Amending an investment project (IRC amendment) is the “seen everywhere” procedure for FDI companies: changing objectives, increasing capital, moving location, extending schedules, changing investors — each content has its own dossier, but all share one common base dossier framework. Once you master the base framework and “add” the specific documents for each amendment content, you will never again face the cycle of filing and being returned for a missing paper. This article is a practical checklist: the base dossier + specific dossiers for the 5 most common amendment contents.
See also the overview guide on amending the Investment Registration Certificate.
Quick summary
| Topic | Dossier checklist for amending a foreign investment project: the common base dossier + specific dossiers per amendment content |
|---|---|
| Key point | Every amendment dossier = the base framework (request letter, investor decision, project status report) plus specific documents per changed content |
| Filing place | The investment registration authority: Industrial Park/Export Processing Zone/Hi-Tech Park/Economic Zone Management Authority, or the Department of Finance for off-park projects |
| Note | Foreign documents must be consular-legalized and notarized-translated per regulations |
The base dossier: common to all cases
- The investment project amendment request (per form): stating the requested amendment contents and reasons.
- The investor’s decision on the project amendment (the owner/Members’ Council/General Meeting of Shareholders decision depending on company type).
- The project implementation status report up to the amendment request date (implemented capital, progress, labor, financial obligations).
- A copy of the issued IRC and prior amendment instruments (if any).
- The investor’s legal standing documents still valid (business registration/passport…).
Documents issued by foreign authorities must be consular-legalized (except where exempted under international treaties) and translated into Vietnamese with notarization/certification. This is a common reason FDI files are returned — handle this step before filing.
Amending project objectives
Base dossier plus: evidence of meeting the new objectives’ market access conditions (if a conditional sector); an explanation of the new objectives’ planning alignment (if the law requires). Where the new objectives are subject to investment in-principle approval, that procedure must be done first or in parallel.
Amending investment capital
Base dossier plus: an explanation of the additional capital source and contribution schedule; evidence of the investor’s financial capacity (financial statements, balance confirmations…); the plan for using the additional capital. Synchronize with the charter capital change on enterprise registration if contributed capital changes.
Amending the implementation location
Base dossier plus: documents on the new location (location lease/land use right contract, location map); the competent authority’s written location approval (if the law requires for that project type). Note: location changes usually entail a head office change and updating location-linked sub-licenses.
Amending the implementation schedule
Base dossier plus: an explanation of delay reasons and remedial plans; the proposed amended schedule (specific, feasible milestones). The appraising authority will assess the new schedule’s feasibility against actually achieved progress — a generic explanation (“due to objective difficulties”) is unpersuasive without evidence.
Changing investors
Base dossier plus: the capital contribution transfer agreement/arrangement or documents evidencing the investor change; evidence that the new investor meets conditions (financial capacity, the project’s market access conditions); the parties’ decisions. See details at transferring an investment project in Vietnam. After amendment, update investment reports for the next period.
Legal basis
- Law on Investment No. 143/2025/QH15 (investment project amendment, IRC amendment);
- Decree 96/2026/ND-CP guiding the Law on Investment No. 143/2025/QH15;
- Law 76/2025/QH15 amending the Law on Enterprises;
- Decree 168/2025/ND-CP on enterprise registration;
- Decree 29/2025/ND-CP on the functions and tasks of the Ministry of Finance;
- Law on consular legalization and notarized translation.
FAQ
What does a project amendment dossier include?
The base framework: amendment request, investor decision, project implementation status report, IRC copy, investor legal documents — plus specific documents per amendment content (objectives, capital, location, schedule, investors).
Where is the dossier filed?
With the investment registration authority where the project is implemented: the Industrial Park/Export Processing Zone/Hi-Tech Park/Economic Zone Management Authority, or the Department of Finance for off-park projects.
Do foreign-language dossiers need translation?
Yes. Foreign documents must be consular-legalized (except where exempted) and translated into Vietnamese with notarization/certification.
Can multiple contents be amended at once?
Yes, and bundling is recommended — one dossier amending multiple contents saves more time than separate files, but all specific documents for each content must be prepared.
Does an IRC amendment require an enterprise registration change?
It depends: changes to contributed capital, location/head office, or investors usually entail enterprise registration changes. Always review both licenses in sync.
When should a lawyer be involved?
When amending objectives to a conditional sector, changing investors, or the file has many foreign documents — conditions must be reviewed and the dossier standardized before filing to avoid repeated returns.
