⚠️ ENTERPRISES THAT HAVE NOT DISCLOSED BENEFICIAL OWNERSHIP INFORMATION MAY FACE FINES OF VND 70–100 MILLION

Enterprises should promptly review their beneficial ownership disclosure status, check whether they are included in the list of enterprises subject to review, and proactively complete the required filings in accordance with applicable regulations.

On 12 October 2026, the Department of Finance of Quang Ninh Province issued Official Letter No. 11059/STC-QLDN, requiring enterprises to identify and disclose beneficial ownership information in accordance with Decree No. 296/2026/ND-CP.

Note: The above deadline applies under the Official Letter issued by Quang Ninh Province. Enterprises registered in other localities should verify the applicable deadlines specified in notices issued by their respective Departments of Finance.

1. HOW CAN ENTERPRISES CHECK WHETHER THEY ARE INCLUDED IN THE LIST?

According to Official Letter No. 3164/DNTN-GS dated 7 October 2026, the Agency for Private Enterprise and Collective Economy Development identified 42,911 enterprises that had been established or registered changes since 1 July 2025 but had not yet disclosed beneficial ownership information.

These enterprises have been prioritised for compliance checks and reviews.

🔎 How to check:

Step 1: Access the list of enterprises that have not disclosed beneficial ownership information under Official Letter No. 3164/DNTN-GS.

Step 2: Select the province or city where the enterprise’s registered head office is located.

Step 3: Download the list and use the search function (Ctrl + F) to look up the enterprise by its tax identification number or registered name.

Step 4: Review the search results:

• Enterprise appears on the list: The enterprise should promptly verify its filing status and submit supplementary information if its disclosure obligations have not been fulfilled.
• Enterprise does not appear on the list: The enterprise should still verify its disclosed information on the National Business Registration Portal.
• Information has already been fully and accurately disclosed: The enterprise is not required to submit the same information again solely because it appeared on an earlier statistical list.

2. WHO QUALIFIES AS A BENEFICIAL OWNER?

Under Decree No. 296/2026/ND-CP, enterprises must identify the individuals who ultimately own or exercise effective control over the enterprise, including:

• ✅ Individuals who directly or indirectly own 25% or more of the charter capital or voting shares.
• ✅ Individuals belonging to groups connected through family relationships or joint ownership agreements, where the prescribed conditions are satisfied.
• ✅ Individuals who exercise effective control over the enterprise.
• ✅ Where no individual can be identified under the above criteria, the senior managing official with the greatest authority to act on behalf of the enterprise must be disclosed in accordance with the applicable regulations.

For foreign-invested enterprises (FDI enterprises), multi-tier ownership structures should be reviewed to identify the individuals who ultimately own or control the enterprise.

3. STEP-BY-STEP GUIDE TO CHECKING AND SUBMITTING ONLINE FILINGS

Enterprises should complete the relevant procedures through the National Business Registration Portal:

🌐 https://dangkykinhdoanh.gov.vn

Step 1. Log in to the system

• Access the website.
• Select Online Business Registration.
• Select Log in with VNeID.
• Use the electronic identification account of the person carrying out the procedure, as required by applicable regulations.

Step 2. Select the relevant procedure

On the business registration interface:

• Select Business Registration.
• Select Registration of Changes to Enterprise/Dependent Unit Registration Information.
• Click Next.

Step 3. Search for the enterprise

• Enter the enterprise registration number or tax identification number.
• Click Search.
• Verify the displayed enterprise name.
• Select Next.

Step 4. Identify the person submitting the application

Select one of the following:

• The person authorised to sign the enterprise registration application.
• An authorised representative carrying out the procedure.

Enter the legal identification document number of the enterprise’s legal representative as required by the system.

Click Next.

Step 5. Review the information already disclosed

• Select Change Enterprise Registration Information.
• Click Next → Start.
• Locate the Beneficial Ownership Information List.

Review the information:

✅ If beneficial ownership information is already available: Verify the names, personal identification numbers, ownership percentages and other relevant details.

⚠️ If the list is empty: The enterprise should review its disclosure obligations and supplement the required information in accordance with applicable regulations.

Step 6. Submit supplementary beneficial ownership information

Where supplementary disclosure is required:

• Select the relevant Notification of Changes procedure corresponding to the applicable filing type.
• Access the Beneficial Ownership Information section.
• Select Create New.
• Enter the required information for each individual identified as a beneficial owner.
• Specify the ownership percentage and information on control rights, as applicable.
• Click Save.

Step 7. Prepare and attach supporting documents

The prescribed forms under Circular No. 121/2026/TT-BTC include:

• 📄 Form No. 10: List of the enterprise’s beneficial owners.
• 📄 Form No. 12: Application for Registration of Changes to the Enterprise Registration Certificate / Notification of Changes to Enterprise Registration Information.
• 📄 Letter of Authorisation: Required where the application is submitted by an authorised representative.

Under the Attached Documents section, select the appropriate document category and upload the required documents as instructed by the system.

Step 8. Check for errors and submit the application

• Select Prepare Application.
• Review any system-generated error notifications and complete or correct the required information.
• Complete the electronic authentication process.
• Pay any applicable fees or charges, if required.
• Select Submit Application.

Upon successful submission, retain the electronic acknowledgement of receipt and the application reference number.

Step 9. Monitor the application status

Access the application management section of the system to check the processing status.

If amendments or additional documents are requested, the enterprise should respond in accordance with the notification issued by the business registration authority.

Note: The interface and names of certain functions may change as the system is updated.

4. WHAT SHOULD ENTERPRISES DO?

MBA Auditing Firm recommends that enterprises:

• ✅ Check whether their names appear on the list of enterprises subject to review.
• ✅ Log in to the National Business Registration Portal to verify their beneficial ownership disclosure status.
• ✅ Correctly identify their beneficial owners and prepare the necessary documents if supplementary disclosure is required.
• ✅ Complete the relevant procedures within the deadline applicable in their locality.

Proactively reviewing and completing the required filings will help enterprises maintain regulatory compliance and minimise unnecessary legal complications.

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