1. What is the obligation to register changes to enterprise registration contents?
Under Clause 2, Article 8 of the Law on Enterprises 2020 (as amended and supplemented by Law No. 76/2025/QH15, effective from 01/7/2025), the obligation to notify changes to enterprise registration contents is as follows:
Fully and promptly perform the obligations regarding enterprise registration, registration of changes to enterprise registration contents, disclosure of information about the establishment and operation of the enterprise, reporting, and other obligations as prescribed by this Law.
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Thus, registering changes to enterprise registration contents is an obligation of the enterprise; therefore, the enterprise must register changes to its enterprise registration contents.
2. Which contents must be notified when changing enterprise registration contents?
Under Article 31 of the Law on Enterprises 2020 (as amended and supplemented by Law No. 76/2025/QH15, effective from 01/7/2025), the contents enterprises must notify are:
The enterprise must notify the business registration authority when changing any of the following contents:
– Business lines;
– Founding shareholders and shareholders who are foreign investors for joint-stock companies, except for listed companies and companies registered for securities trading;
– Information about the beneficial owner of the enterprise, except for listed companies and companies registered for securities trading;
– Other contents in the enterprise registration dossier.
Thus, if you change from medical equipment business to pharmaceutical business, this is a change of business lines; under the above provision you must notify the business registration authority.
3. In which cases may an enterprise not notify changes to enterprise registration contents?
Under Article 59 of Decree 168/2025/ND-CP (effective from 01/7/2025, replacing Decree 01/2021/ND-CP), the provincial business registration authority shall refuse to issue enterprise registration — including registration and notification of changes to enterprise registration contents — in the following cases:
– Having received a Notice from the provincial business registration authority regarding violations subject to revocation of the Enterprise Registration Certificate, or having received a Decision revoking the Enterprise Registration Certificate;
– Being in the process of dissolution under the enterprise’s dissolution decision;
– The enterprise being in the legal status of “No longer conducting business at the registered address”;
– Upon written request of a Court; a civil judgment enforcement agency; or an investigation agency, head or deputy head of an investigation agency, or investigators as prescribed in the Criminal Procedure Code regarding the enterprise not being permitted to carry out one or more enterprise registration procedures, until written approval is obtained from the aforementioned organizations or individuals.
4. What penalties apply for failure to notify changes to enterprise registration contents?
Under Article 49 of Decree 122/2021/ND-CP, as amended and supplemented by Decree 288/2026/ND-CP (effective from 21/7/2026), penalties for violations regarding notification of changes to enterprise registration contents are as follows:
– Warning for violations of the notification time limit from 01 to 10 days;
– A fine of VND 10,000,000 to VND 20,000,000 for violations of the notification time limit from 11 to 30 days;
– A fine of VND 30,000,000 to VND 40,000,000 for violations of the notification time limit from 31 to 90 days;
– A fine of VND 50,000,000 to VND 60,000,000 for violations of the notification time limit of 91 days or more;
– A fine of VND 30,000,000 to VND 70,000,000 for failure to notify changes to enterprise registration contents as prescribed;
– Remedial measures: forcing notification to the business registration authority as prescribed.
Thus, when an enterprise fails to notify changes to enterprise registration contents in cases where notification to the business registration authority is mandatory, it may receive a warning or be fined up to VND 70,000,000.
5. Notifying changes to enterprise registration contents under a Court or Arbitration decision?
Under Clause 5, Article 31 of the Law on Enterprises 2020 (as amended and supplemented by Law No. 76/2025/QH15, effective from 01/7/2025), notifying changes to enterprise registration contents under a Court or Arbitration decision is carried out as follows:
– The organization or individual requesting changes to enterprise registration contents sends the notice of change to the competent business registration authority within 10 days from the date the Court’s judgment or decision takes legal effect or the Arbitration award takes effect. The notice must include a copy of the effective Court judgment or decision or the effective Arbitration award.
– Within 03 working days from receipt of the notice, the business registration authority is responsible for reviewing and effecting the change of enterprise registration contents in accordance with the effective Court judgment or decision or the effective Arbitration award; where the dossier is invalid, the business registration authority must notify in writing the contents to be amended or supplemented to the applicant. Where it refuses to amend or supplement the information under the notice of enterprise registration change, it must notify the applicant in writing and state the reasons.
Notes on applying current legal regulations
This article belongs to the Corporate Knowledge group and is presented for reference, helping readers understand the legal issue at a general level before preparing dossiers or conducting transactions.
Legal regulations may change depending on the time, locality, dossier type, and specific circumstances. To determine the exact legal basis applicable to your dossier, please contact ANT Legal’s lawyers at 0966.475.966 for review and advice before proceeding.
Common risks to note
- Applying legal documents that have been amended, supplemented, or replaced;
- Preparing insufficient dossiers, documents, or evidence;
- Misunderstanding the conditions, procedures, time limits, or competent authorities;
- Signing, submitting dossiers, or conducting transactions without fully assessing legal risks.
How can ANT Legal help?
ANT Legal supports reviewing specific situations, checking dossiers, determining applicable legal bases, advising on handling options, and representing clients in dealings with individuals, organizations, or competent authorities when needed.
For quick advice, please contact our lawyers at 0966.475.966.
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