Sanctioning for administrative violations in the securities and securities market for GKM Holdings Joint Stock Company

Notably, the violations span three reporting cycles — Q1–Q3 2025 financials, 2025 audited and reviewed statements, the 2025 annual report, and 2026 semi-annual governance and financial statements — indicating a systemic breakdown in the company's disclosure calendar rather than an isolated lapse. Critically, the case demonstrates that Vietnam's post-Decree 306/2025 enforcement regime is now actively applied, with amended provisions under the November 2025 decree being invoked in live penalties. The tiered fine structure also shows that being 'less than 15 days late' does not shield issuers from sanction — it merely reduces exposure.

For compliance teams at listed companies and their advisers, this is a concrete signal that regulators are auditing filing cadence against multiple document types, including governance reports, not just financial statements. Recommended actions: conduct an immediate disclosure calendar gap assessment across all periodic filings and event-based disclosures; verify processes against the amended Decree 156/2020 regime as updated by Decree 306/2025; assign named ownership for each filing type with escalation protocols; and review internal controls to ensure completeness, not just timeliness, of submissions. Firms operating cross-border or advising Vietnamese issuers should incorporate this enforcement pattern into their disclosure risk frameworks and board reporting.