New Regulations on Investment Monitoring & Evaluation Report Templates and Mandatory Quarterly Reporting for FDI Investors in Vietnam from 2026

27-04-26 Việt Quang

Circular 44/2026/TT-BTC introduces 19 new report templates; Decree 96/2026/NĐ-CP mandates quarterly reports for non-state capital and FDI investors for the first time

On 22 April 2026, the Ministry of Finance issued Circular 44/2026/TT-BTC, effective immediately, introducing 19 entirely new investment monitoring and evaluation report templates applicable to all investment programs and projects in Vietnam. Concurrently, Decree 96/2026/NĐ-CP (31 March 2026) introduces a new obligation: investors in projects using non-state capital — including FDI enterprises — must now submit quarterly investment monitoring reports for the first time, replacing the previous regime that only required semi-annual and annual reports. This change directly affects thousands of foreign-invested enterprises currently operating in Vietnam.

I. LEGAL FRAMEWORK: THREE INTERLOCKING INSTRUMENTS

The 2026 investment monitoring and evaluation regulatory framework rests on three interconnected legal instruments:

Decree 19/2026/NĐ-CP (14 January 2026): The framework decree governing procedures for appraising nationally significant projects and the entire investment monitoring and evaluation system. Article 94 of this Decree is the primary provision on investors’ reporting obligations.
Decree 96/2026/NĐ-CP (31 March 2026): The decree guiding the implementation of the Investment Law 2025. Clause 6(c), Article 99 inserted Clause 8 into Article 94 of Decree 19 — establishing for the first time the obligation for non-state capital investors (including FDI enterprises) to submit quarterly reports.
Circular 44/2026/TT-BTC (22 April 2026, immediate effect): The most recent instrument, providing specific report templates, online reporting requirements and the management of the investment monitoring information system. This Circular replaces all previous report forms, creating a unified national template set.

II. 19 NEW REPORT TEMPLATES UNDER CIRCULAR 44/2026/TT-BTC

Circular 44/2026/TT-BTC introduces 19 report templates and annexes, categorised by function and applicable at different project stages and for different project types:

Group 1 — Consolidated System-Wide Reports:

Template No. 01: Annual consolidated investment monitoring and evaluation report — prepared by state management agencies, consolidating all investment activities within their jurisdiction.
Template No. 10: Consolidated report on investment monitoring and evaluation activities — for line ministries and economic zone management boards.

Group 2 — Public Investment Project Stage Reports:

Template No. 02: Initial evaluation report — prepared upon project approval and commencement.
Template No. 03: Periodic monitoring and evaluation report during the investment implementation phase.
Template No. 04: Mid-term or phase evaluation report — for multi-phase projects.
Template No. 05: Pre-adjustment monitoring and evaluation report — mandatory when increasing total investment capital or extending the schedule.
Template No. 06: Ad hoc evaluation report — prepared at the request of competent authorities when abnormalities arise.
Template No. 07: Investment completion monitoring and evaluation report — prepared upon full project completion.
Template No. 08: Operations and exploitation monitoring and evaluation report — applicable after the project enters service.
Template No. 09: Impact assessment report — analysing the socio-economic and environmental effects of the project after it is operational.

Group 3 — Reports for Non-State Capital Projects (including FDI):

Templates Nos. 11–19 provide specialised forms for PPP projects, non-state capital projects, and FDI projects, including the new quarterly report template introduced by Decree 96/2026/NĐ-CP.

All reports are submitted online through the national investment monitoring information system administered by the Ministry of Finance, replacing the previous hard-copy submission practice.

III. THE KEY NEW OBLIGATION: MANDATORY QUARTERLY REPORTING FOR NON-STATE CAPITAL AND FDI INVESTORS

Pursuant to Clause 8, Article 94 of Decree 19/2026/NĐ-CP — as inserted by Clause 6(c), Article 99 of Decree 96/2026/NĐ-CP — investors in projects using non-state capital (including FDI enterprises) must now prepare and submit quarterly reports on investment project implementation status. This represents a fundamental shift from the previous reporting regime, which only required semi-annual and annual reports.

Mandatory content of the quarterly report includes:

Investment capital disbursed during the reporting period and cumulatively since project commencement;
Investment and business results (revenue, profit, contributions to the state budget);
Labour information (headcount, nationality, type of employment contract);
Research and development (R&D) investment;
Environmental management and protection measures;
Sector-specific indicators applicable to the project’s field of operation.

IV. REPORTING DEADLINES

Decree 96/2026/NĐ-CP and Circular 44/2026/TT-BTC prescribe the following reporting deadlines:

Report Type	Applicable Entities	Deadline
Quarterly monitoring & evaluation report (NEW)	Non-state capital and FDI project investors	Before the 10th day of the first month of the following quarter (Q1→before 10 April; Q2→before 10 July; Q3→before 10 October; Q4→before 10 January next year)
Semi-annual monitoring & evaluation report	Non-state capital and FDI project investors	Before 10 July each year
Annual monitoring & evaluation report	Non-state capital and FDI project investors	Before 10 January of the following year
Periodic monitoring & evaluation report (public investment)	Project owners, public investment project management boards	As specified by the line ministry/agency
System-wide consolidated report (Template 01)	Ministries, ministerial-level agencies, Provincial People’s Committees	Before 31 March each year (for the previous year)

Note: Reports must be submitted online through the national investment monitoring information system. Where the system is not yet operational, investors may submit electronic copies via email or the competent investment authority’s electronic portal.

V. PRACTICAL IMPACT AND NON-COMPLIANCE RISKS

With tens of thousands of FDI projects and non-state capital enterprises operating in Vietnam, the addition of quarterly reporting creates a significant compliance burden for unprepared businesses:

Increased reporting frequency: From twice per year (semi-annual + annual) to four times per year, requiring continuous and synchronised internal data collection systems.
Broader information scope: Quarterly reports require multi-dimensional data (financial, labour, R&D, environmental) — not merely disbursement figures as many enterprises have assumed.
Mandatory online submission: Enterprises must register accounts and familiarise themselves with the information system operated by the Ministry of Finance under Circular 44/2026/TT-BTC.
Penalties for non-compliance: Late submission, incomplete or inaccurate reporting may result in administrative penalties. Furthermore, applications to amend Investment Registration Certificates or to obtain additional incentives may be rejected if the enterprise has outstanding reporting obligations.

RECOMMENDATIONS FOR FDI ENTERPRISES AND NON-STATE CAPITAL INVESTORS

Immediately review your current reporting obligations: cross-reference Article 94 of Decree 19/2026/NĐ-CP and the new Clause 8 inserted by Decree 96/2026/NĐ-CP to identify all required report types.
Download and familiarise yourself with the 19 new templates in the Annexes to Circular 44/2026/TT-BTC — paying particular attention to the templates applicable to FDI and non-state capital projects.
Prepare Q2/2026 quarterly report data (deadline: before 10 July 2026): begin collecting data from the start of the quarter to avoid last-minute difficulties.
Register an account on the national investment monitoring information system operated by the Ministry of Finance to meet the online submission requirement.
Seek legal advice if you have questions about identifying the correct report types, the scope of information to be declared, or the competent authority to receive your reports.

MT & Partners Law Firm, with a team of experienced lawyers specialising in foreign investment and legal compliance in Vietnam, is ready to assist enterprises with: advising on full compliance with the new monitoring and evaluation reporting requirements; preparing and reviewing quarterly, semi-annual and annual report dossiers; advising on remediation of reporting violations and procedures related to Investment Registration Certificates. Contact our hotline at 0987140772 or email info@mtpartners.vn for a consultation.

(*) This article is for general reference only and does not constitute specific legal advice.

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