluation reports carry a fine of VND 20-30 million, while late or inaccurate implementation status reports carry a fine of VND 30-50 million (organizational rate; individuals pay half).
Are Forms 14, 15, and 18 something my company needs to file?
No. These three forms are prepared by state agencies (the investment registration authority or provincial People’s Committee), not by enterprises, even though they appear in the same numbered set as the forms companies do file.
How do I get an account to submit monitoring and evaluation reports?
Register at taikhoan.mof.gov.vn if you hold a digital signature, or follow the paper-based confirmation process with your managing authority if you don’t. Accounts are typically issued within 1 business day once registration is confirmed.
Related Resources
- Annual Compliance Calendar 2026 for FDI Companies in Vietnam
- Vietnam Tax Deadline Schedule 2026
- Vietnam Tax Compliance Services for FDI Companies
Get Expert Advice on Investment Reporting Compliance
Two overlapping reporting tracks, forms that look alike but serve different purposes, and gaps between when an obligation takes effect and when the matching form exists — getting this wrong is easy, and the fines add up quickly across two regimes. If you’d like help setting up your reporting calendar or registering for the online systems, our team can walk you through it. Contact us.