Factory and warehouse investors in Vietnam often search for “fire safety design approval” (thẩm duyệt thiết kế PCCC) — but note from the outset: that is the terminology of Decree 136/2020/ND-CP, which expired on 01/7/2025. The current term under the Law on Fire Prevention, Firefighting and Rescue 2024 (55/2024/QH15) and Decree 105/2025/ND-CP is “appraisal of fire prevention and firefighting designs”. This article keeps the familiar search phrase in the title but uses the correct statutory term throughout, explaining the process, dossier and timelines in force since 01/7/2025.
1. Which factories and warehouses require design appraisal?
Under Appendix III of Decree 105/2025/ND-CP, the following works require fire-safety design appraisal:
- Warehouses storing goods with fire/explosion hazard categories A, B, C: volume of 15,000 m³ or more, or floor area of 2,000 m² or more;
- Industrial works (including production technology lines);
- Technical infrastructure of industrial parks and industrial clusters;
- Works of 7 storeys or more, or total floor area of 3,000 m² or more.
The appraisal obligation applies to new designs, renovations, and changes of function of such works. Excluded: temporary works, special investment projects, and national-defense works.
2. The appraisal process (Clause 6, Article 9 of Decree 105/2025/ND-CP)
Step 1 — Submission. The investor submits the dossier in person, by post, or via the public-service portal. Online submissions are acknowledged within 8 working hours.
Step 2 — Review. The police authority reviews the dossier against applicable FPFR standards and technical regulations.
Step 3 — Result. If compliant: the authority issues a written fire-safety design appraisal (Form PC12), stamps the appraisal seal (Form PC14) on the design dossier, and returns it to the investor. If not compliant: a written notice stating the reasons is issued and the dossier is returned for completion.
3. What does the dossier contain?
- A written appraisal request using Form PC11 (Appendix VIII of Decree 105/2025/ND-CP);
- The work’s design dossier;
- For adjusted or renovated designs: supplement the adjusted contents plus information on any prior appraisal or commissioning-acceptance documents (if any).
4. How long does appraisal take?
Within 10 days for nationally important projects and Group A projects; within 6 working days for all other cases — counted from the date a complete and valid dossier is received. Note: the figure of “15 working days” was the old rule under Decree 136/2020/ND-CP and no longer applies.
5. An appraisal document is not the end: commissioning still follows
After obtaining the appraisal, the investor must build in line with the appraised design, then organize fire-safety commissioning. The specialized management authority inspects and issues a written acceptance of the commissioning results before the work may be exploited or used. Appraisal and commissioning are two separate steps and must not be merged.
6. Where to submit?
The appraisal competence of police authorities at each level is prescribed by the Minister of Public Security. Investors should not assume “the provincial police” by default — verify the current delegation of competence before submitting.
FAQs
Q: Does renovating, adding floors to, or changing the function of a factory require re-appraisal?
A: Yes. Renovations, floor additions or functional changes that alter FPFR conditions require design re-appraisal (Clause 4, Article 6 of Decree 105/2025/ND-CP) — the point businesses most often overlook.
Q: Is the “15 working days” timeline still correct?
A: No. That was Decree 136/2020/ND-CP’s rule, now expired. The current timelines are ≤10 days (nationally important/Group A projects) and ≤6 working days (other cases).
Q: With the design appraisal in hand, can the factory start operating?
A: Not yet. The investor must still build per the appraised design, organize fire-safety commissioning, and obtain acceptance of the commissioning results before exploitation.
Legal basis: Law on Fire Prevention, Firefighting and Rescue 55/2024/QH15 (effective 01/7/2025); Decree 105/2025/ND-CP (effective 01/7/2025, replacing Decrees 136/2020/ND-CP and 50/2024/ND-CP); Circular 36/2025/TT-BCA. Checked on 14/10/2026.
This article is for general reference only and does not constitute legal advice for any specific case. The content has been reviewed by the QA Council.
Transparency note: This article was drafted with AI assistance and quality-checked by FLAT’s AI Legal Council; it has not been reviewed by a human lawyer.
See also: Contact FLAT Law Firm
