Renovating or expanding a leased factory is routine for FDI enterprises, but the line between self-done repairs and changes needing fresh fire approval is where many enterprises get it wrong. The cheapest handling of renovation of leased factories and repeat fire approval lies in file preparation and a compliance calendar from the year’s start, but management usually faces the question only after the event.
Original texts and validity to verify
For renovation of leased factories and repeat fire approval, a manufacturing FDI enterprise must determine whether its facility falls in the lists requiring fire design approval, acceptance testing and compulsory fire and explosion insurance under Decree 105/2025/ND-CP (amended by Decree 347/2026/ND-CP, effective 15/9/2026), on the basis of Fire Prevention, Fighting and Rescue Law 55/2024/QH15 (effective 01/7/2025). Do not use Decree 23/2018/ND-CP, which has expired; in renovation of leased factories and repeat fire approval, administrative fines follow the current penalty decree on fire prevention, fighting and rescue, with possible suspension of the violating part’s operation.
Points that decide the outcome in practice
- Changes affecting fire solutions need re-approval of the changed part. When renovation changes function, layout, technical systems or scale versus the approved file, the changed part must pass fire design approval before construction and acceptance before use.
- Function change is the most sensitive change. Turning a warehouse into a workshop, a workshop into chemical storage, or raising people and goods density changes the works’ fire hazard group; this almost always needs re-approval and may force upgrading existing systems.
- Procedure duty defaults to the facility operator. Whether the factory owner or the tenant runs the procedures must be agreed clearly in the lease; toward authorities, the enterprise operating the facility under its name bears its fire compliance duty.
What to do now
- Build a current-versus-approved comparison table for every planned renovation item, marking items touching fire solutions.
- Seek the fire authority’s written opinion on the function-change plan before signing the renovation contract.
- Write the duty and cost split for re-approval into a lease annex before renovation starts.
Conclusion
On renovating expanding leased factory new fire approval required, enterprises lose most not because the law is unfavorable but because they discover the problem late; a periodic review calendar costs far less than crisis handling.
Frequently Asked Questions
Does renovating a leased factory need new fire approval?
From the actual file’s perspective: Changes affecting fire solutions need re-approval of the changed part. When renovation changes function, layout, technical systems or scale versus the approved file, the changed part must pass fire design approval before construction and acceptance before use. Minor repairs not changing approved fire solutions need no re-approval — the line is the degree of impact on the approved file. Keep supporting records year by year.
What if the use function changes?
Short answer: Function change is the most sensitive change. Turning a warehouse into a workshop, a workshop into chemical storage, or raising people and goods density changes the works’ fire hazard group; this almost always needs re-approval and may force upgrading existing systems. Minor repairs not changing approved fire solutions need no re-approval — the line is the degree of impact on the approved file. Check this against the project file first.
Owner or tenant — who runs the procedures?
In principle: Procedure duty defaults to the facility operator. Whether the factory owner or the tenant runs the procedures must be agreed clearly in the lease; toward authorities, the enterprise operating the facility under its name bears its fire compliance duty. Minor repairs not changing approved fire solutions need no re-approval — the line is the degree of impact on the approved file. If authority is unclear, ask in writing.
What is the fine for not re-applying?
The distinction that matters: Changes affecting fire solutions need re-approval of the changed part. When renovation changes function, layout, technical systems or scale versus the approved file, the changed part must pass fire design approval before construction and acceptance before use. Minor repairs not changing approved fire solutions need no re-approval — the line is the degree of impact on the approved file. Fix verbal understandings in writing.
This article has been quality-reviewed by the FLAW AI Legal Council