Don’t Miss These Critical FDI Reporting Requirements

Introduction

Are you fully aware of all FDI reporting requirements in Vietnam that your foreign-invested company must comply with after completing the process of establishing a company in Vietnam? Many foreign investors focus heavily on market entry and business expansion but overlook mandatory reporting obligations until facing unexpected penalties or compliance risks. However, once the company is established, ongoing compliance becomes a critical legal responsibility. Understanding which reports must be submitted, to whom, and under which legal framework is essential for maintaining lawful and sustainable operations. This article provides a comprehensive and practical guide to the most important FDI company reports required under Vietnamese law.

Overview of Mandatory Reports for FDI Companies in Vietnam

Under Vietnamese law, foreign-invested enterprises are subject to several mandatory reporting obligations throughout their operation. These reports are not limited to tax or accounting matters but extend to investment implementation, project supervision, trading activities, and labor management.

In general, the key FDI reporting requirements in Vietnam include: the investment activity report submitted to the investment registration authority; the investment supervision and evaluation report assessing project implementation efficiency; the report on goods purchase, sale, and related trading activities for enterprises holding trading licenses; annual audited financial statements prepared in accordance with Vietnamese Accounting Standards; and periodic labor utilization reports submitted to labor authorities.

Each type of report is governed by different legal frameworks and regulatory authorities. The reporting frequency may be quarterly, semi-annual, or annual, depending on the specific obligation. Failure to comply can result in administrative penalties, reputational damage, and potential complications when applying for project adjustments or license amendments.

Investment Activity Report

Pursuant to the Law on Investment 2020 and its guiding regulations, foreign-invested enterprises are required to submit periodic investment activity reports through the National Investment Information System. This is one of the most essential FDI reporting requirements in Vietnam and applies to all enterprises that have been granted an Investment Registration Certificate.

Specifically, Article 102 of Decree No. 31/2021/ND-CP clearly sets out the reporting content and distinguishes between quarterly and annual reporting obligations.

For the quarterly investment activity report, FDI enterprises must provide information on implemented investment capital, net revenue, export and import activities, labor usage, tax obligations and other contributions to the state budget, as well as the status of land and water surface use where applicable. These indicators enable the investment registration authority to monitor the actual implementation progress and operational results of the investment project in comparison with its registered objectives and schedule.

For the annual investment activity report, enterprises are required to include all indicators reported on a quarterly basis and supplement additional data. This includes information on profit, employee income, expenditures and investments in scientific research and technological development, environmental protection and treatment expenses, and the origin of the technology applied in the project. The annual report therefore provides a more comprehensive overview of the project’s financial performance, technological profile, and socio-economic impact.

Regarding reporting deadlines, quarterly reports must be submitted before the 10th day of the first month of the subsequent quarter, while annual reports must be submitted before March 31 of the year following the reporting year. In addition, when carrying out procedures to adjust an investment project, the investment report in accordance with Decree No. 31/2021/ND-CP must be submitted together with the project adjustment dossier to the competent authority.

Investment Supervision and Evaluation Report

In addition to periodic investment activity reporting, foreign-invested enterprises must comply with regulations on investment supervision and evaluation as prescribed in Decree No. 29/2021/ND-CP. Under this regulation, investment supervision is defined as the activity of monitoring and inspecting investment implementation. Investment supervision includes both the supervision of specific programs and investment projects, as well as overall supervision of investment activities within a given scope.

Investment evaluation, on the other hand, refers to a periodic or ad hoc assessment conducted according to a plan or on an extraordinary basis. Its purpose is to determine the extent to which a project achieves its objectives and specific targets compared to the approved investment decision or state-prescribed evaluation criteria at a certain point in time. Evaluation of investment projects may include initial evaluation, mid-term or phase evaluation, final evaluation upon completion, impact evaluation, and extraordinary evaluation when required.

This reporting obligation is distinct from the investment activity report submitted under Decree No. 31/2021/ND-CP. The supervision and evaluation report is primarily designed to serve the state’s monitoring and assessment of investment performance, ensuring that projects are implemented in line with socio-economic objectives, approved policies, and regulatory standards.

Regarding submission deadlines, program owners, project owners, and investors must comply with the timeline stipulated in Point a, Clause 11, Article 100 of Decree No. 29/2021/ND-CP. Accordingly, the six-month report must be submitted before July 10 of the reporting year; the annual report must be submitted before February 10 of the following year; and a report must also be submitted prior to submitting a dossier for adjustment of the investment program or project.

By clearly distinguishing between investment supervision and investment evaluation, foreign-invested enterprises can ensure full compliance with FDI reporting requirements in Vietnam and maintain transparency throughout the lifecycle of their investment projects.

Report on Goods Purchase, Sale and Related Trading Activities

Pursuant to Point a, Clause 1, Article 40 of Decree No. 09/2018/ND-CP, foreign-invested enterprises are required to submit an annual report on goods purchase and sale activities and activities directly related to the purchase and sale of goods. This report must be submitted before January 31 each year to the competent licensing authority.

This reporting obligation applies to FDI companies engaged in trading and distribution activities in Vietnam, including enterprises that have been granted a Business License or a Retail Outlet Establishment License in accordance with Clause 1, Article 5 of Decree No. 09/2018/ND-CP. These companies must periodically report on their operational performance in relation to trading rights and distribution activities granted under their license.

In addition, the obligation also applies to FDI companies that have not yet been granted a Business License or a Retail Outlet Establishment License under Decree No. 09/2018/ND-CP but whose Enterprise Registration Certificate, Investment Registration Certificate, or equivalent legal documents contain business lines related to goods trading or activities directly related to the purchase and sale of goods that fall within the licensing scope prescribed by the Decree.

Accordingly, even where a separate business license has not been issued, if the registered business lines fall within activities subject to licensing requirements under Decree No. 09/2018/ND-CP, the enterprise remains responsible for complying with the annual reporting regime.

The report on goods purchase, sale and related trading activities plays an important role in enabling state authorities to monitor compliance with market access conditions, trading rights, and retail establishment regulations applicable to foreign-invested enterprises operating in Vietnam.

Financial Statements and Accounting Reporting

Among all FDI reporting requirements in Vietnam, financial statements and accounting reporting are considered one of the most strictly supervised obligations. Under the Law on Accounting 2015 and relevant tax regulations, foreign-invested enterprises must prepare financial statements in accordance with Vietnamese Accounting Standards and maintain proper accounting records throughout their operation.

Annual financial statements are mandatory for all FDI companies, regardless of size, sector, or business scale. These statements provide a comprehensive overview of the enterprise’s financial position, business performance, cash flow, liabilities, and equity structure. In most cases, FDI enterprises are required to have their annual financial statements audited by an independent audit firm before submission to the competent authorities.

In addition to annual financial statements, interim financial statements (mid-year reports) are encouraged to enhance internal financial management and transparency. However, interim reporting is not legally mandatory unless specifically required by other regulations or internal corporate governance rules.

The deadline for submission of annual financial statements depends on the legal form of the enterprise. For FDI companies operating as partnerships, the annual financial statements must be submitted within 30 days from the end of the fiscal year. For FDI companies established in the form of joint-stock companies or limited liability companies, the deadline for submission is no later than 90 days from the end of the fiscal year.

Timely preparation and submission of financial statements are essential not only to ensure compliance with accounting and tax regulations but also to demonstrate transparency in capital contribution, profit distribution, and financial management. Accurate financial reporting also plays a critical role in supporting tax finalization, dividend distribution, and future investment adjustments for foreign-invested enterprises in Vietnam.

Labor Utilization Report

In accordance with the Labor Code 2019 and relevant guidance from competent labor authorities, FDI enterprises are required to submit periodic labor utilization reports as part of their mandatory compliance obligations in Vietnam.

Specifically, foreign-invested companies must submit reports on their labor utilization status on a semi-annual and annual basis to the competent labor authority. The six-month report must be submitted before June 5 of the reporting year, and the annual report must be submitted before December 5 of the same year. These reports are typically filed with the Department of Labor, Invalids and Social Affairs where the enterprise’s head office, branch, or production facility is located.

The labor utilization report provides detailed information on the total number of employees, fluctuations in workforce size, recruitment and termination status, the structure of local and foreign employees, and compliance with labor contract regulations. It may also reflect the enterprise’s implementation of obligations relating to social insurance participation, occupational safety, and lawful employment practices.

By requiring periodic labor reporting, state authorities are able to monitor employment trends, ensure compliance with labor regulations, and oversee the lawful use of foreign workers in Vietnam. For FDI enterprises, timely and accurate submission of the labor utilization report is essential to maintain compliance and avoid complications during inspections or administrative procedures.

Conclusion

Understanding and complying with FDI reporting requirements in Vietnam is essential for ensuring sustainable and lawful operations. From investment activity reports and supervision evaluations to trading reports, audited financial statements, and labor utilization reports, each obligation serves a specific regulatory purpose within Vietnam’s legal framework.

Proper compliance requires not only awareness of reporting categories but also accurate preparation, timely submission, and coordination with multiple authorities. In this article, we have provided a comprehensive overview of the key reports that foreign-invested enterprises must submit.

Green NRJ will support your enterprise in reviewing reporting obligations, preparing compliant documentation, and ensuring that all FDI company reports are submitted accurately and on time. Contact us today to secure full compliance and operate confidently in Vietnam’s evolving regulatory environment.