Question: As an FDI enterprise preparing to submit an application dossier for investment project adjustment and implement periodic reports, I recently heard that the Ministry of Finance has just promulgated new forms replacing all forms of previous investment procedures. Could the expert provide clear advice on the core new points, the risks if incorrectly submitting the old forms, and how our legal and project departments shall immediately act to prevent affecting the project schedule?
Answer: Below is the detailed advice regarding the new regulations on the administration of investment forms pursuant to Circular 55/2026/TT-BTC (effective from May 15, 2026):
1/ Main contents
– Broad scope of regulation and subjects of application: Comprehensively applying to all investors implementing investment activities in Vietnam; State management agencies in charge of investment and investment promotion; and any other organizations and individuals related to investment and investment promotion activities.
(Pursuant to Article 1 and Article 2 of Circular 55/2026/TT-BTC)
– Promulgation of a system of 91 new forms: Announcing a new system of forms including Appendix I stipulating the forms of documents and reports related to investment activities in Vietnam (containing 75 forms divided into 04 groups: applying to investors, to management agencies, periodic reports of economic organizations, and periodic reports of management agencies); Appendix II stipulating the forms of documents related to investment promotion activities (containing 16 forms).
(Pursuant to Clause 1 and Clause 2 Article 3 Circular 55/2026/TT-BTC)
– Effect of enforcement and annulment of old documents: The Circular takes effect immediately from the date of signing and annuls all 03 old Circulars previously promulgated by the Minister of Planning and Investment (including Circular 03/2021/TT-BKHĐT, Circular 25/2023/TT-BKHĐT, and Circular 06/2025/TT-BKHĐT).
(Pursuant to Clause 1 Article 5 of Circular 55/2026/TT-BTC)
2/ Greatest impacts
Circular 55/2026/TT-BTC creates a direct and immediate impact on all investors, project companies, FDI enterprises, investment consulting units, and specialized M&A legal departments. The conversion of forms to the standards of the Ministry of Finance obliges enterprises to re-establish the entire internal dossier database, from project proposals and project adjustments to operation reports. Transactions in the stage of dossier preparation but not yet officially submitted have a high probability of having to be redrafted according to the new forms to ensure validity.
3/ Risks of non-compliance
– Dossiers submitted according to the old forms of the Ministry of Planning and Investment shall easily be refused for receipt by State agencies, considered invalid, or subjected to multiple rounds of modification and supplementation, causing time consumption.
– The inconsistency of investment reporting forms shall delay subsequent core legal procedures such as project adjustments, M&A procedures (capital contribution, share purchase), or the licensing of new projects.
4/ Proposed action plans
– Rapidly replace the entire set of old investment dossier forms in the company’s legal checklist with the new forms pursuant to Appendix I and Appendix II of Circular 55/2026/TT-BTC.
– Urgently review the project dossiers being drafted or in the process of submission to promptly convert to the new forms prior to the official submission to the functional agencies.
5/ Notes and recommendations for clients
– Transitional regulations for dossiers submitted prior to May 15, 2026: For valid dossiers using the old forms which have been received by State agencies prior to the effective date of Circular 55 but have not yet returned results, such dossiers shall continue to be processed normally. However, after the effective date of the Circular, State agencies shall only resolve dossiers using the new forms.
(Pursuant to clause 2 Article 5 of Circular 55/2026/TT-BTC)
– Notes upon declaring the Personal identification number: In the new forms (such as Form I.1.1, I.1.4…), investors holding Vietnamese nationality only need to provide full name, identification number, address, and contact information. Particularly, individual investors and representatives holding foreign nationality shall mandatorily fully fill in the date of birth, nationality, gender, and Passport number.
(Pursuant to Note No. 1 in the Forms under Appendix I of Circular 55/2026/TT-BTC)
– Mandatory registration for an account on the National Investment Information System: Upon requesting the issuance or adjustment of the Investment Registration Certificate, the economic organization/investor is bound by the regulation to carry out the procedures for registering an account for use on the State’s management platform.
(Pursuant to clause 1 Article 3 of Form I.2.6 Appendix I of Circular 55/2026/TT-BTC)
