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Beneficial-owner checklist

Vietnam Beneficial Owner (UBO) Filing Checklist

One-page checklist for companies in Vietnam reviewing or supplementing beneficial-owner (UBO) information: the Decree 296/2026 test, Form 10, deadlines and Decree 288/2026 fines. InTimeVisa is a private consulting firm — not the Vietnamese government. Filings go through the National Business Registration Portal.

  1. Pull the current enterprise registration record and the list of members or shareholders
  2. Map ownership up to each ultimate individual — do not stop at a corporate shareholder or a parent company abroad
  3. Step 1: list individuals owning, directly, indirectly or both, 25% or more of charter capital or voting shares
  4. Check family groups and contractual groups that together reach 25%
  5. Step 2: if no one meets the ownership test, or a 25% holder is not the ultimate owner — identify who actually controls the company (appointing management, amending the charter, financial decisions, reorganising or dissolving)
  6. Step 3: if no one meets either test — declare the manager with the greatest authority (excluding state-capital representatives)
  7. Prepare the list of beneficial owners on Form 10 (Circular 121/2026/TT-BTC): identity details, contact address, basis of ownership or control
  8. If a personal identification number is entered in column 5, leave nationality and ethnicity blank; column 17 records actual control rights
  9. Operating company: add the Form 12 request, plus a power of attorney if someone else files
  10. Company set up before 1 July 2025: supplement before the next registration change — filing a change without it is fined VND 70–100 million (Decree 288/2026/NĐ-CP)
  11. Da Nang: the Department of Finance asks companies to finish before 30 November 2026 (letter 14848/STC-DN&ĐKKD)
  12. When a beneficial owner or ownership percentage changes: notify within 10 days, and keep the list of beneficial owners on file
Have us review your filing → Beneficial owner guide → Official portal ↗

Updated Oct 22, 2026. Basis: Decree 168/2025/NĐ-CP as amended by Decree 296/2026/NĐ-CP; Circular 121/2026/TT-BTC; Decree 288/2026/NĐ-CP.