REGULATIONS ON ADMINISTRATIVE PENALTIES IN THE CUSTOMS SECTOR UNDER DECREE 169/2026/NĐ-CP

REGULATIONS ON ADMINISTRATIVE PENALTIES IN THE CUSTOMS SECTOR UNDER DECREE 169/2026/NĐ-CP

To support businesses in promptly updating new regulations related to administrative penalties in the Customs sector, THT Cargo Logistics would like to summarize key highlights under Decree 169/2026/NĐ-CP and implementation guidance issued by the Customs authority.

The new Decree will directly impact customs declaration activities, document processing, and legal compliance for import-export businesses in the coming period.

1. Effective Date of Decree 169/2026/NĐ-CP

According to the new regulation:

  • Decree 169/2026/NĐ-CP officially takes effect from July 1, 2026.
  • At the same time, it replaces:
    • Decree 128/2020/NĐ-CP
    • Decree 102/2021/NĐ-CP

The issuance of the new Decree aims to:

  • Update penalty regulations in line with actual operational conditions
  • Enhance consistency in Customs management
  • Improve the enforcement mechanism for violations in import-export activities
  • Strengthen business compliance

2. Important Transitional Provisions

One of the most important points businesses should pay attention to is the transitional provision for violations occurring before Decree 169 officially takes effect.

For violations arising before July 1, 2026 but discovered or processed by Customs authorities after Decree 169 takes effect, Decree 169/2026/NĐ-CP will apply if:
  • There is no longer any penalty regulation for such violations; or
  • The penalty under Decree 169 is lighter than the previous regulation.

This regulation helps ensure:

  • Fairness in handling violations
  • Application of more favorable regulations for businesses under the law
  • Reduced risk of penalties that are no longer suitable under the new regulations

3. What Should Businesses Prepare?

To minimize risks during the transition period of the new Decree, businesses should proactively:

  • Review internal Customs declaration procedures
  • Check pending or unfinished Customs dossiers and declarations
  • Update new penalty regulations for import-export and compliance teams
  • Train employees involved in Customs operations
  • Coordinate with customs brokers and logistics providers to minimize declaration errors

Early preparation will help businesses:

  • Reduce the risk of administrative violations
  • Minimize penalty risks and customs clearance delays
  • Ensure stable import-export operations
  • Enhance Customs compliance

4. Reference Documents

📄 Official Letter 16491 on the Implementation of Decree 169

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📄 Appendix for the Implementation of Decree 169

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📄 Decree 169

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5. Perspective from THT Cargo Logistics

The issuance of Decree 169/2026/NĐ-CP reflects the increasing trend toward stricter management and stronger compliance requirements in Customs and import-export activities.

As the legal framework continues to evolve, businesses should proactively update new regulations and standardize declaration procedures to minimize operational risks during customs clearance.

THT Cargo Logistics currently supports businesses in:

  • Reviewing Customs compliance
  • Checking Customs dossiers and declaration procedures
  • Providing consultation on Customs violation-related issues
  • Supporting updates on new import-export regulations

Need Support Reviewing Customs Compliance?

THT Cargo Logistics is ready to support businesses in updating new regulations, reviewing declaration procedures, and consulting on issues related to Customs procedures and import-export compliance.

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