--- title: Reading Insider and Affiliated Party Trading Disclosures description: A practical guide to reading insider and affiliated trading disclosures, separating intent from executed orders under Vietnamese market transparency rules. url: https://ginity.vn/en/blog/reading-insider-and-affiliated-party-trading-disclosures canonical: https://ginity.vn/en/blog/reading-insider-and-affiliated-party-trading-disclosures markdown: https://ginity.vn/en/blog/reading-insider-and-affiliated-party-trading-disclosures.md language: en datePublished: 2026-10-30T00:00:00+07:00 dateModified: 2026-10-30T00:00:00+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: [] sources: - name: Government News url: https://baochinhphu.vn/quy-dinh-moi-ve-cong-bo-thong-tin-tren-thi-truong-chung-khoan-102284219.htm title: New Regulations on Information Disclosure in the Stock Market - name: Ministry of Finance url: https://vanban.chinhphu.vn/?docid=201902&pageid=27160 title: Circular 96/2020/TT-BTC Guiding Information Disclosure on the Stock Market - name: National Assembly url: https://vanban.chinhphu.vn/?docid=198541&pageid=27160 title: Law on Securities No. 54/2019/QH14 - name: Government url: https://vanban.chinhphu.vn/?docid=202223&pageid=27160 title: Decree 156/2020/ND-CP on Penalties for Administrative Violations in Securities - name: Tin Nhanh Chung Khoan url: https://www.tinnhanhchungkhoan.vn/cong-bo-thong-tin-nhung-dieu-can-nam-post292759.html title: "Information Disclosure: Key Essentials to Master" - name: CafeF url: https://cafef.vn/muon-van-ly-do-khi-lanh-dao-va-nguoi-nha-mua-ban-chui-co-phieu-tu-loi-danh-may-do-thu-ky-dat-nham-lenhden-thua-nhan-chua-nam-ro-quy-dinh-188230817233135848.chn title: Countless Excuses for Unannounced Insider Trades by Corporate Leaders 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 Insider and Affiliated Party Trading Disclosures > A practical guide to reading insider and affiliated trading disclosures, separating intent from executed orders under Vietnamese market transparency rules. Gini · Learn investing · 2026-10-30 · https://ginity.vn/en/blog/reading-insider-and-affiliated-party-trading-disclosures _Lead analyst: Đào Ngọc Bảo Linh · Finance and securities specialist · Ho Chi Minh City · 0932 439 639_ ## Key takeaways - Insiders and affiliated persons must submit transaction notices at least 03 working days prior to executing trades under Circular 96/2020/TT-BTC. - The mandatory disclosure threshold triggers at VND 50 million in daily transaction value or VND 200 million within a calendar month based on par value. - Registration filings only indicate planned intent; investors must verify final execution reports submitted within 05 working days to confirm filled volumes. - The trade execution rate reveals the actual completion percentage, such as reaching 60% when executing 120,000 out of 200,000 registered shares. Trading filings submitted by corporate management and their affiliated entities consistently attract substantial market scrutiny. Executive leaders possess direct visibility into operating earnings, corporate strategy, and balance sheet conditions. To preserve market fairness and curb information asymmetry, the Vietnamese securities legal framework mandates standardized advance notifications and post-trade execution filings under rigorous statutory deadlines. ## Who Qualifies as an Insider or Affiliated Party? Under Clause 45 and Clause 46 of Article 4 in the [Law on Securities No. 54/2019/QH14](https://vanban.chinhphu.vn/?docid=198541&pageid=27160), internal insiders and affiliated parties are defined by statutory roles and familial relationships. Internal insiders encompass pivotal management personnel in public companies, including the Chairman of the Board of Directors, Board members, legal representatives, the General Director or Director, Deputy General Directors or Deputy Directors, the Chief Accountant, the Head and members of the Supervisory Board, the person in charge of corporate governance, and authorized information disclosure representatives. Affiliated parties include biological or adoptive parents, stepparents, parents-in-law, spouses, biological or adopted children, daughters-in-law, sons-in-law, and biological siblings. Entities where an insider or their family members exercise voting control or represent capital contributions are also classified as affiliated parties under the [Law on Securities No. 54/2019/QH14](https://vanban.chinhphu.vn/?docid=198541&pageid=27160). ## Disclosure Deadlines and Value Thresholds To enhance market transparency, the Ministry of Finance updated disclosure standards effective 1 January 2021, as highlighted by Government News in [New Regulations on Information Disclosure in the Stock Market](https://baochinhphu.vn/quy-dinh-moi-ve-cong-bo-thong-tin-tren-thi-truong-chung-khoan-102284219.htm). According to Article 33 of [Circular 96/2020/TT-BTC](https://vanban.chinhphu.vn/?docid=201902&pageid=27160), pre-trade and post-trade reporting obligations apply whenever the expected transaction value reaches VND 50 million or more in a single trading day, or VND 200 million or more within one calendar month calculated at par value (VND 10,000 per share). This statutory threshold corresponds to trading volumes ranging from 5,000 shares to 20,000 shares. Pursuant to Clause 1, Article 33 of [Circular 96/2020/TT-BTC](https://vanban.chinhphu.vn/?docid=201902&pageid=27160), insiders and affiliated persons must deliver formal written notices to the State Securities Commission and the relevant stock exchange at least 03 working days before the scheduled transaction date. The execution window specified in the registration notice cannot exceed 30 days from the transaction registration date under Point b, Clause 1, Article 33 of [Circular 96/2020/TT-BTC](https://vanban.chinhphu.vn/?docid=201902&pageid=27160). Following transaction completion or expiry of the registration window, the individual must submit a final execution report within 05 working days pursuant to [Circular 96/2020/TT-BTC](https://vanban.chinhphu.vn/?docid=201902&pageid=27160). | Statutory Metric | Requirement Specification | Legal Basis | | :--- | :--- | :--- | | Daily value threshold | From VND 50 million at par value (5,000 shares) | Article 33 Circular 96/2020/TT-BTC | | Monthly value threshold | From VND 200 million at par value (20,000 shares) | Article 33 Circular 96/2020/TT-BTC | | Pre-trade filing deadline | At least 03 working days before trading begins | Article 33 Circular 96/2020/TT-BTC | | Maximum trading window | Up to 30 days from the transaction registration date | Article 33 Circular 96/2020/TT-BTC | | Post-trade filing deadline | Within 05 working days after trade completion | Article 33 Circular 96/2020/TT-BTC | Source: [Ministry of Finance](https://vanban.chinhphu.vn/?docid=201902&pageid=27160). ```flow Step 1: Pre-trade disclosure at least 03 working days prior Insiders and affiliated persons submit formal notices to the State Securities Commission and the exchange at least 03 working days before trading begins. Step 2: Post-trade reporting within 05 working days after execution Within 05 working days following transaction completion or expiration of the trading window, the individual files a final execution report and explains reasons if orders were unfilled. ``` Executing unannounced trades or failing to comply with registered timelines triggers regulatory fines under Article 33 of [Decree 156/2020/ND-CP](https://vanban.chinhphu.vn/?docid=202223&pageid=27160), scaled directly to the transaction value. The financial publication Tin Nhanh Chung Khoan in [Information Disclosure: Key Essentials to Master](https://www.tinnhanhchungkhoan.vn/cong-bo-thong-tin-nhung-dieu-can-nam-post292759.html) notes that public companies must master information disclosure regulations to avoid regulatory penalties and build trust with shareholders and investors. ## Key Components of an Insider Trading Notice A standard disclosure notice filed under the statutory appendices of [Circular 96/2020/TT-BTC](https://vanban.chinhphu.vn/?docid=201902&pageid=27160) contains several critical data fields: 1. Trader identity: Full name, current corporate title, or specific familial relationship to an internal insider. 2. Stock ticker: The exchange ticker symbol of the listed or public trading company. 3. Pre-transaction share ownership: Total number of shares and voting percentage held before the trade. 4. Registered volume: Exact quantity of shares registered for purchase or divestment. 5. Trading method: Order-matching on the central electronic order book or negotiated block transactions. 6. Stated transaction purpose: Personal financial liquidity, portfolio restructuring, or asset transfer. 7. Projected timeline: The formal trading window within the statutory limit of 30 days. ## Separating Registration Plans from Final Execution A common analytical mistake among market observers is equating a transaction registration with executed trading volume. The registration filing reflects initial intentions, whereas actual trading outcomes reside in the final execution report. Under point b, clause 1, Article 33 of [Circular 96/2020/TT-BTC](https://vanban.chinhphu.vn/?docid=201902&pageid=27160), insiders must trade the volume they announced; if the order is not fully matched, point đ of clause 1 requires a report and explanation within 05 working days. Market coverage by CafeF in [Countless Excuses for Unannounced Insider Trades by Corporate Leaders](https://cafef.vn/muon-van-ly-do-khi-lanh-dao-va-nguoi-nha-mua-ban-chui-co-phieu-tu-loi-danh-may-do-thu-ky-dat-nham-lenhden-thua-nhan-chua-nam-ro-quy-dinh-188230817233135848.chn) documented typical excuses given for disclosure violations, such as typographical errors, administrative mistakes by assistants, accidental order placements, or unfamiliarity with legal regulations. Consequently, market participants avoid drawing premature trading conclusions based solely on the initial filing. Any meaningful evaluation of shifts in managerial ownership requires waiting for the official post-trade report issued after the trading window closes as stipulated in [Circular 96/2020/TT-BTC](https://vanban.chinhphu.vn/?docid=201902&pageid=27160). ## Hypothetical Example of Order Execution Rates To assess how much of an insider filing materialized into actual market supply or demand, analysts calculate the execution completion rate: $$\text{Execution Rate} = \frac{\text{Shares Actually Traded}}{\text{Shares Registered}} \times 100\%$$ Suppose that in October 2026, a member of the Board of Directors holding 500,000 shares filed a registration notice to sell 200,000 shares for personal financial purposes, adhering to the statutory template under [Circular 96/2020/TT-BTC](https://vanban.chinhphu.vn/?docid=201902&pageid=27160). At the conclusion of the 30-day window, the final execution report submitted to the State Securities Commission confirmed that only 120,000 shares were sold via order-matching because market prices drifted below the seller target. Applying the execution formula: $$\text{Execution Rate} = \frac{120,000}{200,000} \times 100\% = 60\%$$ The insider remaining share ownership decreased from 500,000 shares to 380,000 shares. Verifying final execution numbers ensures that market participants evaluate actual corporate supply rather than initial paper registrations. ## Where to Access Official Regulatory Disclosures To review original insider filings and filter out unverified rumors across social media forums, primary reporting platforms provide verified records: - The electronic disclosure portal of the stock exchange where the shares are listed or traded. - The official disclosure system maintained by the State Securities Commission under the legal framework established by the [Law on Securities No. 54/2019/QH14](https://vanban.chinhphu.vn/?docid=198541&pageid=27160). - The Investor Relations section hosted on the official corporate website of the issuing enterprise. Accessing official disclosures with digital signatures or regulatory stamps ensures reliable and timely data for disciplined market analysis. ## Sources - Government News: [New Regulations on Information Disclosure in the Stock Market](https://baochinhphu.vn/quy-dinh-moi-ve-cong-bo-thong-tin-tren-thi-truong-chung-khoan-102284219.htm) (11/12/2020) - Ministry of Finance: [Circular 96/2020/TT-BTC Guiding Information Disclosure on the Stock Market](https://vanban.chinhphu.vn/?docid=201902&pageid=27160) (16/11/2020) - National Assembly: [Law on Securities No. 54/2019/QH14](https://vanban.chinhphu.vn/?docid=198541&pageid=27160) (26/11/2019) - Government: [Decree 156/2020/ND-CP on Penalties for Administrative Violations in Securities](https://vanban.chinhphu.vn/?docid=202223&pageid=27160) (31/12/2020) - Tin Nhanh Chung Khoan: [Information Disclosure: Key Essentials to Master](https://www.tinnhanhchungkhoan.vn/cong-bo-thong-tin-nhung-dieu-can-nam-post292759.html) (17/03/2022) - CafeF: [Countless Excuses for Unannounced Insider Trades by Corporate Leaders](https://cafef.vn/muon-van-ly-do-khi-lanh-dao-va-nguoi-nha-mua-ban-chui-co-phieu-tu-loi-danh-may-do-thu-ky-dat-nham-lenhden-thua-nhan-chua-nam-ro-quy-dinh-188230817233135848.chn) (18/08/2023) --- _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._