Beneficial owner information: complete it before the end of 2026.

1. Business registration authorities are asking enterprises to complete their declarations in 2026

Since 1 July 2025, every enterprise must identify and declare its beneficial owners, meaning the individuals who actually own or control it. An enterprise established before that date may add the information at its next change of business registration. As a result, many enterprises have still not declared.

At the end of 2026, the authorities have moved to active review. The Government has set a target for more than 80% of enterprises to complete their beneficial owner information in 2026. The Ministry of Finance has asked provincial business registration offices to step up guidance and inspections until the end of December 2026. The Agency for Private Enterprise and Collective Economy Development has sent the provinces a list of 42,911 enterprises that were established or changed their registration between 1 July 2025 and 7 October 2026 without beneficial owner information, as a priority for inspection.

On that basis, provincial Departments of Finance have asked enterprises to complete the information by a set deadline. How to identify beneficial owners under the three criteria and the group aggregation rule is explained in Beneficial owners of enterprises: three identification criteria.

2. The local deadline takes priority

The requirement applies to enterprises across Vietnam; only the deadline differs by province. An enterprise follows the deadline in the notice of the Department of Finance where its head office is located. Where the province has issued no notice, the enterprise should finish before 15 December 2026, under the general timetable the Ministry of Finance has set for the provinces.

Deadlines announced as at 9 November 2026:

This list is updated as further notices are issued. A local notice may cover only one group of enterprises, as in Hanoi, so an enterprise should check the scope of the notice that applies to it.

3. Three groups of enterprises face different levels of urgency

3.1. Enterprises on the review list should act first

This group covers enterprises that were established or changed their registration from 1 July 2025 but have no beneficial owner information on file. For them, the duty to declare arose when the procedure was carried out. Not having declared may therefore be treated as a breach that has already occurred, not merely a delay in answering the Department of Finance's notice.

3.2. Enterprises established before 1 July 2025 with no change since should declare now

The law lets this group add the information at its next change of registration, or earlier if it chooses. However, an enterprise must provide beneficial owner information when a competent authority asks for it, and the Department of Finance's notice is a request from the business registration authority. An enterprise should not wait for its next change of registration.

3.3. Enterprises that have declared need to notify only when the information changes

According to the Ministry of Finance's guidance, an enterprise that has declared and whose information has not changed does not need to notify again merely because the identification criteria were amended. Family businesses and enterprises with shareholders acting under an agreement should, however, recalculate under the group aggregation rule. If the result differs from the list already declared, the enterprise must notify the change.

4. The update is filed online with two forms

The enterprise files a Notice of change to business registration details together with a List of beneficial owners, using the amended forms issued with Circular No. 121/2026/TT-BTC. If the filer is not the legal representative, a letter of authorisation is attached.

The filing is made through the National Business Registration Information System, signing in with an electronic identification account. Filing online does not mean the application has been accepted. The enterprise should follow up and supplement the file whenever the business registration office asks.

For each beneficial owner, the enterprise declares the full name, date of birth, nationality, ethnicity, sex, contact address, ownership percentage or controlling rights, and identity document details. Where ownership runs through entities abroad, collecting this information usually takes the longest, so the enterprise should send its request to the parent company or investors now.

5. Breaches of the beneficial owner rules carry fines of up to VND 100 million

The fines under Decree No. 288/2026/ND-CP are as follows. They apply to organisations; individuals are fined half.

In addition to the fine, the enterprise is required to add the beneficial owner information.

Missing the Department of Finance's deadline is not a separate fined breach. The notice sets no separate sanction for completing the information after the deadline. However, business registration offices have been asked to carry out inspections until the end of December 2026, starting with enterprises on the review list, and breaches found in an inspection are fined at the levels above.

6. What enterprises should do before the deadline

• Check the enterprise's declaration status on the National Business Registration Information System and against the province's review list.
• Confirm the deadline that applies from the notice of the Department of Finance where the head office is located, or before 15 December 2026 if the province has issued no notice.
• Map ownership and control up to the ultimate individuals, applying the three criteria in order and the group aggregation rule.
• Send information requests now to the parent company, fund or investors abroad, and keep the requests and the replies received.
• Speak in advance with any individual who will be declared under the fallback criterion, and explain what being recorded as a beneficial owner means.
• File early to leave time to supplement the file before the deadline if the business registration office asks.
• Keep the beneficial owner identification file at the enterprise, together with the list filed.