Official Letter 3164/DNTN-GS: List of Companies Without Beneficial Owner Information and What a Company Should Do

On 07/10/2026, the Department of Private Enterprise and Collective Economy Development under the Ministry of Finance issued Official Letter 3164/DNTN-GS, sending provincial and municipal Departments of Finance a list of companies with no beneficial owner declaration. This article summarizes what the letter says, how companies are affected and what to do, without repeating the explanation of the concept already given in the article on beneficial owners of an enterprise.

Quick answer: the letter is addressed to state agencies, not directly to companies. It contains a list of companies established or registering changes since 01/7/2025 that have no beneficial owner declaration (the press counts 42.911 companies; the letter does not state this number), so that provincial business registration authorities can check them as a priority. Being on the list does not mean a violation has been concluded. A company should compare the registration file it has submitted and, if the information is really missing, add it as instructed by the Department of Finance where it is registered.

What does Official Letter 3164/DNTN-GS say?

The Department asks provincial and municipal Departments of Finance to direct provincial business registration authorities to check the listed companies promptly, then compile and report the results under the reporting regime in Official Letter 13767/BTC-DNTN. The list was sent as a QR code for localities to download. The letter does not state a total number of companies; the figure of 42.911 appears consistently in the press (MISA AMIS, MAN, Vietnam Lawyers Magazine) as a count taken from the list.

This is an operational directive between agencies. The letter creates no new obligation, sets no general deadline and does not itself penalize any company. The declaration obligation lies in the Enterprise Law and Decree 168/2025/NĐ-CP, as amended and supplemented by Decree 296/2026/NĐ-CP of 23/7/2026.

Accompanying documents

This deadline was set by Quang Ninh, is not a nationwide deadline, and had passed as of 02/11/2026. According to the Crowe Vietnam bulletin of 29/10/2026, many other localities have also set deadlines, for example Phu Tho 15/11/2026 (Official Letter 9464/STC-ĐKKD), Da Nang 30/11/2026 and Hai Phong 10/12/2026; Thái Tín has not read these letters individually. A company should ask the Department of Finance where it is registered about the notice of its own locality.

What if the company is on the list?

The letter calls this a list for priority inspection and does not conclude that any company has violated the rules. The list reflects the state of the data at the time of the statistics. Three situations are common:

• The company really has not made the declaration: it needs to add it.
• The company made the declaration but the data was not updated correctly, or its file was not recorded: it should keep the receipt and confirmation to deal with the business registration authority.
• The company does not know which situation applies, because an earlier declarant was a service provider: it should request a copy of the file that was submitted.

What a company should do now

1. Ask the Department of Finance where the company is registered (or look up the Department’s notice) whether the company is on the inspection list, since the original list was sent to localities by QR code.
2. Find the most recent business registration file and check whether it contains a beneficial owner declaration.
3. Identify the correct beneficial owner under Decree 168/2025/NĐ-CP (amended by Decree 296/2026/NĐ-CP); the method is explained in the article on beneficial owners.
4. If information is missing, complete the supplementary procedure with the business registration authority. This goes together with the process of changing business registration.
5. Agree on who in the company may sign and submit the file; see also the article on the legal representative, seal and bank account.
6. Keep the receipt and a copy of the submitted file to answer when the business registration authority checks.

The declaration forms follow Circular 121/2026/TT-BTC of 21/8/2026, which amends Circular 68/2025/TT-BTC. According to the MAN bulletin, the file is submitted on the National Business Registration Portal.

The fine

Official Letter 3164 does not state a fine. Official Letter 11059/STC-QLDN of the Department of Finance of Quang Ninh quotes Decree 288/2026/NĐ-CP of 21/7/2026: a fine of 70.000.000 to 100.000.000 VND for failing to add beneficial owner information at the most recent registration of changes or notice of changes to business registration content, for companies established before 01/7/2025. Decree 288 amends Decree 122/2021/NĐ-CP; according to LuatVietnam and Vietnam Lawyers Magazine, companies are also required to add the information. Thái Tín has not read the original of Decree 288, so the fine here follows Official Letter 11059; a company in another group should check the text of the decree. The general background is in the article on business 2025-2026: legal and tax changes.

Common misunderstandings

• Treating the list as a list of violators: the list serves inspection and is not a conclusion.
• Taking one province’s deadline as a nationwide deadline: the deadline of 31/10/2026 above is Quang Ninh’s; other places may differ.
• Thinking only newly established companies are affected: the list includes companies that registered changes from 01/7/2025; a company established before that date must add the information at its most recent registration of changes.
• Declaring for the sake of it: the information should reflect the person who actually owns or controls the company.

How Thái Tín can help

Thái Tín is the point of contact that helps a company re-check its registration file and connects it with specialist partners to complete the supplementary procedure:

• Check the submitted file to determine whether a beneficial owner declaration exists.
• Prepare a list of the information and documents needed for the supplement.
• Connect specialist partners to submit the file and deal with the business registration authority.

Please send us the company name and the province or city of registration so that Thái Tín can prepare a list of what needs to be done.

Cross-check sources and date: scans of Official Letters 3164 and 11059, LuatVietnam, Crowe Vietnam, MISA AMIS and MAN, read on 02/11/2026; the originals of Official Letter 13767, Decree 288 and Decree 296 have not been read.

Questions and answers

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