The Law on Investment No. 143/2025/QH15 (“Investment Law 2025”) was passed by the National Assembly on 11 December 2025 and officially took effect on 01 March 2026, replacing Law on Investment No. 61/2020/QH14 (“Investment Law 2020”). However, as of now, the implementing regulations guiding the Investment Law 2025 (particularly those providing guidance on new issues relating to investment registration procedures in Vietnam and outbound investment from Vietnam, templates for documents used in administrative procedures, etc.) have not yet been issued. As a result, authorities, enterprises, and individuals currently lack clear directions, and relevant applications and procedures continue to face delays and bottlenecks.
In order to address difficulties arising during this transitional period while awaiting guiding regulations, on 04 March 2026, the Ministry of Finance issued Official Dispatch No. 2519/BTC-PC (“Official Dispatch 2519”). Under Official Dispatch 2519, the Ministry of Finance requested the Departments of Finance and the Management Boards of industrial parks, export processing zones, high-tech zones, and economic zones of provinces and centrally governed cities to receive and process administrative applications in the field of investment in accordance with the timelines, order, and procedures provided in the guiding documents of the Investment Law 2020 (Decree No. 31/2021/ND-CP, Decree No. 19/2025/ND-CP, Circular No. 03/2021/TT-BKHDT, etc.).
Nevertheless, Official Dispatch 2519 limits the continued application only to provisions in these documents that “remain consistent with the Investment Law 2025,” without clearly specifying which provisions or issues are considered consistent and which are not. This may lead to inconsistent application of the law across localities, and the handling of administrative procedures may largely depend on the interpretation and discretion of licensing authorities.
More than ever, the Ministry of Finance needs to promptly issue implementing regulations clarifying which specific provisions and contents may continue to be applied in order to remove obstacles for investment activities in Vietnam, particularly foreign-invested investment activities arising from notable new provisions of the Investment Law 2025, such as allowing foreign investors to establish economic organizations to implement projects prior to obtaining an Investment Registration Certificate, or exempting investment licensing procedures for certain cases of outbound investment.
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