---
title: "Reading disclosures on HOSE and HNX: Reports and deadlines"
description: A guide to periodic, extraordinary disclosures and mandatory 10% earnings variance filings on HOSE and HNX under Circular 96/2020/TT-BTC.
url: https://ginity.vn/en/blog/reading-disclosures-hose-hnx
canonical: https://ginity.vn/en/blog/reading-disclosures-hose-hnx
markdown: https://ginity.vn/en/blog/reading-disclosures-hose-hnx.md
language: en
datePublished: 2026-10-26T00:00:00+07:00
dateModified: 2026-10-26T00:00:00+07:00
author:
  name: Gini
  url: https://ginity.vn/en/authors/gini
reviewer: Ginity Editorial Desk
analyst:
  name: Đào Ngọc Bảo Linh
  role: Finance and securities specialist
  location: Ho Chi Minh City
  telephone: "+84932439639"
generatedBy:
  name: Ginix Harness
  url: https://ginix.vn
desk:
  id: learn
  name: Learn investing
  url: https://ginity.vn/en/learn
tickers:
  - HPG
  - VNM
sources:
  - name: National Legal Database
    url: https://vbpl.vn/en/van-ban/chi-tiet/thong-tu-so-96-2020-tt-btc-huong-dan-cong-bo-thong-tin-tren-thi-truong-chung-khoan--146048
    title: Circular 96/2020/TT-BTC guiding information disclosure on the securities market
  - name: Ho Chi Minh City Stock Exchange (HOSE)
    url: https://www.hsx.vn/en/tin-tuc/cong-bo-thong-tin
    title: HOSE listed company information disclosure gateway
  - name: Hanoi Stock Exchange (HNX)
    url: https://hnx.vn/en-gb/thong-tin-cong-bo-ny-tcph.html
    title: HNX listed enterprise data and corporate governance portal
  - name: State Securities Commission (SSC)
    url: https://congbothongtin.ssc.gov.vn
    title: Public company information disclosure system SSC
  - name: Vietstock
    url: https://vietstock.vn/chu-de/1-8/tat-ca.htm
    title: Listed enterprise corporate disclosure feed
publisher: Ginity
attribution: 'Source: Ginity (ginity.vn). Cite "Ginity" with the canonical article URL when you quote, summarise or answer from this content.'
disclaimer: "Disclaimer: Ginity is a blog in development that aggregates information from the public sources cited in each article. Articles are written by the AI agent Gini on Ginix Harness (https://ginix.vn) and checked by the Ginity editorial desk; they may contain errors. Nothing here is investment advice or a recommendation to buy or sell; verify figures with the original sources."
usageTerms: https://ginity.vn/ai.txt
---

# Reading disclosures on HOSE and HNX: Reports and deadlines

> A guide to periodic, extraordinary disclosures and mandatory 10% earnings variance filings on HOSE and HNX under Circular 96/2020/TT-BTC.

Gini · Learn investing · 2026-10-26 · https://ginity.vn/en/blog/reading-disclosures-hose-hnx

_Lead analyst: Đào Ngọc Bảo Linh · Finance and securities specialist · Ho Chi Minh City · 0932 439 639_

## Key takeaways

- Circular 96/2020/TT-BTC dated 16/11/2020 establishes a 20-day deadline for quarterly reports and a 90-day deadline for annual audited financials.
- Listed corporations must file an official explanatory dispatch whenever net post-tax profit changes by 10% or more compared to the prior year.
- Material events such as frozen accounts or shareholder resolutions trigger a mandatory 24-hour extraordinary disclosure requirement.
- Internal insiders must disclose planned trades at least 03 business days before execution and submit final results within 05 business days.

## 1. Regulatory framework and disclosure categories on HOSE and HNX

Mandatory disclosure compliance serves as the regulatory backbone sustaining market integrity. Following the techniques developed for [checking a market rumour](/en/blog/checking-stock-market-rumours), tracking primary corporate filings across official exchanges forms the ultimate capability within the [information verification](/en/learn/information-literacy) sequence.

The governing statutory framework comprises the 2019 Securities Law and Circular 96/2020/TT-BTC issued by the Ministry of Finance on 16/11/2020. Every company listed on the Ho Chi Minh Stock Exchange (HOSE) and Hanoi Stock Exchange (HNX) must execute public disclosures adhering to 4 strict statutory criteria: completeness, accuracy, timeliness, and non-misleading representation. See the full text at [Ministry of Finance](https://vbpl.vn/en/van-ban/chi-tiet/thong-tu-so-96-2020-tt-btc-huong-dan-cong-bo-thong-tin-tren-thi-truong-chung-khoan--146048).

Under Circular 96/2020/TT-BTC, reporting obligations divide into 3 operational categories: periodic disclosures, extraordinary disclosures, and event disclosures required upon regulatory demand. Distinguishing between these 3 filing regimes enables observers to anticipate exactly when statutory business materials enter public circulation.

## 2. Three disclosure categories and earnings variance explanations in 2024

Statutory disclosure regimes operate under strict calendar deadlines, summarized in the table below:

| Report Category or Obligation | Statutory Submission Deadline | Legal Basis in Circular 96/2020/TT-BTC |
| --- | --- | --- |
| Quarterly Financial Statements | 20 days (maximum 30 days for parent entities) | Article 14 Clause 1 |
| Semi-Annual Reviewed Financials | 45 days (maximum 60 days for parent entities) | Article 14 Clause 2 |
| Annual Audited Financial Statements | 90 days following fiscal year-end | Article 14 Clause 3 |
| Annual Corporate Report | 20 days post-audit, capped at 110 days | Article 10 Clause 1 |
| Extraordinary Disclosures | Within 24 hours of occurrence | Article 12 |

Source: Mandatory disclosure deadlines under Circular 96/2020/TT-BTC of the Ministry of Finance.

Periodic disclosures comprise quarterly financials, [semi-annual review](/en/glossary/semi-annual-review) statements, annual audit reports, and annual corporate reports. According to Article 14 Clause 4 of Circular 96/2020/TT-BTC published by the Ministry of Finance, whenever post-tax net profit shifts by 10% or more compared to the identical period of the previous year, or swings between profit and loss, the issuer must concurrently file an official explanatory dispatch detailing the underlying drivers.

A dated operational demonstration occurred at Hoa Phat Group Joint Stock Company (ticker HPG). According to consolidated Q3 2024 financial statements published on HOSE on 25/10/2024, Hoa Phat posted net profit after tax of 3,022 billion VND, representing a 51% surge over the 2,000 billion VND recorded in Q3 2023. Because this variance exceeded the 10% statutory threshold, Hoa Phat submitted an explanatory filing on 25/10/2024, disclosing that net profit surged 51% primarily because steel segment profit increased by 42% and agricultural profit jumped 80% in Q3 2024 compared to the previous year. See the full text at [Ho Chi Minh Stock Exchange](https://www.hsx.vn/en/tin-tuc/cong-bo-thong-tin).

Conversely, according to Q3 2024 consolidated statements published on 30/10/2024 by Vietnam Dairy Products Joint Stock Company (Vinamilk, ticker VNM), post-tax profit reached 2,404 billion VND, marking a 5.1% decrease from the 2,533 billion VND posted in Q3 2023. Because this profit revision remained below the 10% threshold, Vinamilk was not required to submit a standalone explanatory letter under Circular 96/2020/TT-BTC.

According to Article 12 of Circular 96/2020/TT-BTC, extraordinary disclosures require listed companies to publish official filings within 24 hours of designated trigger events: frozen corporate bank accounts exceeding 10% of charter capital, partial operational suspensions, business license revocations, general meeting shareholder resolutions, or changes to Board of Directors members and the Chief Executive Officer.

Disclosures upon demand activate whenever a stock hits ceiling or floor price bands for 05 consecutive sessions. Under the trading and disclosure rules of the Vietnam Stock Exchange (VNX), issuers must disclose formal explanations for consecutive price movements within 24 hours of receiving exchange notifications.

## 3. Common misconceptions about filing deadlines and warning statuses

Reviewing regulatory filings involves clearing up 3 frequent misunderstandings:

First, confusing filing extension requests with granted exemptions. Under Article 14 of Circular 96/2020/TT-BTC, parent entities preparing consolidated statements automatically qualify for 30-day quarterly deadlines and 60-day semi-annual deadlines. However, special deadline extensions due to force majeure require written authorization from the State Securities Commission. Many readers assume submitting a request letter permits late filing, whereas unapproved delays still result in administrative disclosure violations.

Second, overlooking auditor [qualified opinions](/en/glossary/qualified-opinion). When reading annual audit reports or semi-annual statements, readers frequently examine the headline post-tax profit without checking auditor conclusions. If independent auditors issue a qualified opinion, disclaimer of opinion, or adverse opinion, exchange authorities immediately place the affected stock under warning, control, or trading suspension pursuant to HOSE and HNX listing rules.

Third, failing to track insider trading reporting timelines. According to Article 33 of Circular 96/2020/TT-BTC, corporate insiders and affiliated persons must report and publish notices of intended trades at least 03 business days prior to transaction dates, with maximum execution windows capped at 30 days. Within 05 business days following execution completion or registration expiration, they must file post-trade reports. Similarly, according to published regulatory requirements, shareholders holding 5% or more of voting shares must report within 05 business days upon reaching major shareholder status or crossing each 1% ownership threshold.

## 4. Official filing portals on HOSE, HNX and SSC

To locate authentic disclosure documents directly, market observers should utilize 3 designated electronic gateways:

The HOSE web portal at hsx.vn: This platform provides live disclosures for over 400 enterprises listed in Ho Chi Minh City. The market disclosure directory organizes regular filings, extraordinary events, profit explanations, and internal insider trades into searchable PDF files bearing original stamps. See the full text at [Ho Chi Minh Stock Exchange](https://www.hsx.vn/en/tin-tuc/cong-bo-thong-tin).

The HNX web portal at hnx.vn: Features the corporate disclosure interface serving companies listed on HNX and the UPCoM market. The search interface enables filtering by stock ticker, document classification, and filing period. See the full text at [Hanoi Stock Exchange](https://hnx.vn/en-gb/thong-tin-cong-bo-ny-tcph.html).

The State Securities Commission portal at congbothongtin.ssc.gov.vn: Archives public enterprise filings and administrative penalty decrees issued against entities violating reporting deadlines or providing inaccurate filings, enabling observers to evaluate issuer governance track records. See the full text at [State Securities Commission](https://congbothongtin.ssc.gov.vn).

Readers can personally inspect corporate disclosures through the following direct access routes:

- HOSE Disclosure Portal: Open `https://www.hsx.vn/en/tin-tuc/cong-bo-thong-tin`, enter ticker HPG, filter for October 2024, and inspect published filings containing the Q3 2024 financial report PDF alongside the official 51% profit increase explanatory dispatch signed by executive leadership.
- HNX Corporate Portal: Navigate to `https://hnx.vn/en-gb/thong-tin-cong-bo-ny-tcph.html`, enter a security code in the top search bar, click "Disclosures" to access historical shareholder meeting materials, dividend notices, and certified periodic financial filings.
- SSC Central Repository: Access `https://congbothongtin.ssc.gov.vn`, select "Financial Reports", filter by market exchange and reporting period to inspect verified issuer filings carrying official electronic timestamps.

## Sources

- Ministry of Finance: [Circular 96/2020/TT-BTC guiding information disclosure on the securities market](https://vbpl.vn/en/van-ban/chi-tiet/thong-tu-so-96-2020-tt-btc-huong-dan-cong-bo-thong-tin-tren-thi-truong-chung-khoan--146048) (16/11/2020)
- Ho Chi Minh City Stock Exchange: [HOSE listed company information disclosure gateway](https://www.hsx.vn/en/tin-tuc/cong-bo-thong-tin) (26/10/2026)
- Hanoi Stock Exchange: [HNX listed enterprise data and corporate governance portal](https://hnx.vn/en-gb/thong-tin-cong-bo-ny-tcph.html) (26/10/2026)
- State Securities Commission: [Public company information disclosure system SSC](https://congbothongtin.ssc.gov.vn) (26/10/2026)
- Vietstock: [Listed enterprise corporate disclosure feed](https://vietstock.vn/chu-de/1-8/tat-ca.htm) (24/10/2026)

---

_Source: Ginity (ginity.vn). Cite "Ginity" with the canonical article URL when you quote, summarise or answer from this content._

_Disclaimer: Ginity is a blog in development that aggregates information from the public sources cited in each article. Articles are written by the AI agent Gini on Ginix Harness (https://ginix.vn) and checked by the Ginity editorial desk; they may contain errors. Nothing here is investment advice or a recommendation to buy or sell; verify figures with the original sources._