MONTHLY LEGAL & TAX UPDATE | SEPTEMBER 2026
September 2026 continues to bring notable developments in investment, financial reporting, tax and customs policies. The common thread is not only the introduction of new regulations, but also the need for businesses to proactively review their operating models, data and compliance systems before these changes take effect in practice.
In this month’s update, KTC highlights four key areas for businesses to watch: the reduction in the list of conditional business investment sectors; preparation for IFRS adoption in the context of the Vietnam International Financial Centre (VIFC); key changes under the amended Customs Law; and the increasing emphasis on data-driven tax administration and compliance reconciliation.
01 | INVESTMENT LAW
AMENDED INVESTMENT LAW 2026: WHAT DOES THE REMOVAL OF 62 CONDITIONAL BUSINESS INVESTMENT SECTORS MEAN FOR BUSINESSES?
On 24 August 2026, the National Assembly passed Law No. 24/2026/QH16, amending and supplementing certain provisions of the Investment Law. One notable change is the removal of 62 conditional business investment sectors, together with the revision and standardization of 14 sectors under the new Appendix IV.
The new provisions may create greater room for businesses to enter and expand in the market. However, removing a sector from Appendix IV does not mean that all legal requirements are eliminated. Sector-specific conditions may still apply, while foreign investors should separately assess applicable market access conditions.
👉 KTC analyzes the key changes, transitional arrangements and the issues businesses should review during the 2026–2027 period:
👉 Read KTC’s detailed analysis
02 | INTERNATIONAL FINANCIAL REPORTING STANDARDS (IFRS)
CIRCULAR NO. 118/2026/TT-BTC: WHAT SHOULD BUSINESSES PREPARE FOR IFRS?
Circular No. 118/2026/TT-BTC, effective from 1 January 2027, provides a regulatory framework for the application of International Financial Reporting Standards (IFRS), further supporting the implementation of IFRS in financial reporting practices in Vietnam.
For businesses, IFRS is not simply a matter of changing how financial statements are prepared. It also involves data systems, accounting policies, operating processes and the capabilities of finance and accounting teams. As the Vietnam International Financial Centre (VIFC) is being developed, the ability to access and use financial information based on international standards is becoming increasingly important.
👉 KTC highlights the key provisions of Circular 118 and the practical steps businesses should take to prepare:
👉 Read KTC’s detailed analysis
03 | CUSTOMS LAW
AMENDED CUSTOMS LAW 2026: FROM CLEARANCE-STAGE CONTROL TO DATA-DRIVEN COMPLIANCE MANAGEMENT
Law No. 11/2026/QH16, amending and supplementing certain provisions of the Customs Law No. 54/2014/QH13, will take effect from 1 March 2027. The amended Law continues to shape customs administration toward stronger compliance management, risk management and data utilization.
For export manufacturing enterprises, processing enterprises and businesses with frequent import and export activities, the changes extend beyond procedures at the border. The ability to control, reconcile and trace data across customs records, inventory, production, accounting and tax systems will increasingly become an important factor in risk management.
Notably, the new provisions on post-clearance amendments, post-clearance audits, storage periods at bonded warehouses and CFS facilities, as well as the discontinuation of the tax-suspension warehouse regime, will require businesses to proactively review their processes and operating models before the Law takes effect.
👉 KTC analyzes the key changes and four priorities businesses should address before 1 March 2027:
👉 Read KTC’s detailed analysis
04 | TAX & E-INVOICES
FROM RISK IDENTIFICATION TO COMPLIANCE CONTROL: WHEN DATA BECOMES THE BASIS FOR TAX ADMINISTRATION
Tax administration is increasingly shifting toward data analytics and risk-based assessment, placing greater demands on the consistency of information maintained and provided by businesses.
Under Decision No. 1161/QD-CT, effective from 14 August 2026, at least 90% of cases included in annual tax inspection plans at taxpayers’ premises are selected through automated risk assessments via IT applications, with no more than 10% selected randomly.
Importantly, risk management is no longer confined to the taxpayer’s own filed tax returns. According to the Vietnam Tax White Paper 2026, tax authorities are actively linking and leveraging multiple integrated data sources—including e-invoices, tax filings, business registration registries, banking transactions, customs records, and cross-sectoral databases—to analyze, monitor, and identify risk indicators early. The approach to tax administration has fundamentally shifted from examining isolated files to analyzing entire transaction chains, cash flows, and overall compliance patterns.
This requires reported tax data to not only be accurate upon submission, but also fully consistent across revenue, expenses, e-invoices, accounting records, and operational realities. In a data-driven regulatory environment, discrepancies and unusual transactions can be surfaced promptly through cross-database reconciliation, serving as immediate flags for tax authorities to assess an enterprise’s risk and compliance profile.
In addition, Consolidated Document No. 27/VBHN-BTC updates the current penalty framework for tax and e-invoice administrative violations. For under-declarations resulting in a tax deficit, a 20% penalty applies to the underpaid amount, alongside full recovery of the unpaid tax and applicable late payment interest.
Crucially, financial exposures may extend far beyond direct penalty fees. An error involving an input invoice—if leading to a loss of VAT credit or CIT deductible expenses—can trigger multi-year adjustments across several tax categories.
KTC Perspective
As tax authorities transition from retrospective post-clearance audits to active real-time monitoring and early risk warnings, businesses cannot afford to delay internal reviews until formal explanation requests are issued.
KTC advises businesses to institute a regular three-way reconciliation mechanism: Accounting Records – Tax Returns – E-invoice Systems, while proactively building substantiation dossiers for high-risk transactions such as intercompany service charges, consulting fees, trade discounts, and high-value expenditures requiring non-cash payment proofs.
Modern tax governance goes beyond simply filing accurately on paper; it requires ensuring that every number reported can be traced, cross-checked, and substantiated by bona fide economic transactions, commercial contracts, and accounting books.
FROM REGULATORY UPDATES TO PROACTIVE MANAGEMENT
Regulatory changes do more than introduce new compliance requirements. They can directly affect investment decisions, financial systems, data flows and the way businesses operate. Staying ahead of these changes enables businesses to assess their impact, adjust their systems and manage risks before issues arise.
KTC continues to support businesses in monitoring regulatory developments, assessing their impact and translating legal requirements into solutions aligned with their actual operating needs.
KTC AUDIT & CONSULTING COMPANY LIMITED
Audit Services | Tax Advisory | IFRS & Risk Management Advisory
🌐 Website: ktcvietnam.com
📧 Email: contact@ktcvietnam.com
