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Vietnam – Province-specific transitional deadlines announced for UBO declarations
Further guidance has been issued on deadlines for completing Ultimate Beneficial Owner (UBO) declarations in Vietnam following updated UBO identification requirements under Decree 296/2026/ND-CP.
Province-specific deadlines now apply for the completion of UBO declarations, ranging from the 31st of October to the 15th of December 2026.
The underlying UBO identification requirements require companies to trace through each layer of their ownership structure until the individual or individuals who ultimately own or control the company are identified.
The latest guidance establishes different transitional deadlines across a number of Vietnamese provinces, while Hanoi and Ho Chi Minh City have not established separate transitional deadlines.
Provincial UBO Declaration Deadlines
The announced deadlines are:
| Date | Province |
|---|---|
| 31 October 2026 | Quang Ninh, Lam Dong and Tay Ninh |
| 15 November 2026 | Phu Tho |
| 20 November 2026 | Khanh Hoa, Dak Lak and Ninh Binh |
| 30 November 2026 | Da Nang City |
| 10 December 2026 | Hai Phong City |
| 15 December 2026 | Dong Nai |
Hanoi and Ho Chi Minh City
Hanoi and Ho Chi Minh City have not established separate transitional deadlines.
Authorities in these locations are conducting inspections, reviews and enforcement actions in accordance with applicable laws and regulations.
Companies in Hanoi and Ho Chi Minh City are therefore advised to complete and submit their UBO declarations as soon as possible.
Actions for Companies
Given the different deadlines across provinces and the absence of extensions, companies should:
- Confirm the applicable deadline based on their province
- Review their ownership structures to identify the individuals who ultimately own or control the company
- Complete and submit the required UBO declaration as soon as possible
No extensions are available under the current guidance.
How Mercator® by Citco (Mercator) Can Help
Mercator can assist with:
- Reviewing ownership and control structures
- Identifying reportable beneficial owners under Vietnam’s revised framework
- Analysing complex multi-layer ownership chains
- Preparing UBO registration information and supporting documentation
- Assisting with initial registrations and ongoing maintenance requirements
- Supporting amendments following ownership or governance changes
- Preparing internal beneficial ownership registers where required
For assistance, please contact [email protected]
