Does changing the signature of the general director of an enterprise require notification to the business registration authority?

Short answer: No. There is no procedure for notifying the business registration authority of a change in the general director’s signature. Moreover, since 01/01/2026, ordinary enterprises are no longer required to maintain a specimen signature register — the old obligation under Circular 200/2014/TT-BTC has been replaced by Circular 99/2025/TT-BTC, which removed that requirement.

1. Does changing the signature of the general director of an enterprise require notification to the business registration authority?

No. There is no specific procedure for changing the signature of the general director (legal representative). Enterprise law does not provide for any notification to, or registration with, the business registration authority when such a change arises. Therefore, no filing with any state agency is required for this issue.

2. Is the enterprise still required to maintain a specimen signature register?

The old rule: Under Clause 7, Article 118 of Circular 200/2014/TT-BTC, enterprises had to open a book to register specimen signatures of the treasurer, storekeeper, accountants, chief accountant (and authorized persons), and the General Director (and authorized persons). The specimen signature register had to be page-numbered and sealed, managed by the head of the unit (or an authorized person) for convenient inspection when necessary. Each person had to sign three specimen signatures in the register.

The current rule: Circular 99/2025/TT-BTC (effective 01/01/2026) replaces Circular 200/2014/TT-BTC (Article 31 of Circular 99/2025/TT-BTC). Under Article 10 of Circular 99/2025/TT-BTC, enterprises are no longer required to open a specimen signature register. The current requirements are:

• Preparation and signing of accounting documents follow the Accounting Law, its guiding documents, and the guidance in Circular 99/2025/TT-BTC;
• Signature delegation on accounting documents must comply with the law and the enterprise’s internal governance rules to ensure strict control and asset safety;
• The chief accountant (or authorized person) may not sign beyond authorization (“thừa ủy quyền”) for the enterprise’s manager/executive on accounting documents.

Practical consequence: when the general director’s signature changes, an ordinary enterprise no longer needs to “add the new signature to the register” — because the register is no longer mandatory. What matters now is that the enterprise’s internal signature-delegation rules remain consistent and that signatures comply with the Accounting Law (a person’s signature on accounting documents must be consistent — Article 19 of the Accounting Law 2015).

Exception: sectors with their own accounting regimes may still require a specimen signature register — for example, securities companies (Clause 4, Article 6 of Circular 210/2014/TT-BTC, as amended by Circular 334/2016/TT-BTC). Enterprises in such sectors should check their sector-specific regulations. In practice, enterprises should also update any specimen signatures registered with their bank for payment accounts when the legal representative’s signature changes.

3. Is there still a fine for “changing the general director’s signature without adding it to the register”?

The old answer — a fine of VND 10,000,000 to VND 20,000,000 under point d, Clause 2, Article 8 of Decree 41/2018/ND-CP (a person’s signature inconsistent with the specimen signature register) — was premised on the now-removed general obligation. For ordinary enterprises, that violation scenario no longer has a factual basis under current law, so the fine no longer applies as a general rule.

The penalty provision itself (Decree 41/2018/ND-CP, still in force, as amended by Decree 102/2021/ND-CP and Decree 132/2026/ND-CP) can still apply where a specimen signature register is maintained — for example, securities companies under Circular 210/2014/TT-BTC, or an enterprise that keeps such a register voluntarily — if a person’s signature is inconsistent with the registered specimen.