After the devolution in Investment Law 143/2025/QH15, the Prime Minister is the approval level for the largest and most sensitive projects remaining in the administrative system: nuclear power, casinos, special-class seaports, international airports, projects resettling tens of thousands of people, and projects touching world-heritage core zones. This article lists exactly the groups under Prime Ministerial authority in Article 25 and the dossier an investor must prepare — under the new law, not from memory of the old one.
The project list under the Prime Minister
Clause 2, Article 25 of Investment Law 143/2025/QH15 assigns the Prime Minister three groups. Group one: projects in clauses 1, 2, 4, 6, 7 and 19 of Article 24 — covering infrastructure and special, sensitive fields (nuclear energy; casinos and betting; oil and gas processing; air transport business; network-infrastructure telecommunications, publishing and press with foreign capital; sea-area allocation; large-scale conversion of forest and rice land under the Article 24 list). Group two: clause 3 Article 24 projects requiring resettlement of 20,000 people or more in mountainous areas or 50,000 or more elsewhere. Group three: clause 5 Article 24 projects inside protection zone I of a special national relic on the World Heritage List, regardless of land area or population.
Memorise this if you prepare files: for the same clause 3 or clause 5 project, the approval level flips by threshold — resettlement of 10,000 people in mountainous areas or 20,000 elsewhere goes to the provincial People Committee chair (clause 3, Article 25), and only double that threshold reaches the Prime Minister; ordinary national relics sit at provincial level, and only a World Heritage site with protection zone I goes up. Misread the threshold and the file is filed at the wrong level, costing a full round of time in re-routing.
What the approval dossier contains
The core dossier under the Investment Law 143/2025/QH15 sequence comprises: a written request to implement the investment project; documents on the investor legal status; the investment project proposal (objectives, scale, capital, location, term, schedule, land and labour needs); a preliminary environmental impact assessment or full EIA report under environmental law as scale requires; documents evidencing the investor financial capacity; and an investment-incentive proposal if any. Projects in fields with specialist appraisal add technology appraisal results, defence-security opinions or corresponding sector documents.
For a Prime Minister-level project, document quality decides speed more than volume: the pre-feasibility report must answer the questions the inter-agency consultation round will certainly ask — land needs and compensation plan, capital sources and financing ability, environmental and social impact, conformity with sector planning and provincial planning. A file missing one of these pillars draws a supplementation request, and every supplementation round at this level is measured in months.
Realistic timelines and handling a returned file
The Prime Minister-level sequence runs: receipt, consultation of relevant ministries and sectors, consolidated appraisal, and submission to the Prime Minister for a written policy approval. The nominal statutory timeline does not reflect real time for complex projects: large-land, resettlement or sensitive-sector projects pass several explanation rounds, and realistic end-to-end time commonly runs from many months to over a year. Professional investors plan against the supplementation-round scenario, not the nominal deadline.
A file asked for supplementation or returned is not a rejected project: the appraisal body letter identifies exactly what falls short, and the investor corrects and resubmits the affected parts. The difference between supplementation and refusal is that the project remains inside the sequence. Only upon a written non-approval must the investor consider redesigning the project or the complaint and litigation routes. The costliest mistake at this step is resubmitting the identical old file with a long explanation letter — instead of fixing exactly what was flagged.
The Prime Minister level is not hard because it is “high”; it is hard because projects at this level all touch large land, sensitive sectors or heritage. The file that wins at this level answers the toughest ministry question before it is asked. This draft is pending review by the QA Council.
Frequently asked questions
Which projects fall under the Prime Minister approval authority?
Under clause 2, Article 25 of Investment Law 143/2025/QH15: projects in clauses 1, 2, 4, 6, 7 and 19 of Article 24 (infrastructure and special-field groups such as nuclear power, casinos, seaports, aviation, telecommunications, foreign-capital publishing, sea-area allocation, large-scale forest and rice-land conversion); clause 3 Article 24 projects with resettlement of 20,000 people or more in mountainous areas or 50,000 or more elsewhere; and clause 5 Article 24 projects inside protection zone I of a World Heritage special national relic.
What does a Prime Minister approval dossier include?
A written project implementation request; investor legal-status documents; the project proposal stating objectives, scale, capital, location, term, schedule, land and labour needs; environmental documents by scale (preliminary assessment or EIA report); evidence of financial capacity; and an incentive proposal if any. Special-sector projects add technology appraisal, defence-security opinions or sector dossiers as the field requires.
How long does processing actually take?
Investment Law 143/2025/QH15 prescribes the appraisal and decision sequence, but real time for a Prime Minister-level project is usually many months, and for large-land or sensitive projects can exceed a year, because the file passes an inter-agency consultation round and possibly one or more supplementation and explanation rounds. The only reliable figure comes from comparable projects recently approved in the same field — not from the nominal timeline in the statute.
If the file is returned, how do we fix and resubmit?
Separate two situations: a supplementation or explanation request — the project stays in sequence, and the investor corrects exactly the flagged contents and resubmits the supplemented parts with a point-by-point response; and a written non-approval — the project stops at this level, and the investor must redesign for conformity or use complaint and administrative-litigation rights. Never resubmit the old file unchanged: the appraisal body compares item by item against what it flagged.
A project matching both PM and provincial criteria — who decides?
Under the devolution structure of Article 25 of Investment Law 143/2025/QH15, where a project simultaneously meets a higher-level criterion, the higher level decides the whole policy approval: one Prime Minister-group trigger (for example the resettlement threshold or a world-heritage zone I location) sends the entire approval up, unsplit. For projects spanning several provinces, competence follows the Government rules for inter-provincial projects.
This article has been quality-reviewed by the FLAW AI Legal Council