Minimum capital for a foreign-invested hospital in Vietnam

The figure asked about most often when a foreign healthcare group weighs entering Vietnam is the minimum capital for a hospital, and that figure does not sit in health legislation at all: it sits in Vietnam’s services schedule on joining the WTO. Misreading its nature, for example treating it as minimum charter capital or legal capital, produces a wrong capital structure from the very first investment filing.

USD 20 million is project investment capital, not charter capital

Under Vietnam’s WTO schedule of services commitments for hospital and medical services, the minimum investment capital is USD 20 million for a hospital, USD 2 million for a polyclinic and USD 200,000 for a specialist treatment facility. This is a market access condition applied to the project establishing a foreign-invested hospital, examined by the investment registration authority when issuing the investment registration certificate under Law on Investment 143/2025/QH15.

Because it is project investment capital, the USD 20 million includes both the investor’s contributed capital and the project’s planned mobilised capital; it does not require the entire amount to be cash paid into charter capital on day one. The investor’s own contribution must nevertheless be substantial, with a credible contribution schedule, for the project to be accepted as genuinely implementable, and the authority may require evidence of matching financial capacity.

Contribution timing and how equipment counts

The investor’s capital contribution to the economic organisation follows the schedule recorded in the investment registration certificate, while the charter capital of a limited liability company must be fully contributed within 90 days of the enterprise registration certificate under Law on Enterprises 59/2020/QH14. These two clocks are different and often confused: 90 days governs the legal entity’s charter capital, while disbursement of the hospital project’s full investment capital runs across the registered construction and equipment procurement phases.

Medical equipment spending is a legitimate component of total project investment capital, because a hospital cannot operate with a building alone. In the filing, investors should separate three components: facility construction, medical equipment and initial working capital, with a list of principal equipment. This presentation shows the authority that USD 20 million reflects real project needs, and it becomes the reference when the company later imports equipment and explains disbursement progress.

What happens if the minimum is not met

If the project’s total investment capital falls below the commitment minimum, the project fails the market access condition and will not receive an investment registration certificate as a hospital. The investor is left with resizing options: step the project down to a polyclinic at the USD 2 million threshold, or a specialist treatment facility at USD 200,000, each carrying a different permitted service scope.

After licensing, failing to contribute capital on the registered schedule is a separate violation: the investor may be fined, required to adjust the project, or face project termination in statutory cases. The capital commitment in the filing should therefore be built on a firm financing plan rather than inflated for presentation and left unimplemented.

Frequently Asked Questions

How much minimum capital is needed for a foreign-invested hospital?

The minimum investment capital for a foreign-invested hospital is USD 20 million under Vietnam’s WTO services schedule. This is the project’s total investment capital, combining the investor’s contribution and mobilised capital, not an all-cash charter capital requirement. For comparison, a polyclinic is USD 2 million and a specialist treatment facility is USD 200,000.

Within what period must the capital be contributed?

The investor’s contribution follows the schedule in the investment registration certificate, usually aligned with the project’s construction and equipment phases. Separately, a company’s charter capital must be fully contributed within 90 days of the enterprise registration certificate under Law on Enterprises 59/2020/QH14. Falling behind the investment capital schedule can draw fines and a requirement to adjust the project.

How is investment in medical equipment counted?

Equipment investment counts as one component of the project’s total investment capital, alongside facility construction and initial working capital. The investment filing should list the principal equipment and its expected value by phase, because this is the basis on which the authority tests the credibility of the minimum capital figure and on which the company later explains its disbursement.

Can a licence be granted if the minimum capital is not met?

No. With total investment capital below USD 20 million, a hospital project fails the WTO market access condition and will not be issued an investment registration certificate as a hospital. The investor must raise project capital to the minimum, or switch to the polyclinic form at USD 2 million or the specialist treatment facility form at USD 200,000.

Bottom line on the capital figure

The USD 20 million threshold is a market access condition measured on total project investment capital, not on cash charter capital. Investors should structure capital across construction, equipment and working capital, and commit only to an amount their financing plan can actually disburse on schedule.