Beneficial-owner penalties in Vietnam under Decree 288/2026/NĐ-CP
Decree 288/2026/NĐ-CP of 21 July 2026, effective on signature (288/2026/NĐ-CP), amends Decree 122/2021/NĐ-CP on administrative penalties in planning and investment and writes beneficial-owner information into several offences. The highest bracket, VND 70–100 million, applies to a company established before 1 July 2025 that does not supplement its beneficial-owner information when it files its next change of enterprise registration. Untruthful or inaccurate declarations are fined VND 30–70 million, and late change notices are fined by the number of days late. The table below lists each offence, its fine and the article.
Beneficial-owner fines at a glance
The articles below are articles of Decree 122/2021/NĐ-CP as amended by Decree 288/2026/NĐ-CP (Articles 1–5) (288/2026/NĐ-CP).
| Offence | Fine | Article |
|---|---|---|
| Untruthful or inaccurate beneficial-owner information, or information used to identify beneficial owners, in a registration or change-notice dossier | VND 30–70 million | Art. 43 |
| Notice of a beneficial-owner change filed 1–10 days late | Warning | Art. 44(1) |
| 11–30 days late | VND 10–20 million | Art. 44(2) |
| 31–90 days late | VND 30–40 million | Art. 44(3) |
| 91 days or more late | VND 50–60 million | Art. 44(4) |
| No notice of a change in beneficial-owner information | VND 30–70 million | Art. 44(5) |
| Company established before 1 July 2025 that does not supplement beneficial-owner information (if any) when filing its latest registration change or change notice | VND 70–100 million | Art. 44(6) |
| No beneficial-owner information (if any) declared at incorporation | The Art. 46(4) bracket | Art. 46(4)(c) |
| Incomplete or late reporting when requested (including beneficial-owner information) | VND 20–30 million | Art. 48(1) |
| Not reporting when requested, or reporting untruthfully or inaccurately (including beneficial-owner information) | VND 50–70 million | Art. 48(3) |
| Not keeping company records as required, including the list of beneficial owners | VND 40–70 million | Art. 52(2)(e) |
When does the VND 100 million fine apply?
The VND 70–100 million bracket in Article 44(6) covers a company established before 1 July 2025 that does not supplement its beneficial-owner information (if any), and the information used to identify beneficial owners (if any), at the time it files its latest registration change or change notice.
In other words, the offence is tied to a registration filing — a new legal representative, address, capital or business line — made without adding the beneficial-owner information. Summaries that say "no declaration means a VND 100 million fine" do not match the wording. The safe course is to supplement now, before the next change filing.
Beyond the fine: remedial orders
A fine does not replace the filing. Decree 288/2026/NĐ-CP adds remedial measures: an order to file the change notice or supplement beneficial-owner information (Article 44(7) and Article 46(5)(d)), to provide the requested information (Article 48(4)) and to keep the list of beneficial owners (Article 52(3)(g)). The company still files — only after paying.
How does Da Nang's 30 November 2026 date fit in?
Da Nang Department of Finance letter 14848/STC-DN&ĐKKD of 20 October 2026 asks companies to complete their beneficial-owner filings before 30 November 2026; the letter itself names no penalty. The fines are those in Decree 288/2026/NĐ-CP above.
For a company set up before 1 July 2025, the biggest risk is filing a registration change in the coming months without the beneficial-owner information. Filing by 30 November, as the Department asks, removes that risk.
How to avoid the fines
Five steps:
A one-page version to print and work through: Beneficial-owner filing checklist (printable)
- Trace ownership to each ultimate individual and identify beneficial owners in the three-step order of Decree 296/2026/NĐ-CP;
- Companies set up before 1 July 2025: file the supplement (Form 12 and Form 10 under Circular 121/2026/TT-BTC) before the next registration change;
- Declare truthfully and accurately — false information is fined VND 30–70 million;
- When a beneficial owner or ownership percentage changes, notify within 10 days; from day 11 late, fines apply;
- Keep the list of beneficial owners on file at the company.
Frequently asked questions
What is the fine for not declaring beneficial owners in Vietnam?
It depends on the offence. A company established before 1 July 2025 that does not supplement beneficial-owner information when filing its latest registration change faces VND 70–100 million; not notifying a change is VND 30–70 million; untruthful or inaccurate declarations are VND 30–70 million (Decree 288/2026/NĐ-CP).
Is every company without a declaration by 30 November 2026 fined VND 100 million?
No. The VND 70–100 million bracket applies when a company established before 1 July 2025 files a registration change or change notice without supplementing its beneficial-owner information. 30 November 2026 is the Da Nang Department of Finance's request; its letter names no penalty.
What are the fines for a late beneficial-owner change notice?
1–10 days late: warning; 11–30 days: VND 10–20 million; 31–90 days: VND 30–40 million; 91 days or more: VND 50–60 million (Article 44 of Decree 122/2021/NĐ-CP as amended by Decree 288/2026/NĐ-CP).
When did Decree 288/2026/NĐ-CP take effect?
On signature, 21 July 2026 (Article 8 of Decree 288/2026/NĐ-CP).
Want your beneficial-owner filing done before a fine applies?
We trace the ownership chain, prepare Forms 10 and 12 and file the supplement 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.