Ho Chi Minh City: Enterprises required to provide beneficial owner information before 12 December 2026
On 30 October 2026, the Ho Chi Minh City Department of Finance issued Official Letter No. 32452/STC-ĐKKD regarding the implementation of requirements for supplementing beneficial owner information of enterprises. Accordingly, enterprises operating in Ho Chi Minh City are required to proactively review, identify and declare their beneficial owner information in accordance with the applicable regulations on enterprise registration.
1. Enterprises Subject to the Information Supplementation Requirement
According to Official Letter No. 32452/STC-ĐKKD, the information supplementation requirement applies to the following two groups of enterprises:
- Enterprises established before 1 July 2025: Enterprises are required to review, identify and supplement their beneficial owner information in accordance with Articles 3 and 4 of Decree No. 296/2026/ND-CP, which amends and supplements Decree No. 168/2025/ND-CP.
- Enterprises established from 1 July 2025 onwards: Where there are changes to beneficial owner information under the new regulations, enterprises must carry out the relevant notification procedures in accordance with Clause 1, Article 52 of Decree No. 168/2025/ND-CP.
2. Required Documents and Submission Procedures
According to the guidance of the Ho Chi Minh City Department of Finance, the dossier for supplementing beneficial owner information comprises:
- Notification of Changes to Enterprise Registration Information – Form No. 12;
- List of Beneficial Owners of the Enterprise – Form No. 10.
These forms are issued together with Circular No. 121/2026/TT-BTC.
Enterprises are required to submit their applications online via the National Public Service Portal or the National Identification Application, using an electronic identification account to access the National Business Registration Information System at: https://dangkyquamang.dkkd.gov.vn.
Where the procedures are carried out by an authorized representative, the enterprise must also prepare an authorization document in accordance with Clauses 1 and 2, Article 12 of Decree No. 168/2025/ND-CP.
3. Deadline for Compliance
The Ho Chi Minh City Department of Finance has requested that enterprises complete the supplementation of their beneficial owner information before 12 December 2026.
In addition, enterprises may combine the supplementation of beneficial owner information with updates to other enterprise registration details, such as their head office address following administrative boundary adjustments or the personal identification numbers of their legal representatives, owners and capital-contributing members.
4. Recommendations from CBI Law Firm
The identification of beneficial owners should not be based solely on the percentage of capital or shares held by an individual. Enterprises must also consider the individual’s actual control over the enterprise in accordance with applicable laws.
Accordingly, enterprises should conduct a comprehensive review of their direct and indirect ownership structures, as well as the actual control and decision-making rights within the enterprise, to accurately identify individuals subject to the declaration requirements.
CBI Law Firm recommends that enterprises proactively review their relevant information, prepare the required documents and complete the relevant procedures within the prescribed deadline, thereby ensuring compliance with enterprise registration regulations and mitigating potential legal risks.
