Beneficial-owner declarations in Da Nang: what letter 14848 asks companies to do
On 20 October 2026 the Da Nang Department of Finance issued letter No. 14848/STC-DN&ĐKKD asking every company registered in the city to review the information it has filed and submit any missing beneficial-owner information on the National Business Registration Portal, completing it before 30 November 2026. The filing is a Form 12 request plus a Form 10 list of beneficial owners under Circular 121/2026/TT-BTC (121/2026/TT-BTC). This guide explains who counts as a beneficial owner, what to prepare and how to file — including for foreign-invested companies.
What does letter 14848 ask companies to do?
Letter No. 14848/STC-DN&ĐKKD of 20 October 2026 is addressed to all companies in Da Nang. It relies on Decree 168/2025/NĐ-CP on business registration as amended by Decree 296/2026/NĐ-CP (296/2026/NĐ-CP); Ministry of Finance letter 16558/BTC-DNTN of 16 October 2026 on collecting beneficial-owner information; and letter 3164/DNTN-GS of 7 October 2026 from the Agency for Private Enterprise and Collective Economy Development on checking declarations.
Companies are asked to review and reconcile what they have declared and file a supplementary notice of beneficial-owner information, completing it before 30 November 2026. The stated aim is complete, accurate registration data and fewer requests for corrections when the company files other registration changes later.
30 November 2026 is the date the Da Nang Department of Finance asks for; the letter itself does not state a penalty. The fines are in Decree 288/2026/NĐ-CP (288/2026/NĐ-CP): a company established before 1 July 2025 that files a registration change without supplementing its beneficial-owner information faces VND 70–100 million. Companies registered in other provinces should watch for their own registration office's instructions.
Who is a beneficial owner?
Article 17 of Decree 168/2025/NĐ-CP, as amended by Article 3 of Decree 296/2026/NĐ-CP and quoted in the letter, defines the beneficial owner of a company with legal personality as one or more individuals who directly or indirectly own or ultimately control the company in practice — excluding individuals who represent state capital in the company.
The criteria are in Articles 17–18 of Decree 168/2025/NĐ-CP (168/2025/NĐ-CP) as amended by Articles 3–4 of Decree 296/2026/NĐ-CP (296/2026/NĐ-CP). They apply in order:
- Direct or indirect ownership of 25% or more of charter capital or of voting shares;
- A family group or contractual group that together reaches that threshold, and specific criteria for general partners;
- If no one meets the ownership test, or a 25% holder is not the ultimate owner: the individuals with actual control — appointing management, amending the charter, financial decisions, reorganising or dissolving the company;
- Fallback: if no one meets either test, declare the manager with the greatest authority.
Why are so many companies filing now?
The duty to provide beneficial-owner information was added to the Law on Enterprises by Law 76/2025/QH15, effective 1 July 2025 (76/2025/QH15). Most companies set up before that date never declared it, so their record on the national portal is empty.
Government Resolution 312/NQ-CP of 5 October 2026 (Appendix II, clause 1, point q) (312/NQ-CP) sets a target of completing beneficial-owner information for over 80% of companies established before 1 July 2025 by the end of 2026. That is an implementation target for the authorities, not a general legal deadline; the Da Nang letter is the city's step to meet it.
What goes in the filing?
Section 2 of letter 14848 lists the documents; both forms are issued with Circular 121/2026/TT-BTC of 21 August 2026 (121/2026/TT-BTC):
- Request for registration of changes to enterprise registration content — Form 12 issued with Circular 121/2026/TT-BTC of 21 August 2026;
- List of beneficial owners — Form 10 issued with Circular 121/2026/TT-BTC, with each person's identity, contact address and basis of ownership or control;
- A power of attorney, if someone else files on the company's behalf.
How to file, step by step
Step 1 — Review: pull the current registration record, map ownership up to each ultimate individual (not stopping at a corporate shareholder), and check it against the criteria above and anything declared before.
Step 2 — Declare: prepare Forms 12 and 10, sign them with the right authority, add a power of attorney if needed, and file the supplementary notice on the National Business Registration Portal. Track the result and answer any request from the registration office.
Foreign-invested companies, and any company with a corporate member or shareholder, have to trace every layer — including a parent company abroad — to name the right individuals. This is where filings most often go wrong.
A one-page version to print and work through: Beneficial-owner filing checklist (printable)
Contacting the Da Nang business registration office
The letter directs questions to the Enterprise and Business Registration Division, Da Nang Department of Finance: 6th floor, City Administrative Centre, 24 Tran Phu, Hai Chau ward, Da Nang; phone 0236.3821755.
Frequently asked questions
What is the beneficial-owner deadline in Da Nang?
Letter 14848/STC-DN&ĐKKD of 20 October 2026 from the Da Nang Department of Finance asks companies to complete the supplementary filing before 30 November 2026.
Our company declared beneficial owners at registration. Do we file again?
The letter asks every company to review and reconcile what it declared. If the information is complete and still correct, nothing needs refiling; if it is missing or has changed, file a supplementary notice.
We are 100% foreign-owned through a parent company. Who do we declare?
The individuals who ultimately own or control the company, traced through the parent and any intermediate holding companies — not the parent company itself. If no individual meets the ownership or control tests after a full review, the fallback is the manager with the greatest authority.
Which forms are used?
Form 12 (request) and Form 10 (list of beneficial owners), both issued with Circular 121/2026/TT-BTC of 21 August 2026, plus a power of attorney if someone files on the company's behalf.
Need your beneficial-owner filing reviewed and submitted before 30 November?
We trace the ownership chain, prepare Forms 10 and 12 and file for you, with a fixed quote once we have seen your structure. InTimeVisa is a private consulting firm, not a government agency, and is not affiliated with the Vietnamese government.