Vietnam’s list identifies 42,911 companies with no beneficial owner (“chủ sở hữu hưởng lợi”, or BO) information on file. More than half are concentrated in five provinces and centrally run cities. The accompanying letter makes no finding of breach; it identifies companies for priority inspection. [CL]
Author: Attorney-at-Law Vu Manh Quynh, Managing Partner, ECOVIS Vietnam Law
Key takeaways
- The list identifies companies for priority inspection, without concluding that any listed company has breached disclosure requirements. [CL]
- Ho Chi Minh City and Hanoi account for the largest shares, at 21.8% and 18.2%.
- Median registered capital across all 42,911 companies is about VND 8.6 billion.
- Address and naming patterns are indirect signals; they do not establish foreign investment or common ownership. [AS]
- The latest date appearing in the data is 8 October 2026; the letter states no cut-off.
Why did the authorities issue the list?
The Agency for Private Enterprise and Collective Economy Development issued Official Letter 3164/DNTN-GS on 7 October 2026. [CL] It lists companies incorporated or amended since 1 July 2025 with no BO information on file. [CL]
The letter sends the list to provincial Departments of Finance for prompt review and inspection. It also asks the tax department to coordinate. [CL]
Ministry of Finance Official Letter 13767/BTC-DNTN, dated 3 September 2026, provides the preceding inspection context. It asks provincial business registration offices to focus on BO information during the last four months of 2026. [CL, as cited in Letter 3164]
For directors, CFOs and in-house counsel, the distinction matters: inclusion identifies a file for review, without establishing a breach. [CL]
Where are the listed companies concentrated?
Ho Chi Minh City has the largest count, followed by Hanoi.
| Province / centrally run city | Companies | Share |
|---|---|---|
| Ho Chi Minh City | 9,371 | 21.8% |
| Hanoi | 7,826 | 18.2% |
| Tay Ninh | 2,615 | 6.1% |
| Bac Ninh | 2,264 | 5.3% |
| Hai Phong | 2,233 | 5.2% |
| Other 29 provinces | 18,602 | 43.4% |
These figures describe the geographical distribution of companies within the attached list. They do not provide a comparison against the total company population in each location.
The geographical concentration therefore helps readers understand the list’s composition. It does not, by itself, establish how frequently companies in each location omit BO information.
What does registered capital show?
The largest registered-capital category is VND 1 to under 10 billion. The list also includes companies across the other capital bands shown below.
| Registered capital (VND billion) | Companies | Share |
|---|---|---|
| Under 1 | 3,112 | 7.3% |
| 1 to under 10 | 20,077 | 46.8% |
| 10 to under 100 | 12,976 | 30.2% |
| 100 to under 1,000 | 5,648 | 13.2% |
| 1,000 and above | 1,098 | 2.6% |
Median registered capital across all 42,911 companies is about VND 8.6 billion, computed from the file.
The table describes registered capital. It does not identify the individuals behind the companies or resolve whether their BO information has subsequently been filed.
Can the list identify foreign-invested companies or corporate groups?
The list has no field for foreign ownership or nationality. Address and naming patterns offer indirect signals only. [AS]
A total of 6,972 companies (16.2%) have an address in an industrial park, industrial cluster, export-processing zone, economic zone or high-tech park. This is about one in six listed companies.
These address patterns may help identify files for closer review, but they do not establish foreign ownership. [AS] Industrial-zone status was read from address text rather than checked against official zone lists.
Another 6,560 companies (15.3%) have names without Vietnamese diacritics after removal of legal-form words. This can indicate foreign investment, but many Vietnamese-owned companies also use such names. [AS]
There are also 563 companies sharing an address with at least nine other listed companies. These addresses may represent serviced offices or office towers. [AS]
Companies sharing an address do not necessarily belong to the same group. A shared location alone does not establish a common ownership structure. [AS]
What do the dates in the list mean?
The listed dates run from 1 July 2025 to 8 October 2026. Of these, 16,721 fall in July–September 2025.
That period was the first quarter after BO information became mandatory at incorporation or amendment. [CL] However, the letter does not state whether the date column records incorporation or the latest amendment. [AS]
The date range should therefore be read with that uncertainty in mind. [AS] The latest date appearing in the file is not an expressly stated cut-off in the letter.
Some companies may have filed BO information after 8 October 2026. [AS] The list alone cannot resolve their subsequent filing position.
How was the analysis prepared, and what are its limits?
Method and limits
- Source: The company list attached to Letter 3164/DNTN-GS. The latest date appearing in the data is 8 October 2026; the letter states no cut-off.
- Analysis: ECOVIS Vietnam Law counted the records on 22 October 2026.
- Ownership: The list contains no field for foreign ownership or nationality.
- Indirect signals: Names without diacritics and industrial-zone addresses do not establish foreign investment. [AS]
- Address checks: Industrial-zone status comes from address text, without verification against official zone lists.
- Shared locations: Companies at the same address do not necessarily belong to the same group.
- Subsequent filings: Some companies may have supplied BO information after 8 October 2026. [AS]
- Publication: No company names are published.
What should directors, CFOs and in-house counsel check?
Search the company’s registration number in the list attached to the letter. Then review registrations and change notices since 1 July 2025 for BO information.
Map ownership through to individuals and apply the BO identification tiers. Keep the company’s BO list on file.
Under the first tier, individuals holding 25% or more of capital or voting shares qualify through direct or indirect holdings. Holdings of family members, as defined in the Law on Enterprises, or of individuals acting under an agreement are aggregated. All general partners are included. [CL]
Individuals representing state capital in the company are excluded. [CL]
If nobody meets the first tier, identify the individual with actual control. If there is still none, identify the manager with the highest authority. [CL]
These tiers appear in Decree 168/2025/ND-CP, Article 17, as replaced by Article 3 of Decree 296/2026/ND-CP. [CL]
Use the beneficial owner disclosure self-check to support your review. For questions about your company, use the ECOVIS Vietnam Law contact form.
What questions do companies frequently ask?
Does inclusion mean that a company has breached the law?
Official Letter 3164/DNTN-GS makes no finding of breach. Its attached list identifies companies for priority inspection. [CL]
Does an industrial-zone address establish foreign investment?
An industrial-zone address is an indirect signal only. [AS] The list contains no field identifying foreign ownership or nationality.
Does the latest listed date establish an official cut-off?
The latest date in the list attached to Official Letter 3164/DNTN-GS is 8 October 2026. The letter states no cut-off. [CL] Some companies may have filed BO information afterwards. [AS]
What should a listed company review first?
A listed company should check its registration number and review registrations and change notices since 1 July 2025. The review should establish whether those records contain BO information.
Which sources support this article?
Sources
- Official Letter 3164/DNTN-GS, dated 7 October 2026, and its attached company list.
- Ministry of Finance Official Letter 13767/BTC-DNTN, dated 3 September 2026, as cited in Letter 3164.
- Decree 168/2025/ND-CP, dated 30 June 2025, as amended by Decree 296/2026/ND-CP, dated 23 July 2026.
Last reviewed: 22 October 2026 · Reviewer: Attorney-at-Law Vu Manh Quynh, Managing Partner
This article provides general information and does not constitute legal advice.
