Beneficial ownership: Numerous provinces and cities set declaration deadlines in October–December 2026

Decree No. 296/2026/ND-CP, effective from 23 July 2026, has entirely replaced Articles 17 and 18 of Decree No. 168/2025/ND-CP concerning beneficial owners ("BO").

On that basis, the Departments of Finance of numerous localities have issued official letters requiring enterprises to complete the declaration and supplementation of BO information between October and December 2026.

1. Deadlines under the law

2. Deadlines under official letters of individual localities

This list continues to be updated. Enterprises located in localities not yet named above, including Ho Chi Minh City and Hanoi, should monitor announcements issued by the Department of Finance where their head office is located.

3. Order of determining beneficial owners under Decree No. 296/2026/ND-CP

Clause 2, Article 18 of Decree No. 168/2025/ND-CP (as replaced by Article 4 of Decree No. 296/2026/ND-CP) prescribes three steps to be applied in the following order:

Step 1 - Ownership rights. Individuals holding, directly, indirectly, or through a combination of both, 25% or more of the charter capital or of the total voting shares. Where a group of individuals having a family relationship as defined in Clause 22, Article 4 of the Law on Enterprises, or bound by contract, jointly holds 25% or more, all individuals within that group are beneficial owners. For partnerships, all general partners are beneficial owners regardless of their capital contribution ratio.

Step 2 - Actual controlling rights. Applicable where no individual can be determined under Step 1, or where there are grounds to conclude that the individual identified under Step 1 is not in substance the beneficial owner.

Step 3 - The manager holding the greatest authority. Applicable where no individual can be determined under either of the two steps above. An enterprise registration application must therefore always declare at least one beneficial owner.

💡 Immediate actions for enterprises

1. Verify the deadline applicable in the locality where the head office is located. Where no official letter has been issued, contact the Business Registration Office under the Department of Finance for confirmation.
2. Review the List of Beneficial Owners against the new criteria under Article 17 of Decree No. 168/2025/ND-CP (as amended). The outcome is likely to differ from the previous declaration, particularly for family-owned companies and partnerships.
3. Enterprises established before 01 July 2025 that have never made a declaration should complete it within the deadline set by their locality.

This newsletter is prepared by Crowe Vietnam for general information purposes only and does not constitute advice for any specific case. Enterprises should refer to the original legal instruments and consult professional advisors before applying the above to their particular circumstances.