Situation: “We are a state-owned enterprise (currently having a major infrastructure project utilizing on-lent funds from foreign loans). Recently, the finance department received information that the Ministry of Finance has promulgated a new regulation wholly amending the forms for public debt reporting and mandating the calculation of risk indicators. Please advise us on the key new points, the risks in the event of submitting the incorrect form, and the action plan to be executed immediately to meet the upcoming reporting period?”
Answer: Below is the detailed advice regarding the new regulation on forms for public debt information reporting and risk indicators pursuant to Circular 47/2026/TT-BTC.
- Main contents
Circular 47/2026/TT-BTC re-prescribes the set of forms for public debt reporting and risk indicators of the Government debt portfolio, specifically including the following core contents:
- Reporting on annual plans for borrowing and repayment of public debt: Use 09 forms in Appendix I, submit to the Ministry of Finance / the Department of Debt Management and External Finance according to the deadline of each form. (Legal basis: clause 1 Article 3 of Circular 47/2026/TT-BTC).
- Reporting on 05-year plans for borrowing and repayment of public debt: Use 08 forms in Appendix II. (Legal basis: clause 2 Article 3 of Circular 47/2026/TT-BTC).
- Supplementing the requirement on advance calculation of risk indicators: Expectedly calculate the risk indicators of the Government debt portfolio to serve the announcement of annual plans for borrowing and repayment of debt. (Legal basis: Article 5 of Circular 47/2026/TT-BTC).
- Accepting electronic reports: The form of report submission may be accepted as electronic documents; data shall match the dossierson borrowing, debt repayment, guarantee, on-lending, and budget accounting. (Legal basis: clause 1 Article 4 of Circular 47/2026/TT-BTC).
- Major impacts
The new regulation primarily impacts state-owned enterprises, entities guaranteed by the Government, entities having foreign loan on-lending, and the public finance departments within corporations having major infrastructure projects. Data on debt, maturity terms, interest rates, guarantees, and debt repayment obligations shall be further standardized to serve the tasks of appraisal, auditing, and reporting to management agencies.
- Risks of non-compliance
- Incorrect reporting forms or lack of debt data: May be subject to requirements for explanation, return of dossiers, or prolonged approval of borrowing plans.
- Failure to monitor risk indicators of the debt portfolio: Directly impacts borrowing limits, guarantees, and internal credit ratings.
- Proposed action plan
- Review all debt obligations, on-lent loans, guarantees, and debt repayment schedules according to the new forms (09 annual forms and 08 05-year forms).
- Standardize financial and accounting data sources to submit electronic reports strictly on time and matched with the borrowing dossiers and budget accounting.
- Notes and recommendations for clients
- Establish an internal data reconciliation mechanism: Because the new regulation permits the submission of electronic reports but mandates that the data shall completely match the dossiers on borrowing, guarantee, and budget accounting, the enterprise shall establish a cross-checking process between the Accounting Department and the Project Management Board prior to submission. Avoid the situation where the actual disbursement figures deviate from the public debt reporting figures.
- Expiration of old forms: Clients shall remind the specialized departments to absolutely not reuse the old reports. This Circular has fully replaced Circular 84/2018/TT-BTC and Circular 05/2024/TT-BTC, mandating the use of 17 new forms commencing on May 12, 2026.
