Averseas investment monitoring report procedure: Full procedure guide

Long Phan Consulting receives numerous inquiries from businesses with overseas investment projects regarding how to prepare a overseas investment monitoring report procedure in compliance with applicable regulations and avoid penalties. Under Decree No. 19/2026/ND-CP (as amended and supplemented by Decree No. 96/2026/ND-CP), which provides guidance on the Law on Investment 2025, investors are required to prepare periodic six-month and annual reports. This article presents the four-step reporting process, specific submission deadlines for each reporting period, and applicable penalties for violations.

Entities Required to Report and Mandatory Report Types

Not every outbound investment activity is subject to the same reporting regime. This section identifies who must report and which report types are mandatory, so enterprises do not overlook their obligations.

Investors with Outbound Investment Projects Subject to an Outbound Investment Registration Certificate

This obligation applies to Vietnamese economic organizations and individuals that have been granted an Outbound Investment Registration Certificate and are implementing a project in the host country. The reporting obligation arises as soon as the project is approved or licensed by the host country and continues throughout the project’s life cycle until a closing evaluation report is submitted.

Three Mandatory Report Types

Investors with outbound investment projects must prepare three main groups of reports: periodic supervision and evaluation reports (biannual and annual); quarterly investment status reports updated on the online system; and a supervision and evaluation report submitted before proposing a project adjustment, where the adjustment requires amending the Outbound Investment Registration Certificate. Upon project completion, the investor must also prepare a closing evaluation report.

Legal basis: Article 94 of Decree 19/2026/ND-CP (as amended by Points a, b, c, d, Clause 6, Article 99 of Decree 96/2026/ND-CP); Points c, d, Clause 2, Article 47 of the Law on Investment 2025.

Authorities Receiving the Outbound Investment Supervision and Evaluation Report

A point many enterprises overlook is that the report must be sent simultaneously to several authorities on the prescribed list, not to a single recipient; missing even one recipient may still be treated as an incomplete submission.

Ministry of Finance: National Consolidation Authority

The Ministry of Finance is the focal authority that receives and consolidates all outbound investment supervision and evaluation reports nationwide, and it is responsible for reporting annually to the Prime Minister on supervision and evaluation activities.

Authorities Simultaneously Receiving Reports at the Local Level and the Vietnamese Representative Agency Abroad

In parallel with the Ministry of Finance, investors must send the report to the State Bank of Vietnam, the state ownership representative agency (for state-owned enterprises), the provincial People’s Committee and the Department of Finance where the investor’s head office is located, and the Vietnamese representative agency in the host country.

Legal basis: Clauses 2 and 9, Article 94 of Decree 19/2026/ND-CP (as amended by Decree 96/2026/ND-CP).

>>>See more: Procedures for reporting the implementation of overseas investment projects

4-Step Process for Preparing and Submitting the Report

To avoid a overseas investment monitoring report procedure due to missing data, investors should follow the four steps below rather than preparing the report right before the deadline.

1. Collect and reconcile project implementation data in the host country. The investor consolidates data on disbursed capital, implementation progress, financial position, and business results of the project in the host country, and reconciles this against the content registered in the Outbound Investment Registration Certificate to ensure the figures match.
2. Prepare the report using the prescribed form. The report is prepared using the form issued by the Ministry of Finance under Circular 44/2026/TT-BTC, completing all appendices on implementation status, operational status, and the financial indicators corresponding to each report type (periodic, quarterly, pre-adjustment, or closing evaluation).
3. Update and submit the report online on the Investment Supervision and Evaluation Information System. In line with digital transformation, project monitoring, supervision, and evaluation must be carried out on the Investment Supervision and Evaluation Information System; a report submitted on the system replaces a paper report. Investors should register a system account in advance to avoid delayed account issuance causing a missed deadline.
4. Retain records and data for reconciliation and post-audit purposes. All data and supporting documents used as the basis for the report must be systematically retained for reconciliation when the state management authority conducts a post-audit, or when the investor needs to extract data for subsequent reporting periods.

Legal basis: Point a, Clause 2, Article 95 of Decree 19/2026/ND-CP; Clause 1, Article 10 of Circular 44/2026/TT-BTC.

Reporting Deadlines to Remember to Avoid Violations

Each report type has its own deadline. The table below consolidates the applicable milestones for investors with outbound investment projects for easy tracking throughout the year.

Biannual and Annual Report Milestones

These are the two fixed, recurring milestones that investors should remember most easily: the biannual report is due before 10 July, and the annual report is due before 10 February of the following year. Enterprises should set a reminder at least two weeks before each deadline to allow time for data reconciliation.

Pre-Adjustment Report Milestone and Quarterly Data Updates

In addition to the two periodic milestones above, investors must also update quarterly investment status data on the online system and submit a supervision and evaluation report before proposing a project adjustment dossier; this deadline is tied to when the adjustment dossier arises and is not fixed to the calendar year.

Legal basis: Clause 11, Article 94 of Decree 19/2026/ND-CP (as amended by Point d, Clause 6, Article 99 of Decree 96/2026/ND-CP).

Penalties for Late, Missing, or Inaccurate Reports

Late or omitted reports do not only result in a fine; they can also affect other project procedures, so enterprises should understand the penalty framework to assess the risk.

Fine Levels by Violation Group

Under Article 20 of Decree 122/2021/ND-CP on violations of the outbound investment activity reporting regime, a fine of VND 20,000,000 to VND 30,000,000 applies to organizations (individuals committing the same violation are fined at one-half of this level) for any of the following acts: failing to comply with the outbound investment activity reporting regime.

Or submitting a report with incomplete content or without accompanying documents; failing to update, or updating incompletely, inaccurately, or out of time, on the National Investment Information System; preparing a supervision and evaluation report out of time or with incomplete content; and failing to comply with the periodic investment supervision and evaluation reporting regime.

Effect on the Dossier to Adjust the Outbound Investment Registration Certificate

Beyond the fine, the investor is still required to comply with the reporting regime or supplement the missing content or documents. Late or missing supervision reports are also typically cross-checked by the receiving authority when appraising a project adjustment dossier, which may extend the processing time for the adjustment beyond the expected timeline.

Legal basis: Decree 122/2021/ND-CP, currently in force as amended by Decree 288/2026/ND-CP (effective from 21 July 2026).

Common Mistakes That Lead to Requests for Supplementation or Penalties

In practice, most penalty cases do not stem from intentional violations but from recurring technical errors. The most common mistakes include:

• Using the wrong report form compared to the form prescribed under Circular 44/2026/TT-BTC.
• Missing reconciliation data between the report and the actual project implementation in the host country.
• Submitting late against the fixed 10 February and 10 July deadlines.
• Forgetting to update quarterly data on the Investment Supervision and Evaluation Information System.
• Data in the supervision report not matching the previously submitted project adjustment dossier, requiring the receiving authority to request an explanation or supplementation.

Consulting Services for Overseas Investment and Project Compliance Support

Long Phan Consulting provides consulting and support services to businesses and investors throughout the implementation of overseas investment projects, management of legal obligations, and handling of procedures arising throughout the project lifecycle, including:

• Advising on the conditions, procedures, and processes for conducting overseas investment activities;
• Advising on the application and procedures for obtaining and amending an Overseas Investment Registration Certificate;
• Reviewing the legal status of the project, implementation progress, investment capital, and investor reporting obligations;
• Advising on monitoring and evaluation reporting requirements for overseas investments at each stage of project implementation;
• Supporting the collection, review, and reconciliation of financial data, business activities, and project implementation progress for reporting purposes;
• Drafting and finalizing periodic monitoring and evaluation reports, pre-adjustment reports, and project completion reports;
• Supporting the updating of investment information and data on the Investment Monitoring and Evaluation Information System;
• Reviewing consistency between investment reports, project adjustment documents, and other relevant legal documents;
• Advising on solutions where reports are late, incomplete, contain inaccurate data, or are subject to requests for clarification;
• Acting under authorization to work with state management agencies, financial authorities, Vietnamese representative agencies abroad, and other relevant organizations;
• Advising on project adjustments, changes to investment details, and other legal procedures arising during implementation;
• Supporting businesses in establishing document management procedures, monitoring deadlines, and controlling periodic compliance obligations.

Clients may send their case documents via email info@longphanpmt.com or Zalo 0906.735.386 for a preliminary assessment.

Frequently Asked Questions About Preparing Monitoring and Evaluation Reports for Overseas Investment

To help investors and businesses properly fulfill their reporting obligations, below are some frequently asked questions regarding the reporting method, when the obligation arises, the relevant authorities, reporting after project completion, and penalties for violations.

Conclusion

Preparing and submitting overseas investment monitoring and evaluation reports on time, in the prescribed format, and to all required authorities is a mandatory legal obligation. Proper compliance helps businesses avoid fines of up to VND 30,000,000 under Decree No. 122/2021/ND-CP and minimizes potential impacts on subsequent procedures for amending the Overseas Investment Registration Certificate. If you need assistance reviewing outstanding reporting periods or submitting reports on time, Long Phan Consulting is ready to support your business via hotline 1900636389.