Updated: 10 November 2026

The amended Law on Investment (Law No. 24/2026/QH16) takes effect on 1 March 2027. This note explains what changes, how to check whether your business lines are affected, and which licences and pending applications foreign investors and foreign-invested enterprises (FIEs) should review before that date.

1. Law No. 24/2026/QH16: effect and scope

Law No. 24/2026/QH16 amends the Law on Investment No. 143/2025/QH15, which has applied since 1 March 2026. According to the introduction published by the State Audit Office, the Law "takes effect from 1 March 2027, except for the provisions in Clause 2 of this Article", and the provisions on N2O take effect from 1 January 2027.

The Law focuses on Article 6 (prohibited business lines), Appendix IV (conditional business lines), amendments to Article 88 of the Law on Construction No. 135/2025/QH15, repeal of Article 29.6 of the Law on Roads No. 35/2024/QH15, and transitional rules. It does not amend the procedures for the IRC, establishing an economic organisation, or capital contribution and share acquisition. The main impact therefore lies in the business conditions attached to each business line.

2. The new list of conditional business lines

Under Article 1 of the Law, Appendix IV is replaced by the appendix issued with Law No. 24/2026/QH16. The Government's policy portal states that the Law "removes 62 business lines and amends 14" compared with the 2025 Law; the State Audit Office introduction states the list falls from 142 to 137 conditional lines. The Ministry of Finance estimates about 786 business conditions and 232 administrative procedures will be cut, saving about VND 175 billion a year in compliance costs.

For foreign investors, business conditions apply alongside market access conditions. A line removed from Appendix IV is not automatically open to foreign investors: market access under Article 8 of the Law on Investment and Vietnam's international commitments must still be checked. 7S Law recommends that FIEs compare the lines on their ERC, IRC and sub-licences with the new appendix to see which licences must be maintained and which need not be renewed.

3. New conditional line: visa support services

The Law adds "visa application support services provided by authorised businesses" as item 137 of the list. The Government will regulate transitional handling. As of 23 October 2026, no implementing decree on the conditions for this service had been published on the Government portal. Investors providing or planning this service should prepare their legal documents and licensing roadmap early.

4. Ban on N2O trading from 1 January 2027

The Law adds point (m) to Article 6.1: trading N2O gas for human inhalation, except for medical purposes and other excluded uses such as food technology, testing and scientific research, as detailed by the Government. The number of prohibited lines rises from 11 to 12. Suppliers of industrial and food gases should identify customers' end use and adjust contracts.

5. Transition: existing licences, pending applications and N2O contracts

• Lines removed from the list. Businesses may operate without meeting investment conditions; licences, certificates and practising certificates already issued remain usable until expiry without renewal or adjustment.
• Pending applications. For applications filed validly before the effective date but not yet decided, the authority will notify suspension and return the file.
• N2O contracts. Parties must liquidate prohibited contracts within 45 days from 1 January 2027.
• Visa support services. The Government will regulate transitional handling.

6. IRC procedures remain unchanged

The IRC procedure continues under the Law on Investment No. 143/2025/QH15 and Decree No. 96/2026/ND-CP dated 31 March 2026. Article 26.1(a) requires an IRC for "investment projects of foreign investors". Capital contribution or share acquisition does not always require an IRC but must be registered in the cases set out in Article 21.3. Article 19.2 still allows foreign investors to "establish an economic organisation to implement an investment project before carrying out the procedure for issuance or adjustment of the IRC". Where project objectives or business lines change under a new business plan, the IRC may need to be adjusted.

7. Illustrative scenarios

Scenario 1. Company A (hypothetical), wholly foreign-owned, has a business line removed from Appendix IV. Its eligibility certificate is valid until 2028, and it filed an additional licence application in January 2027. The existing certificate remains usable until expiry; the pending application, if undecided by 1 March 2027, will be returned. Company A should confirm early whether the line truly loses its conditions before pursuing the application.

Scenario 2. Company B (hypothetical), foreign-invested, distributes gas to food producers and restaurants. From 1 January 2027 it must classify customers by end use and liquidate prohibited contracts within the deadline above.

8. Practical notes

Risks. Continuing a newly prohibited activity, or a newly conditional one without a licence, may lead to penalties and affect investment files; maintaining licences no longer required adds cost.

Impact. FIEs can streamline compliance but must identify correctly which lines benefit; implementing decrees on N2O and visa services had not been issued at the time of writing.

Recommendations. Inventory business lines and licences before December 2026; close out N2O contracts before 1 January 2027; always assess market access separately.

9. How 7S Law can help

• Map the lines on your ERC and IRC against the new appendix and market access conditions, with a conclusion per line.
• Identify which sub-licences to maintain, which remain valid until expiry, and which pending files to handle.
• Obtain business licences for conditional lines and review or liquidate affected contracts.
• Handle company formation, IRC issuance and adjustment under the current Law on Investment.

10. Frequently asked questions

Does the amended Law change the IRC procedure?
No. Key dates: N2O contracts liquidated within 45 days from 1 January 2027; new list from 1 March 2027; undecided applications for removed lines returned after that date.

My line has been removed from the list. Do I need to do anything?
From 1 March 2027 you may operate without meeting investment conditions, and existing licences remain valid until expiry. Foreign investors must still check market access.

What are the State fees?
The Law sets no new fees; each sub-licence follows sectoral and fee legislation.

What should I send 7S Law for a review?
Copies of the ERC, IRC, a list of sub-licences with expiry dates, and pending applications. Information is kept confidential.

Appendix: Legal basis

Quoted provisions are unofficial translations by 7S Law. Some quotations of Law No. 24/2026/QH16 are taken from official introductory materials published on government portals.

Author: Lawyer Hoang Thi Thuong

This article is for reference only and reflects the law in force at the date of update. Please consult a lawyer on your specific case before acting.

Contact 7S Law: +84 877 523 888 – lienhe@7slaw.vn