Vietnam's Conditional Business Sectors in 2026: Only 142 Remain under Resolution 66.17/2026/NQ-CP

Vietnam's conditional business sectors are being cut in a three-step sequence no foreign investor can afford to ignore: the 2025 Investment Law locked in a 198-sector list from 1/7/2026 — but on that very same date, Government Resolution No. 66.17/2026/NQ-CP cut 56 more sectors, leaving only 142 sectors actually in force. This second cut is temporary, running only until 28/2/2027; from 1/3/2027, Law No. 24/2026/QH16 introduces a new list of 137 sectors. Knowing "which list applies, and until when" is the starting point for assessing any FDI project's sub-license obligations.

Table of contents

• 1. Timeline: 237 → 198 → 142 → 137
• 2. Key changes
• 3. Practical impact on FDI enterprises
• 4. Action items and deadlines
• 5. Open points to monitor
• 6. Frequently asked questions

1. Timeline: 237 → 198 → 142 → 137

Three takeaways:

First, the list in force at the time of writing (27/9/2026) is the 142-sector list under Resolution 66.17, not the 198-sector list of Law 143/2025. While the Resolution is in force, where its conditional-sector rules differ from related legal instruments, the Resolution prevails.

Second, the Resolution 66.17 cut is temporary. The Resolution expires at the end of 28/2/2027; moreover, if a law or National Assembly resolution, an ordinance or Standing Committee resolution, or a Government resolution with related provisions is passed or issued and takes effect between the signing date of this Resolution and 28/2/2027, the corresponding provisions of this Resolution cease to have effect from the moment the new instrument takes effect.

Third, the "destination" after 28/2/2027 is already set: Law 24/2026/QH16 (effective 1/3/2027) issues a new list of 137 sectors. But transition details — especially how sectors sitting between the three lists are treated — await guiding instruments.

2. Key changes

2.1. The 56 sectors cut by Resolution 66.17 — source corrected

A correction against much earlier commentary: groups such as tax-filing services, customs-brokerage services, insurance auxiliary services, commercial inspection, labor subleasing and temporary import–re-export belong to the 56 sectors cut by Resolution 66.17/2026/NQ-CP, not to the "39 sectors cut by Law 143/2025" as some sources misreported. The two cuts rest on different legal bases and dates — they should not be lumped together.

Notable groups among the 56 cut sectors (illustrative, by field):

• Finance – accounting – trade: tax-procedure services; customs-procedure services; insurance auxiliary services; commercial inspection services; temporary import–re-export of goods subject to special consumption tax; temporary import–re-export of frozen food; temporary import–re-export of used goods; energy audit; currency printing and minting; storage services.
• Culture – society – healthcare: employment services; management and operation of cremation facilities; overseas-study consultancy; cosmetic surgery services; artistic performance, fashion shows, beauty and model contests; fire prevention and fighting services.
• Construction – transport: labor subleasing; automobile warranty and maintenance; new building, conversion, repair and restoration of inland waterway vessels; maritime safety assurance; sea towage; new building, conversion and repair of seagoing vessels; flight-operation assurance; urban railways; multimodal transport; architectural services; construction activities of foreign contractors; construction-investment cost management; condominium operation management.
• Technology – land – measurement: data-center services; inspection, calibration and testing of measuring instruments; IT infrastructure and software development for the land information system; land-database development; data analysis and synthesis products and services.
• Justice – education – agriculture: asset auctioneering; bailiff practice; asset management and liquidation in bankruptcy proceedings; education quality accreditation; farming of ordinary forest animals; animal quarantine services.

Note: the list above is illustrative, compiled from reputable analyses. For formal filings, companies must consult the Appendix issued with Resolution 66.17 directly.

2.2. The 142 remaining sectors: familiar "red zones" stay

Sensitive sectors foreign investors typically care about remain on the 142-sector list: securities trading, insurance business (excluding insurance auxiliary services), gold trading, petrol and oil, air transport, real estate business, telecommunications services, medical examination and treatment, education (higher, general and preschool), lawyering, notarization, judicial expertise, audit services, lotteries, prize-winning games (casinos)… Sub-license duties for these sectors are unchanged.

2.3. Three transition rules to remember

Resolution 66.17 sets three directly practical principles:

1. Issued licenses remain valid until expiry. For cut sectors, organizations and individuals may continue using licenses, certificates, certifications, confirmations or other investment/business authorization documents issued by competent state authorities — until those documents expire. Licenses do not "automatically lapse" on 1/7/2026.
2. The Resolution prevails in conflicts. While the Resolution is in force, where its conditional-sector rules differ from related legal instruments, the Resolution applies.
3. A self-expiring mechanism. If a new legal instrument with related provisions is passed or issued and takes effect between the signing date of the Resolution and 28/2/2027, the corresponding provisions of the Resolution cease to have effect from that moment.

2.4. "Post-inspection" remains the governing philosophy

Alongside the numerical cut, Article 7 of the 2025 Investment Law codifies the "post-inspection" (hậu kiểm) principle for the first time: the Government publishes two lists — (i) sectors requiring a license or certificate before operation, and (ii) sectors shifting to published business requirements managed by post-inspection. Decree 96/2026/ND-CP implements this: investors may operate in a conditional sector from the moment they satisfy the conditions, and must keep satisfying them throughout. Resolution 66.17 continues this spirit by tasking ministries with issuing technical standards or occupational standards for cut sectors (where needed) for post-inspection management.

3. Practical impact on FDI enterprises

First, re-check every sub-license against the 142-sector list — not the 198. Many companies updated their files under Law 143/2025 earlier this year; they must now cross-check again against the Resolution 66.17 Appendix. A sector just removed no longer supports a Law-on-Investment sub-license requirement — but issued licenses stay valid until expiry, so the "stop maintaining vs. keep" decision must weigh specialized-law factors too (see point four).

Second, shorter market-entry time and lower cost. FDI projects in the 56 cut sectors no longer need a pre-operation sub-license, which may shorten market-entry time and reduce compliance costs — the actual saving depends on the sector and the licensing authority.

Third, the IRC is still mandatory — don't confuse the two layers. Cutting business conditions does not change investment procedures: projects with foreign investors must still obtain an Investment Registration Certificate (IRC) under the Investment Law before establishing the business entity. "No sub-license needed" is not "no IRC needed".

Fourth, "cut from the list" is not "unregulated". Removal from the Appendix only ends "business conditions" under the Investment Law; sector-specific requirements (standards, technical regulations, labor safety, environment, fire prevention…) may still apply. In particular, ministries are now tasked with building standards for post-inspection of cut sectors — duties may change form rather than disappear.

Fifth, the timing puzzle: today's investment decision spans three milestones. Projects running 1/7/2026–28/2/2027 use the 142-sector list; but if the project life extends past 1/3/2027, the 137-sector list of Law 24/2026 must be factored in. Legal planning needs a dual scenario.

4. Action items and deadlines

1. Cross-check now against the Resolution 66.17 Appendix (not just Law 143/2025's App. IV): review the IRC, enterprise registration certificate and every sub-license held. Prioritize projects in the 56 cut sectors.
2. Classify licenses: licenses with no remaining legal basis (cut sector, no specialized-law requirement) → plan an orderly wind-down; licenses still needed for specialized law or new post-inspection requirements → stay fully compliant.
3. New projects: build timelines on the 142-sector list — drop the buffer once reserved for sub-license applications in cut sectors; update the FDI company setup roadmap and business-line registration for FDI companies accordingly.
4. Prepare for 28/2/2027: track transition guidance as Resolution 66.17 expires and Law 24/2026/QH16 takes effect (1/3/2027). For long-horizon projects, build periodic legal reviews into the compliance plan.
5. Keep condition-compliance files for sectors remaining on the list: under post-inspection, the burden of proof shifts to the company when authorities inspect — files must be complete from day one of operation.

5. Open points to monitor

• The detailed 39-sector cut list under Law 143/2025 (vs. Law 61/2020): this article does not itemize each sector; the 39/237 figures come from the drafting authority's official explanatory documents. Consult App. IV directly for formal filings.
• The 56 cut sectors listed here are illustrative, compiled from reputable analyses — check the original Resolution 66.17 Appendix when a precise basis is needed.
• The "62 sectors cut" figure tied to Law 24/2026/QH16 has not been verified against the full Appendix text; this article only states the future 137-sector list per published information.
• The regime after 28/2/2027 when Resolution 66.17 expires: transition guidance is awaited. Law 24/2026 takes effect 1/3/2027 but implementation details are unclear.
• For these open points, FLAT recommends case-by-case assessment — contact FLAT at hotline 0988424851 for a review of your project.

6. Frequently asked questions

6.1. How many conditional business sectors are there now, and since when?

142 sectors under Government Resolution No. 66.17/2026/NQ-CP, effective from 1/7/2026 to 28/2/2027. Before that, Appendix IV of Investment Law 143/2025 listed 198 sectors (also effective from 1/7/2026).

6.2. Are sub-licenses issued for cut sectors still valid?

Yes. Resolution 66.17 allows organizations and individuals to continue using issued licenses, certificates, certifications and confirmations until those documents expire.

6.3. Does removal from the conditional list mean no license is needed at all?

Not entirely. The cut only removes "business conditions" under the Investment Law; sector-specific requirements such as technical standards, labor safety and environmental protection may still apply. The two layers of obligations must be distinguished to avoid under-compliance.

6.4. Which list applies after 28/2/2027?

Resolution 66.17 expires at the end of 28/2/2027. Law No. 24/2026/QH16 — with its 137-sector list — takes effect on 1/3/2027. Detailed transition guidance is still awaited; companies with long-horizon projects should track developments closely and prepare legal scenarios for both lists.

Need a sector review for your FDI project?

Checking a project's business lines against the Resolution 66.17 Appendix requires a careful reading of the original text and related specialized laws. FLAT supports comprehensive reviews of business-condition obligations, IRCs and sub-licenses for foreign investors — contact hotline 0988424851 for advice.

References

• Resolution No. 66.17/2026/NQ-CP on cutting and amending conditional business sectors (issued 15/5/2026; effective 1/7/2026–28/2/2027).
• Investment Law No. 143/2025/QH15 (effective 1/3/2026; Article 7 and Appendix IV effective 1/7/2026).
• Decree No. 96/2026/ND-CP guiding the Investment Law (effective 31/3/2026).
• Law No. 24/2026/QH16 amending the Investment Law — promulgated, not yet in force (effective 1/3/2027).
• Investment Law No. 61/2020/QH14 — expired (cited for "before–after" comparison only).

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