Investment funds: ILPA and SSC, when is it mandatory

ILPA (Institutional Limited Partners Association) and SSC (State Securities Commission, associated with Circular 96/2020/TT-BTC) are two different standards in nature, not two versions of the same requirement. Confusing them can lead to one of two mistakes: either putting effort into unnecessary areas or missing what international LPs actually require during the evaluation process.

The essence of each standard set.

The ILPA Reporting Template is a voluntary reporting template developed and updated by the LP community to standardize the presentation of fees, costs, and carried interest between GPs and LPs. Version 2.0, effective from Q1 2026, is more detailed than the original 2016 version. No legal authority mandates funds to comply with ILPA, but many large LPs have made using this template a condition for committing capital to new funds.

Circular 96/2020/TT-BTC is a legal document issued by the Ministry of Finance, applicable to public companies and listed organizations in Vietnam, regulating the obligation to disclose information under the supervision of SSC. This is a legal obligation, not a recommendation.

When is ILPA necessary, and when is SSC mandatory?

Four real situations you need to differentiate:

• Private fund raising from international institutional LPs: Not mandatory by law, but ILPA should be considered a default requirement. Many large LPs include ILPA reporting templates in their due diligence document lists and as a condition before committing capital.
• Public fund or listed in Vietnam: Mandatory under Circular 96. No exceptions based on size or type of investor.
• Domestic fund with foreign LP: Requires both layers. Circular 96 addresses domestic legal obligations, while ILPA meets the transparency expectations of international LPs.
• Small private fund, close individual investors: Full ILPA compliance is not immediately necessary, but early standardization of the structure avoids having to redo everything when institutional LPs join later.

Most common mistakes

• Confusing ILPA with legal regulations and then allocating resources to it when the fund does not yet have an organized LP, while the actual SSC obligations are overlooked.
• Thinking that being part of ILPA automatically meets the requirements of Circular 96, while these two do not replace each other.
• Presenting capital account statements and fee schedules in different formats each period, making it impossible to compare across stages.
• Waiting until the LP requests it during the assessment process to create a reporting standard may not meet the committed timeline.

Reporting standards are not just to "have for the record". They are what LP uses to check if GP is operating transparently. Disorganized presentation, even with correct data, sends the wrong signal.

Practical experience, Sinh Vũ Studio

The viewpoint of Sinh Vũ

Sinh Vũ is not a fund management entity or legal advisor. Determining whether the fund is public or private, and verifying compliance data, you need to do with a qualified professional entity.

What Sinh Vũ does next: once you know the budget needs to follow ILPA, according to Circular 96, or both, Sinh Vũ transforms that framework into a presentation that LP can quickly scan and trust. Capital account statements, fee tables, and portfolio performance are organized for easy comparison across each period. Sinh Vũ creates a master template so that each period only requires updating the data while maintaining a consistent appearance, avoiding the situation where each report has a different structure that forces LP to read from the beginning.