This article is for reference only and does not constitute legal advice. Content reviewed by the FLAW AI Legal Council.
Short answer: No. Projects granted an Investment Registration Certificate (IRC) before 1 March 2026 continue to be implemented under the issued IRC, without having to adjust it to the Investment Law 2025.
1. The legal basis: Article 52.1 of Law 143/2025
Article 52.1 of the Investment Law 2025 (Law No. 143/2025/QH15) provides that projects granted investment licenses and certificates — Investment Licenses, Investment Incentive Certificates, Investment Certificates, Investment Registration Certificates, or written decisions/approvals of investment policy — before the new Law takes effect continue to be implemented in accordance with the issued documents.
2. No need to redo investment policy approval
Projects already granted an IRC (or equivalent documents) are not required to redo investment policy approval procedures under the new Law (Article 52.2(d)).
3. The only exception: voluntary adjustments
If the investor voluntarily adjusts the project and the adjusted content falls under investment policy approval according to the 2025 Law, the new procedures apply. This is the only case triggering the new Law (Article 52.3).
4. Related transition rules
- Pending dossiers (submitted before 1 March 2026 but no IRC yet): continue to be processed under the 2020 Law (Article 52.14);
- More favorable market-access conditions on the old IRC are preserved — no retroactive tightening (Article 52.9);
- Existing incentives are grandfathered for their remaining term (Article 12.2).
Contact FLAT Law Firm for advice on transition issues under the new Investment Law.