Vietnam: Ultimate Beneficial Owner Notification Requirements

The Ministry of Finance has introduced new disclosure obligations under Circular No. 68/2025/TT-BTC, effective 1 July 2025. The rules require companies to declare and maintain information on their ultimate beneficial owners and notify the relevant licensing authority. Companies incorporated before this date must update their details when they next submit an application to amend business registration information. The requirements apply to companies that must file enterprise registration changes through the National Business Registration Portal.

Key changes and requirements

Companies must identify and notify individuals or organisations that meet the new thresholds for beneficial ownership. These include individuals holding at least 25% of voting shares, individuals owning at least 25% of the charter capital of a partnership or multi‑member limited liability company, the owner of a single‑member limited liability company, and individuals with the authority to approve significant corporate decisions. Organisations holding at least 25% of voting shares also fall within scope.

Companies must retain a list of beneficial owners in paper or electronic form as notified to the competent authority. To comply, companies must submit a notice of changes in enterprise registration contents using Form No. 12 and a list of beneficial owners using Form No. 10, as issued under the Circular. A power of attorney is required where a representative files the application. The authority does not accept electronic signatures for these submissions.

Penalties apply for non‑compliance, including fines for late notification or failure to notify changes in business registration information.

How can we help?

Computershare can support companies in identifying required information, preparing compliant disclosure materials, and coordinating submissions to the National Business Registration Portal. We can also help maintain accurate records of beneficial ownership through our GEMS platform.

Contact

Please contact your dedicated Computershare Relationship Manager or send an email to #GLCGSGECNetworkManagement@computershare.com for more information about how Computershare may assist you in responding to these new requirements.

Disclaimer: This notice is provided by Computershare for general informational purposes only and is not intended and should not be construed as legal, regulatory, financial or tax advice. Computershare is not licensed or authorized to practice law in any jurisdictions and hence does not provide any legal advice and it does not hold itself out as doing so. Neither Computershare nor any of its affiliates or contributors accept any responsibility or liability for the quality, accuracy or completeness of any information contained in this notice. It is important that you seek independent professional advice relating to the subject matter of this notice before relying on it.