This article is for reference only and does not constitute legal advice. Content reviewed by the FLAW AI Legal Council.
Investment dossiers submitted before 1 March 2026 but not yet granted an IRC: which law applies? The transition rules of the Investment Law 2025 give a clear answer.
1. General rule: continue under the 2020 Law
Valid dossiers already received by the competent authority under the Investment Law 2020 but without a result before 1 March 2026 continue to be processed under the 2020 Law — no need to refile (Article 52.14 of Law No. 143/2025/QH15).
2. Exception: Prime Minister-level dossiers
Dossiers under the Prime Minister’s investment-policy approval authority (submitted or not yet submitted before the new Law took effect, but not meeting 2020 requirements) are transferred by the Ministry of Finance to the provincial People’s Committee Chairperson for handling under the 2025 Law; existing dossiers and appraisal opinions may continue to be used (Article 52.14(a)–(b)).
3. Special investment procedures: two options
For special-procedure dossiers (industrial parks, export processing zones, high-tech parks, concentrated digital technology zones, free trade zones, international financial centers, functional areas in economic zones) received by the Management Board but without a result, investors have two options: (a) continue under the 2020 Law + Decree 31/2021; or (b) supplement commitments under Decree 96/2026/ND-CP Article 47.2 to obtain an IRC under the new special procedure (Article 100 of Decree 96/2026/ND-CP).
4. Comparison table
| Situation | Applicable rule |
|---|---|
| Valid dossier received, no result yet | Continue under 2020 Law (Art. 52.14) |
| PM-level dossier not meeting requirements | Transferred to provincial Chairperson (Art. 52.14(a)) |
| PM-level dossier not yet submitted | Transferred to provincial Chairperson (Art. 52.14(b)) |
| Special-procedure dossier pending | Continue under old law or opt into new procedure (Art. 100 Decree 96/2026) |
5. Practical notes
- Completed procedures before 1 March 2026 are not redone; but later adjustments subject to new-law approval follow new procedures (Article 52.2–52.3);
- Dossiers merely sent but not yet received by the authority are not covered by the transition rule — confirm with the authority case by case.
Contact FLAT Law Firm for support with pending investment dossiers under the transition rules.
