Vietnam's 142-Sector Conditional Business Lines List under Resolution 66.17/2026: Lookup and Application

Since 1 July 2026, the conditional business lines list businesses must check is no longer Appendix IV of the 2025 Investment Law (198 sectors), as many publications still state — it is the 142-sector list issued with Government Resolution No. 66.17/2026/NQ-CP. This is the single most consequential point for compliance: checking the wrong list means applying the wrong licensing obligations across the board. This guide builds the lookup framework on the four legal layers currently in force: the background (2025 Investment Law), the governing layer (Resolution 66.17), the transitional rules, and the open point after 28 February 2027.

Table of contents

• 1. The four legal layers of the current list
• 2. Layer 1 — Background: Appendix IV of the 2025 Investment Law (198 sectors)
• 3. Layer 2 — Governing: Resolution 66.17/2026/NQ-CP (142 sectors, 1 July 2026–28 February 2027)
• 4. Layer 3 — Transition: what happens to issued licences (Article 5)
• 5. Layer 4 — After 28 February 2027: the open point to monitor
• 6. How to check correctly — 4 steps
• 7. Action items now
• 8. Frequently asked questions

1. The four legal layers of the current list

The conditional business lines list currently in force is composed of four layers, in descending order of priority for the present period:

The golden rule for lookup: during 1 July 2026–28 February 2027, always check the 142-sector list of Resolution 66.17 first; Appendix IV (198 sectors) is only the legislative background for context and cross-reference. Reversing the order — treating the 198-sector Appendix as the applicable list — is the most common mistake being made today.

2. Layer 1 — Background: Appendix IV of the 2025 Investment Law (198 sectors)

On 11 December 2025, the National Assembly passed the 2025 Investment Law (No. 143/2025/QH15), replacing the 2020 Investment Law. On effective dates, Article 51 provides: general effect from 1 March 2026, with Article 7 and the conditional investment business lines list in Appendix IV effective from 1 July 2026; correspondingly, Article 7 and Appendix IV of the 2020 Investment Law ceased to have effect on 1 July 2026.

Appendix IV of the 2025 Investment Law contains 198 sectors, down from 227 in Appendix IV of the 2020 Law — the new Law itself already removed a group of sectors from conditional business at statute level. The definition in Article 7(1) retains the previous approach: conditional investment business lines are those where conducting business must satisfy necessary conditions for reasons of national defence and security, social order and safety, social ethics, and community health.

The background layer serves two practical purposes today: (i) it explains the starting point of the reduction — why the figure 198 exists; and (ii) it is the reference for cross-checking when a sector appears in Appendix IV but not in the 142-sector list of Resolution 66.17 — that is precisely the group removed at the governing layer. Appendix IV is not the list currently in force while Resolution 66.17 remains effective.

On the implementing side, the Government issued Decree No. 96/2026/ND-CP on 31 March 2026, detailing and guiding the implementation of the Investment Law, effective from its signing date and replacing Decree No. 31/2021/ND-CP.

3. Layer 2 — Governing: Resolution 66.17/2026/NQ-CP (142 sectors, 1 July 2026–28 February 2027)

On 15 May 2026, the Government issued Resolution No. 66.17/2026/NQ-CP on cutting and amending conditional investment business lines. This is the instrument that determines what the list actually looks like today:

• Article 1 + Appendix: issues the conditional investment business lines list of 142 sectors — 56 fewer than the 198 in Appendix IV of the 2025 Investment Law.
• Article 6(1): the Resolution is effective from 1 July 2026 to 28 February 2027.
• Article 6(3): during the Resolution's effective period, where its provisions on conditional investment business lines differ from related legal instruments, the Resolution's provisions apply — Resolution 66.17 takes priority.
• Article 6(2): where a law or resolution of the National Assembly, an ordinance or resolution of the National Assembly Standing Committee, or a Government resolution regulating conditional business lines is passed or issued and takes effect between the signing of this Resolution and 28 February 2027, the corresponding provisions of this Resolution cease to have effect from the effective date of that instrument.

The sectors removed from conditional status in this cut are those where state management at the "business condition" level was assessed as no longer necessary — for example, accounting services and the bailiff profession (the latter still appears at item 15 of Appendix IV of the 2025 Investment Law but is gone from the 142-sector list of Resolution 66.17). Conversely, sectors sensitive to national defence, security and social order (seal manufacturing, support-tools trading, security services, casinos and prize-winning games, petroleum trading, legal practice, auditing, and others) remain on the list and continue to face strict conditions.

Article 6(3) must be understood precisely in practice: whenever the 142-sector list differs from any related instrument — including Appendix IV of the Law itself — businesses apply the 142-sector list. That is why this guide centres on Resolution 66.17, not Appendix IV.

4. Layer 3 — Transition: what happens to issued licences (Article 5)

The most practical question for businesses operating in a removed sector: do licences and certificates issued before 1 July 2026 remain valid, and is a termination procedure required? Article 5 of Resolution 66.17/2026/NQ-CP answers directly, leaving no room for open-ended phrasing:

For investment business lines regulated by the Investment Law that have been cut under this Resolution, organisations and individuals may continue to use the licences, certificates, practising certificates, confirmations, or other written investment/business authorisations issued by competent state authorities until the expiry stated in those documents.

The practical consequences run both ways:

1. Licences issued before 1 July 2026 for a removed sector remain valid until the expiry printed on them — no termination procedure is required, and they are not treated as void from 1 July 2026.
2. Businesses established after 1 July 2026 in a removed sector no longer need that licence as a market-entry condition. Other obligations under sectoral law (tax, labour, safety, reporting, and so on) still apply in full — leaving the conditional list does not mean leaving every obligation behind.

Note: this transitional rule covers only sectors cut under Resolution 66.17. For sectors remaining on the 142-sector list, licences and conditions under sectoral law continue to apply normally.

Two practical points complete the transition picture. First, a licence whose printed expiry falls between 1 July 2026 and 28 February 2027 cannot be renewed under the old sectoral regime if the sector has been cut — the business should plan the renewal timeline against the sector's new status rather than assuming an automatic extension. Second, keep documentary proof of the transition right: the original licence, the text of Article 5 of the Resolution, and a dated record of the business's continued operation. If a local authority or counterparty questions the licence's validity during the transition window, Article 5 is the operative citation — not a general argument that "the sector was cut". For sectors staying on the 142 list, the ordinary renewal and compliance regime continues unchanged.

5. Layer 4 — After 28 February 2027: the open point to monitor

Resolution 66.17/2026/NQ-CP is effective until 28 February 2027. After that date, the 142-sector list loses its legal footing — unless a new instrument is issued (a scenario the Resolution itself anticipates in Article 6(2): a new instrument on conditional business lines passed or issued and effective during this period progressively replaces the corresponding provisions).

This guide does not speculate on the content of the succeeding instrument. Instead, businesses need an active monitoring mechanism:

• Put 28 February 2027 on the internal compliance calendar now;
• Track new Government/National Assembly instruments on the conditional business lines list between now and the end of February 2027;
• This article is placed on a scheduled review before 28 February 2027 so the list, effective dates and transitional provisions can be updated (recorded in the legal notes).

6. How to check correctly — 4 steps

Step 1 — Precisely identify the planned business activity. Describe the actual business (what is produced, what services are supplied, to whom), then map it to VSIC codes. A business's commercial name rarely matches the sector name in the list.

Step 2 — Cross-check against the 142-sector list of Resolution 66.17/2026/NQ-CP. This is the governing instrument — verify whether each activity from Step 1 appears in this list. At the same time, cross-check the background (the 198-sector Appendix IV of the 2025 Investment Law) to understand whether the sector sits in the "cut at the Resolution layer" group or was never conditional.

Step 3 — If conditional: identify the specific conditions in the sectoral law. The list only names sectors — the concrete conditions (licences, certificates, capital, personnel), the issuing authority and processing times sit in the legislation governing that sector. This is the most time-consuming step and typically requires counsel's assistance.

Step 4 — For foreign investors: additionally check market access conditions. Cross-check the sector against Vietnam's WTO/FTA commitments for ownership caps or investment-form requirements. The 142-sector list applies to all investors; market access conditions for foreign investors are an additional layer. Only after all four steps is the full picture of legal obligations clear before launching the project.

Once determined, proceed to obtain the business licenses required after ERC issuance and build them into post-licensing compliance for FDI companies.

7. Action items now

1. Review all current and planned business lines against the 142-sector list of Resolution 66.17 — not the 198-sector Appendix IV. Prioritise identifying sectors in the Resolution-layer cut group (e.g., accounting services, the bailiff profession) to reassess licensing obligations.
2. For removed sectors: licences and certificates already issued remain usable until expiry (Article 5 of Resolution 66.17) — no renewal is needed for "maintaining business conditions" purposes, and new businesses need not apply afresh. Keep the issued documents on file to evidence continuity when required.
3. For sectors remaining on the 142-sector list: re-verify compliance with current sectoral-law conditions; complete or renew any missing licences so operations are not interrupted.
4. When completing business line registration for FDI companies or adding lines: check VSIC codes (for enterprise registration records) and the 142-sector list (for condition obligations) in parallel. The two systems are independent — holding a VSIC code does not authorise the activity if the sector is conditional.
5. Put 28 February 2027 on the monitoring calendar: update to the replacing/succeeding instrument of Resolution 66.17 before it expires.

8. Frequently asked questions

Which conditional business lines list applies from 1 July 2026? The 142-sector list issued with Government Resolution No. 66.17/2026/NQ-CP (signed 15 May 2026), effective from 1 July 2026 to 28 February 2027. During this period the Resolution's provisions take priority where they differ from related instruments (Article 6(3)). Appendix IV of the 2025 Investment Law (198 sectors) is only the legislative background.

My sector was removed from the conditional list — what happens to licences already issued? Under Article 5 of Resolution 66.17/2026/NQ-CP, licences, certificates and confirmations already issued remain usable until the expiry stated on the document. Businesses established after 1 July 2026 in a removed sector no longer need that licence as a market-entry condition — but must still comply with other sectoral obligations.

Where is the most reliable source to check whether a sector is conditional? The currently applicable source is the 142-sector Appendix issued with Resolution 66.17/2026/NQ-CP (effective until 28 February 2027). Note: the list only names sectors; the specific conditions sit in the corresponding sectoral legislation.

Do foreign investors face additional conditions beyond this list? Yes. Beyond the generally applicable 142-sector list, foreign investors must satisfy market access conditions under Vietnam's international commitments (WTO and FTAs). Some sectors unrestricted for domestic investors are restricted for foreign investors.

Need a compliance review for your business lines?

Checking the wrong list or applying the wrong governing instrument can leave a business operating without a required licence — or maintaining one it no longer needs. Both are costly. For a full review of business-condition obligations under the current 142-sector list, see the Vietnam investment guide for foreign investors or contact FLAT — hotline 0988424851.

References

• Resolution No. 66.17/2026/NQ-CP dated 15 May 2026 of the Government on cutting and amending conditional investment business lines (with the 142-sector Appendix).
• 2025 Investment Law (No. 143/2025/QH15), passed by the National Assembly on 11 December 2025.
• 2020 Investment Law (No. 61/2020/QH14) and amending laws — Article 7 and Appendix IV ceased to have effect on 1 July 2026.
• Decree No. 96/2026/ND-CP dated 31 March 2026 of the Government detailing and guiding the implementation of the Investment Law.

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