Scenario: an investment fund models a casino project in Vietnam with USD 800 million in total capital, benchmarking against regional integrated resorts. The model is unusable: Decree 03/2017/ND-CP requires a minimum investment of USD 2 billion for the integrated service-tourism-entertainment complex that may host a casino — before any discussion of gaming tables begins.
The USD 2 billion floor: capital as the first gate
Decree 03/2017/ND-CP (effective 15 March 2017) makes casino business a strictly controlled conditional sector. The decree requires the investor to build an integrated service, tourism and entertainment complex with minimum total investment capital of USD 2 billion before a casino business license can even be considered.
Article 24 sets the conditions for the certificate of eligibility for casino business: the enterprise must hold an investment registration covering casino operations and must have disbursed at least 50% of the project’s registered total investment. A project that is ‘approved but not yet funded’ cannot open its gaming floor.
The second gate: who may enter the gaming floor
Vietnamese casinos historically served only foreigners and overseas Vietnamese. Decree 03/2017 introduced a pilot allowing Vietnamese citizens to gamble — subject to strict conditions: at least 21 years old, minimum regular monthly income of VND 10 million, and full civil capacity. After eight years of the pilot, three large casinos operate (Phu Quoc, Ho Tram, Nam Hoi An) alongside six smaller ones licensed before the decree took effect.
On 3 October 2025, the Ministry of Finance announced it is reviewing the decree toward a dedicated law on casinos and betting — investors should treat the current framework as transitional and monitor the legislative timetable before committing capital.
What this means for foreign capital ratios
No statutory foreign ownership cap is published for casino projects; the ‘ratio’ that matters is the capital commitment itself — USD 2 billion minimum, 50% disbursed — plus the integrated-resort model the decree mandates. In practice, foreign investors participate as developers and operators of the integrated complex, with the casino as one component of a tourism-driven project. Surveillance and compliance obligations are heavy: 24/7 camera coverage of gaming areas with minimum 6-month footage retention, and posted house rules in Vietnamese and English.
Frequently asked questions
1. Is USD 2 billion the license fee or the project investment?
It is the minimum total investment capital of the integrated complex project — not a fee paid to the state.
2. When can the casino actually open?
Only after the enterprise has disbursed at least 50% of registered investment and obtained the certificate of eligibility under Article 24.
3. Can Vietnamese citizens gamble at all casinos?
Only at casinos licensed under the pilot program and meeting its conditions; the pilot remains subject to government review.
4. Is there a foreign ownership cap for casino projects?
No published ratio; the binding constraints are the capital floor, the integrated-resort requirement and the licensing conditions.
5. Will the law change soon?
The Ministry of Finance is preparing amendments toward a dedicated casino and betting law (announced October 2025); investors should track this before finalizing structures.