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Actual Timelines at the Industrial Park Management Board: Statutory Days vs Reality, and Where Delays Happen

Aerial view of factories in an industrial park (illustrative)

Scenario: a Singaporean investor leases a factory inside an industrial park in Bac Ninh and files for an Investment Registration Certificate (IRC) with the park’s Management Board in early March, planning to break ground in May. By late April the file is still pending. Asked why, the receiving officer explains the dossier is awaiting fire-prevention design appraisal and the environmental opinion of the park infrastructure developer. The statutory IRC timeline is only part of the story — the rest lies in satellite appraisal rounds that investors rarely budget for.

What the Industrial Park Management Board does in investment procedures

Under Article 27 of Law No. 143/2025/QH15 on Investment (passed by the National Assembly, effective 1 March 2026, replacing Law No. 61/2020/QH14 which expired the same day), the Management Board of an industrial park, export processing zone, high-tech park or economic zone acts as the investment registration authority for projects inside the zone: receiving dossiers and issuing, amending and revoking Investment Registration Certificates. Projects outside zones fall to the Department of Finance. Decree No. 96/2026/ND-CP provides implementation details for the 2025 Investment Law.

The Board’s defining feature is the one-stop mechanism: the investor deals with a single contact point instead of running between departments. The Board coordinates and collects opinions from relevant agencies during dossier appraisal. But one-stop does not mean one-step — specialised appraisals (fire prevention, environment, technology) still take place; they are simply channelled through the Board.

The rules: how many days does the law allow?

The law sets timelines by case. For projects subject to investment policy approval, once the approval decision is issued, the IRC must be granted within 05 working days from the date the investment registration authority receives the approval decision (Point a, Clause 1, Article 38 of Decree No. 96/2026/ND-CP). This is the only IRC-related day count this article states, because it has been cross-checked against open sources.

For ordinary IRC issuance (projects not subject to policy approval), Decree No. 96/2026/ND-CP sets the issuance timeline in Article 47. The specific day count of that provision is currently under legal re-review, so this article does not quote a figure; investors should consult the original text at the time of filing. Verified satellite timelines are as follows: fire-prevention design appraisal for technical designs or construction drawings takes no more than 10 working days for ordinary projects and 15 days for projects of national importance or Group A projects (Clause 10, Article 13 of Decree No. 136/2020/ND-CP, as amended by Decree No. 50/2024/ND-CP); environmental permits take no more than 45 days under the authority of the Ministry of Natural Resources and Environment and no more than 30 days under provincial People’s Committees, counted from receipt of a complete and valid dossier (Clause 4, Article 43 of Law No. 72/2020/QH14 on Environmental Protection).

Reality: how long does it take, and where does it stall?

The durations below are observed in practice, not prescribed by law. With a complete dossier from day one, an ordinary business line and no policy-approval requirement: roughly 2–4 weeks from filing to IRC issuance. Projects requiring investment policy approval: add 1–3 months for the prior approval round.

Four bottlenecks specific to the Management Board route:

First, site confirmation and zoning conformity. The project must conform to the park’s detailed zoning plan and the park’s list of encouraged business lines. Many investors sign a land-lease memorandum with the infrastructure developer only to discover their business line is not on the park’s priority list — renegotiating or switching parks then costs months.

Second, fire-prevention appraisal. Factories and warehouses face the strictest fire-safety scrutiny. Each round of comments from the Fire Police requiring design revisions restarts the appraisal clock. Two to three comment rounds are common in practice, turning the paper “10 working days” into 1–2 months.

Third, the environmental opinion round. Projects inside industrial parks and clusters must still complete environmental procedures according to scale and type; before issuing an environmental permit, the licensing authority must collect the written opinion of the developer operating the park’s infrastructure (Point d, Clause 2, Article 43 of Law No. 72/2020/QH14). This opinion round, plus preparing the environmental permit proposal report, is usually the longest leg.

Fourth, the technology explanation. Projects with pollution risk or using restricted-transfer technologies must submit a convincing technology explanation. Thin technology dossiers are a common reason the Board requests supplementation repeatedly.

How to avoid stalling at the Management Board

Practical experience points to parallel rather than sequential preparation. While the IRC dossier is under appraisal, simultaneously advance the fire-prevention appraisal file and the environmental permit proposal report — these three tracks do not depend on each other for preparation. Obtain the site-confirmation letter and the business-line conformity confirmation before filing the formal dossier. Hire a fire-prevention design consultant with experience in the specific industrial park, because each locality applies technical standards slightly differently. Finally, check the park’s encouraged business-line list at the site-survey stage, before signing any land-lease commitment.

Frequently asked questions

Should the IRC dossier go to the Management Board or the Department of Finance?
It depends on project location. Projects inside industrial parks, export processing zones, high-tech parks or economic zones file with the zone’s Management Board; projects outside zones file with the Department of Finance (Article 27, Law No. 143/2025/QH15). Projects spanning both file with the investment registration authority where the operating office sits.

Can construction start once the IRC is issued?
No. The IRC only satisfies the investment condition. Before breaking ground, the project still needs a construction permit, an approved fire-prevention design appraisal document, and completed environmental procedures (an approved environmental impact assessment before construction; an environmental permit before official operation). Starting work without these can draw administrative fines and a stop-work order.

Does leasing an existing factory in the park exempt the project from environmental procedures?
No, where the investor’s project falls within the scope of Law No. 72/2020/QH14 on Environmental Protection. Environmental permits attach to the project owner and the specific scale and type of activity — a new investor does not automatically inherit the previous owner’s permit. A pure change of project owner without changing environmental commitments follows an amendment procedure, but a procedure must still be completed.

Does the Management Board issue construction permits?
Construction-permit authority for in-zone works is delegated differently across provinces — some assign it to the Management Board, others keep it with the Department of Construction. This article has not verified each province’s delegation; investors should check the provincial People’s Committee delegation decision where the project sits before filing.