Annual reports and ESG: who reads, what to write, how to write
For funds and financial companies, the annual report is a legal document and a signal of trust sent to investors.
If your business is listed or public in Vietnam, you must comply with the mandatory structure and deadlines of Circular 96/2020/TT-BTC before considering aesthetics. If the fund reports to an institution or international investor, it is advisable to use ISSB (IFRS S1, S2) and GRI as additional reference frameworks. These two aspects do not replace each other: domestic compliance and international readability must go hand in hand.
- listing on HOSE or HNX in compliance with Circular 96
- reports for international institutions using ISSB and GRI
- the large ESG block separates the sustainability report
- consider the annual report as a beautiful publication that forgets deadlines
- Label as ESG but lack data according to standard frameworks.
The annual report of an investment fund or financial company is not like a typical corporate brochure. It is both a legal obligation and a signal of trust sent to investors and the market. When creating such documents, the first question is "who reads this document and what decisions do they need to make," not "what colors should be used."
The mandatory legal framework before discussing design
If your business is listed on HOSE or HNX, or is a public company, Circular 96/2020/TT-BTC clearly stipulates the structure, minimum content, and publication deadlines. Financial information must match the audited annual financial statements. According to this document, the report must be published no later than 20 days from the date of the audited annual financial statement, and not exceeding 110 days from the end of the financial year. The sustainable development section in the appendix includes topics such as energy use, water, emissions, labor policies, and social responsibility. This document has been amended and supplemented multiple times (most recently with Circular 08/2026/TT-BTC) and may continue to be revised regarding sustainable development content, so you should compare the current version with your legal department or lawyer before finalizing. This is an essential starting point before considering any design options.
When the fund reports to international investors.
For fundraising or reporting to international LPs (limited partners), Circular 96 needs to be supplemented with a global reference framework. The two most common frameworks are GRI and ISSB.
- GRI (Global Reporting Initiative): takes a multi-stakeholder approach, covering a wide range. It is suitable when you want to tell a comprehensive sustainability story for various target groups.
- ISSB (International Sustainability Standards Board) with IFRS S1 and S2: defines precisely what must be disclosed to the capital market, focusing on investors. IFRS S2 integrates TCFD (Task Force on Climate-related Financial Disclosures) recommendations regarding climate risks.
These two frameworks complement each other, and many businesses use them in parallel. Choosing one does not mean abandoning the other.
Should ESG be integrated into the annual report or kept separate?
Separate into a dedicated sustainability report: suitable when the ESG content is substantial enough to tell in depth, when the fund wants to use this material separately in fundraising or dialogue with international investors, or when a full disclosure according to GRI or ISSB is needed without inflating the annual report.
Common mistakes that break trust
- Viewing the annual report as a beautiful publication and forgetting the mandatory items and deadlines of Circular 96.
- The data in the design section deviates from the audited financial report. This is a technical error, but investors will notice immediately and lose trust.
- Piling dense tables without visualization buries the main message. Investors scan documents in the first few seconds.
- Labeling ESG while only telling positive stories, lacking data and measurement methods according to standard frameworks. This part will be scrutinized by international institutions.
- Copying the ISSB or GRI framework from abroad while omitting mandatory parts according to Vietnamese law.
A good investor report is not the most comprehensive report, but one that investors can read and understand the key messages the business wants to convey within the time they actually have.
Practical experience.
Decision checklist
Topic: Annual reports and ESG for investment funds. Sinh Vũ guide, sinhvu.com
Tick each item that applies or that you can already answer, then print or save as PDF to take with you.
If you have marked most of the signs above, this is the time to discuss in more detail. Sinh Vũ can help you review and propose a direction.
This article provides general information according to the documents in effect as of October 6, 2026. This is not legal advice and does not substitute for a lawyer's opinion for your specific case. Rights and obligations between Sinh Vũ and clients arise only according to the signed contract.
References
Circular 96/2020/TT-BTC guiding information disclosure on the securities market; SSC and IFC, Guidelines for Sustainable Development Reporting; IFRS Foundation, introduction to ISSB and IFRS Sustainability Disclosure Standards; ISSB issued IFRS S1 and S2, integrating TCFD (2023).
Frequently asked questions
Is ESG mandatory, or just a trend?
For listed companies and public companies in Vietnam, the sustainable development content is mandatory according to the appendix of Circular 96/2020/TT-BTC, not voluntary. You can integrate it into the annual report or separate it into a standalone report, but it cannot be completely omitted. For unlisted private funds, ESG depends on commitments to investors. However, if the LP (limited partner) is an international institution, they often set clear requirements in the investment terms.
In this reporting project, what tasks belong to the designer, and what tasks belong to the company?
The designer is responsible for information architecture, templates, data visualization, and the consistency of the entire document. The hard boundaries are financial content, audited figures, and assured ESG data: this part is provided by your company and its specialized unit. For long reports, you should clearly state in the contract the rights to the source files, so that the internal team can update the figures for subsequent periods without starting from scratch.
This article is for reference. The scope, pricing, and specific commitments of Sinh Vũ are detailed in the proposal and signed contract.