Foreign-invested enterprises (FIEs) in Vietnam file a long list of reports every year: financial statements, tax returns, investment activity reports. Among them, the investment supervision and assessment report is the one most often missed, because its form, frequency and filing system all changed in 2026.
Under Circular No. 44/2026/TT-BTC of the Ministry of Finance on investment supervision and assessment report forms and online reporting, investors now use a single form, Form No. 13, filed quarterly and annually. This replaces the previous regime of two forms filed every six months and annually.
Key changes at a glance
| Item | Previous rules (Circular 05/2023/TT-BKHDT) | Current rules (Circular 44/2026/TT-BTC) |
|---|---|---|
| Forms | Two forms: Form 13 (implementation stage) and Form 17 (operation stage) | One form: Form 13, covering both project implementation and operation |
| Reporting periods | Half-year and annual | Quarterly and annual |
| Periodic report deadline | Half-year report: before 10 July | Quarterly report: before the 10th day of the first month of the following quarter |
| Annual report deadline | Before 10 February of the following year | Before 10 February of the following year |
| Filing channel | Legacy supervision reporting system | Investment Supervision and Assessment Information System; a user account must be registered first |
| Penalty for late or incomplete filing | Fine of VND 20–30 million (Article 15.1(a), Decree 122/2021/ND-CP) | |
1. What is the investment supervision and assessment report?
It is a periodic report that an investor submits to the investment registration authority to update the status of its project. Under Article 57 of Decree No. 19/2026/ND-CP, investors monitor their own projects and report on implementation progress, capital mobilisation and disbursement, business results, labour, state budget contributions, R&D spending, compliance with land, environmental and conditional business requirements, use of investment incentives, and any difficulties encountered.
For an FIE, the obligation applies to each investment project holding an Investment Registration Certificate (IRC). A company with several projects (for example an original project and an expansion with its own IRC) should prepare a report for each one.
Do not confuse it with the investment activity report filed online on the National Information System on Foreign Investment. These are two separate obligations filed on two separate systems. Completing one does not satisfy the other.
2. Change 1: one form only, Form No. 13
Under the former Circular 05/2023/TT-BKHDT, investors used two forms depending on the project stage: Form 13 for the implementation stage and Form 17 for the operation stage. Operating FIEs had to decide which stage their project was in, and filing the wrong form was common.
Form 13 under Circular 44/2026/TT-BTC, titled “Report on supervision and assessment of investment implementation (Quarter … Year …)”, combines both stages in four sections:
- Project information: investors, project company, and project details per the IRC (objectives, scale, schedule, total investment capital, incentives, conditions). This section is completed only once, in the first period after construction starts or after an amendment changes the project information.
- Project implementation: capital actually contributed and mobilised, business results, labour, state budget payments, R&D spending, environmental spending, project status, use of investment incentives, and difficulties. The form states expressly that this section applies to investors that are economic organisations or individuals, including FIEs.
- Operation: workforce, budget obligations (amounts for the period, cumulative amounts, amounts outstanding and reasons), production and business results (profit or loss), and compliance with land, environment, fire safety, conditional business and IRC requirements.
- Recommendations to the competent authorities, if any.
3. Change 2: quarterly instead of half-yearly
This is the change with the biggest impact on workload. The number of filings per year rises from two (half-year and annual) to five (four quarters plus the annual report).
Deadlines under Article 94.11 of Decree No. 19/2026/ND-CP (as amended by Decree No. 96/2026/ND-CP):
- Quarterly report: before the 10th day of the first month of the following quarter.
- Annual report: before 10 February of the following year, covering 1 January to 31 December.
- Report before a project amendment: before the amendment is submitted.
Indicative filing calendar for FIEs
| Reporting period | Deadline |
|---|---|
| Q3 2026 | Before 10 October 2026 (already passed) |
| Q4 2026 | Before 10 January 2027 |
| Year 2026 | Before 10 February 2027 |
| Q1 2027 | Before 10 April 2027 |
| Q2 2027 | Before 10 July 2027 |
| Q3 2027 | Before 10 October 2027 |
Companies that have not yet filed their Q3 2026 report should do so immediately. Filing late is still better than not filing, since failing to comply with periodic reporting is subject to the same VND 20–30 million fine.
4. Change 3: a new system and a mandatory user account
Circular 44/2026/TT-BTC governs online reporting and the operation of the Investment Supervision and Assessment Information System. Companies no longer file on the legacy system. Instead they must:
- Register a user account following the guidance of the provincial Department of Finance or the industrial zone / economic zone management board where the project is located. In practice in Ho Chi Minh City, account approval takes about 3–5 working days.
- Update full project information on the system (some localities, such as Hai Phong, have issued specific instructions for FDI projects outside industrial and economic zones).
- Prepare and file Form 13 for each quarter and year.
Because account approval takes several days, companies should not wait until the deadline. The Q4 2026 report (due 10 January 2027) falls in the busy year-end period alongside other tax and labour obligations.
5. Penalties
Under Article 15 of Decree No. 122/2021/ND-CP on administrative penalties in planning and investment:
- VND 20–30 million for preparing the investment supervision and assessment report late or with incomplete content, or for failing to comply with periodic reporting.
- VND 30–50 million for failing to file the investment activity report, filing it late, or reporting dishonestly or inaccurately on investment activities.
These fines apply to organisations. Beyond the fine, a poor reporting record can complicate IRC amendments, capital increases or project transfers, as investment registration authorities often check compliance history.
6. Five practical points for FIEs
1 — Figures must reconcile with other reports. Contributed capital should match the direct investment capital account (DICA) and the financial statements. Revenue, profit and taxes paid should match tax filings. Headcount should match social insurance records. Authorities increasingly cross-check data between systems.
2 — Quarterly reports rely on management accounts. Audited figures are only available at year end, so quarterly reports are usually based on management accounts. Keep a reconciliation schedule to explain differences between the annual figures and the sum of the four quarters.
3 — Capital contribution and project schedule. If capital contribution or project implementation lags behind the IRC, the report will show it. Explain the reasons in the difficulties section and consider an IRC amendment rather than waiting for the authority to raise the issue.
4 — Investment incentives. Companies enjoying CIT incentives, land rent exemptions or similar should report on whether they still meet the incentive conditions. Tax authorities may use this information in later audits.
5 — Assign a named owner. With five filings a year, set fixed reminders and a clearly responsible person, especially when the chief accountant or the outsourced accounting provider changes.
7. Form 13 preparation checklist
- User account on the Investment Supervision and Assessment Information System.
- List of all projects holding an IRC.
- Latest IRC for each project (objectives, scale, schedule, total investment capital).
- DICA statements and cumulative contributed capital.
- Revenue, profit and taxes paid for the period and cumulatively.
- Headcount (Vietnamese and foreign) at the reporting date.
- R&D and environmental spending, if any.
- Status of investment incentives and related conditions.
- Difficulties and recommendations, if any.
TrustlineAX helps FIEs register system accounts, prepare and file Form 13, and reconcile the figures with financial statements, tax filings and social insurance records. Contact TrustlineAX for advice.
Disclaimer
This article is based on:
- Circular No. 44/2026/TT-BTC of the Ministry of Finance on investment supervision and assessment report forms, online reporting and the operation of the investment supervision and assessment information system (Form No. 13);
- Decree No. 19/2026/ND-CP (Article 57; Article 94.11 as amended by Decree No. 96/2026/ND-CP);
- Decree No. 122/2021/ND-CP (Article 15) on administrative penalties in planning and investment;
- Circular No. 05/2023/TT-BKHDT (former rules on Forms 13 and 17).
Scope notes:
- This article focuses on the obligations of FIEs as investors. Projects using state capital, PPP projects and projects of state-owned enterprises follow separate rules and schedules.
- Account approval times and technical guidance may differ between localities and between projects inside and outside industrial zones. Check the guidance of the Department of Finance or management board where the project is located.
- The investment activity report on the National Information System on Foreign Investment is a separate obligation not analysed in detail here.
This article is for reference only. It does not replace the original legal texts and does not constitute advice for any specific case. Please check the rules in force at the time of application and consult a professional adviser before making decisions.
TrustlineAX — Tax, accounting and compliance advisory for foreign-invested enterprises in Vietnam.