This article is for reference only and does not constitute legal advice. Content reviewed by the FLAW AI Legal Council.
Short answer: No re-registration is required. Projects granted investment licenses or certificates before 1 March 2026 continue to be implemented under the issued documents — even while suspended.
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 an Investment License, Investment Certificate, or IRC before the new Law takes effect continue to be implemented in accordance with the issued documents, including projects currently suspended (Article 101.1 of Decree 96/2026/ND-CP).
2. The 2025 Law no longer has a separate suspension concept
Unlike the 2020 Law, Article 35 of the 2025 Law only provides for suspension of project operation in two groups: (a) the investor voluntarily decides to suspend — with a written notice to the investment registration authority; (b) the state investment management authority orders suspension or partial suspension (heritage protection, environmental remediation, labor safety, court judgments/arbitral awards, continued violations of approval/IRC terms; the Prime Minister orders suspension for defense, security, or environmental risks).
3. Force majeure: land rental exemption
Where suspension is due to force majeure, the investor is exempted from land rental and granted land-use-fee reduction during the suspension to remedy consequences (Article 35.1) — a new investor-friendly policy.
4. Time limits and the risk of termination
- Total suspension must not exceed 12 months (Article 65.2 of Decree 96/2026/ND-CP);
- Voluntary suspension: notify the authority within 5 working days of the decision; the authority acknowledges and informs relevant agencies within 3 working days;
- Risk: a suspended project that the authority cannot contact (investor or legal representative) after 12 months from suspension is subject to termination (Article 36.2(d)).
5. Comparison table
| Item | 2020 Law | 2025 Law |
|---|---|---|
| Concept | Separate suspension regime | Only operation suspension (Art. 35) |
| Voluntary suspension | Notice | Written notice (5 working days) |
| Time limit | Yes | Max 12 months |
| Force majeure | — | Land rental exemption, fee reduction |
| Overdue suspension | — | Termination if unreachable after 12 months |
Contact FLAT Law Firm for advice on suspending and resuming investment projects under the new Law.