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Appraisal and Approval Timelines for Group-B Public Investment Projects in Vietnam

Construction crane — illustration for the article on group-B project appraisal timelines

How long does appraisal of a group-B investment-policy proposal take? And once appraised, within what time limit is the investment-policy decision issued? Before answering with numbers, one widespread confusion must be cleared up: “group B” is a public-investment classification — entirely different from “investment-policy approval” under the Investment Law. Confuse the two and you will apply the wrong law and the wrong deadlines.

1. Which law does “group B” belong to?

Public investment projects are classified into groups A, B and C by scale and nature under the Law on Public Investment 58/2024/QH15 (in force). “Investment-policy decision” is public-investment terminology — a competent state authority deciding on the use of public investment capital.

By contrast, “investment-policy approval” is a procedure under the Investment Law 143/2025/QH15, applying to investors’ projects (domestic and foreign) — a completely different regime with its own authorities and timelines. This article covers only group-B projects in public investment.

2. The two timelines that answer the question

Decree 85/2025/ND-CP guiding the 2024 Law on Public Investment (replacing Decree 40/2020/ND-CP — the old text must no longer be cited as current law) provides:

2.1. Appraisal of the investment-policy proposal: maximum 20 working days

Under Article 11.5 of Decree 85/2025, appraisal of the investment-policy proposal for group-B (and group-C) projects must not exceed 20 working days from receipt of a complete and valid dossier.

Appraisal covers: project necessity; conformity with relevant plans; scale, duration and schedule; total investment and capital structure; socio-economic efficiency; and other prescribed contents.

During appraisal, the appraising authority may request dossier supplementation — within 5 working days. Notably, the current rules allow no extension of the appraisal period, pressuring both the authority and the project owner to finish on time.

2.2. Investment-policy decision: maximum 5 working days

After the appraisal result, the competent authority decides on the investment policy for group-B and group-C projects within 5 working days under Decree 85/2025.

2.3. Who decides the investment policy for group-B projects?

Decision-making authority is allocated by level in Articles 25–29 of the Law on Public Investment 58/2024, depending on the capital source and management level (central vs. local, central vs. local budget). Project owners must match the correct provision to their project rather than assume authority.

3. Practical notes for project owners and contractors

3.1. Prepare the investment-policy proposal (8 contents)

The proposal report starts the entire process. Owners should prepare all eight content groups: necessity; objectives; scale; location; total investment and capital sources; timeline and schedule; efficiency; and implementation arrangements. Missing contents are the most common trigger for supplementation requests — costing 5 working days right at the start.

3.2. Electronic dossiers

Many ministries and localities now accept online filing for public-investment procedures. A properly prepared e-dossier shortens reception time and avoids paper files stalling at intake.

3.3. Build the milestones into the master project schedule

The 20-day appraisal plus 5-day decision are maximum legal periods, excluding supplementation rounds (if any) and the owner’s own preparation time. Master schedules should allow buffer for supplementation to avoid breaking the overall project timeline.

4. Frequently asked questions

Does every group-B project need an investment-policy decision?

Yes. Under the 2024 Law on Public Investment, group-B projects using public investment capital require an investment-policy decision from the competent level before the investment project itself is prepared and appraised.

Does Decree 40/2020 still apply?

No. Decree 85/2025 has replaced Decree 40/2020 in guiding the Law on Public Investment. Any citation of 40/2020 as current law is outdated.

What is the difference between “investment-policy decision” and “investment-policy approval”?

“Investment-policy decision” belongs to the Law on Public Investment (the state deciding to spend public capital). “Investment-policy approval” belongs to the Investment Law 143/2025 (the state approving an investor’s project). They differ in subject, legal basis and timelines.

5. Conclusion

For group-B projects: appraisal within 20 working days, decision within 5 working days — under Decree 85/2025 guiding the 2024 Law on Public Investment. Getting the concept right, preparing a complete dossier from the outset, and buffering for supplementation rounds are the three factors that get project owners through the investment-policy “gate” fastest.

If your organisation needs legal support on public-investment procedures, contact FLAT Law Firm for advice.


This article has been reviewed by the QA Council.

Transparency note: this article was prepared by the FLAW AI Legal Council based on legislation in force at the time of writing (14 October 2026). It is for general information only, is not an official legal text, and does not replace legal advice for your specific case. Authority-by-level figures should be checked against Articles 25–29 of the Law on Public Investment 58/2024.