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Specifically, under Clause 6, Article 44 of Decree No. 122/2021/ND-CP, as amended by Article 2 of Decree No. 288/2026/ND-CP, an enterprise established before July 1, 2025 shall be subject to a fine ranging from VND 70 million to VND 100 million if it fails to supplement information on the enterprise's beneficial owner (if any) and information used to identify the beneficial owner (if any) when carrying out its next procedure for registration of changes in enterprise registration information or notification of changes in enterprise registration information.
In addition to monetary penalties, Clause 7, Article 44 also prescribes a remedial measure requiring enterprises to supplement information on the beneficial owner and information used to identify the beneficial owner in accordance with the regulations.
Previously, Article 44 of Decree No. 122/2021/ND-CP only imposed penalties for violations relating to deadlines for registering changes to the Enterprise Registration Certificate, notifying changes in enterprise registration information, registering changes in branch, representative office or business location operations, or notifying business suspension or resumption. It did not provide penalties for failing to supplement beneficial owner information.
Besides introducing this new violation, Decree No. 288/2026/ND-CP also incorporates obligations relating to beneficial owner information into several other penalty provisions of Decree No. 122/2021/ND-CP.
Accordingly, violations involving late notification of changes, failure to notify changes, or failure to provide information at the request of the business registration authority are also extended to cover beneficial owner information and information used to identify the beneficial owner.
