Foreign-invested logistics companies wishing to provide international multimodal transport services in Vietnam must note two major 2026 changes: licensing authority has moved from the Ministry of Transport to the Ministry of Construction (Decree 14/2026/ND-CP), and multimodal transport has been removed from the conditional business list since 1 July 2026 — yet Decree 87/2009/ND-CP on multimodal transport has not been repealed, creating a transition period that calls for caution.
1. Current legal framework
- Decree 87/2009/ND-CP — on multimodal transport; still in force, amended by Decree 144/2018/ND-CP and Decree 14/2026/ND-CP (effective 15/1/2026);
- Investment Law 143/2025/QH15 (Article 7 and Appendix IV, effective 1/7/2026) — multimodal transport has been removed from the conditional business list since 1/7/2026;
- Decree 96/2026/ND-CP (31/3/2026) — guiding the Investment Law (replacing Decrees 31/2021, 19/2025, and 239/2025).
2. What is international multimodal transport?
International multimodal transport is carriage combining two or more transport modes (road, rail, inland waterway, sea, air) under a single multimodal transport document, with the multimodal transport operator responsible for the entire journey from the place of receipt to the place of delivery.
3. New authority: the Ministry of Construction issues the license
A key change under Decree 14/2026/ND-CP (effective 15/1/2026): international multimodal transport business licenses are now issued by the Ministry of Construction — no longer by the Ministry of Transport (following the merger of the Ministry of Transport into the Ministry of Construction). Processing time: 3 working days from receipt of a complete and valid dossier.
Companies should file under the Ministry of Construction’s current guidance; references to the “Ministry of Transport” in dossiers, contracts, or internal documents should be updated to the correct authority.
4. Conditions for international multimodal transport business
Under Decree 87/2009/ND-CP (as amended), international multimodal transport operators must meet core conditions (check the original text and Decree 14/2026 before filing):
- Financial security: maintain a deposit or a credit-institution guarantee covering liability for goods in transit;
- Personnel: have managers and responsible officers meeting professional qualification and experience requirements;
- Means and equipment: meet conditions on transport means and equipment serving multimodal operations.
5. The transition period: removed from the conditional list, but Decree 87/2009 still applies
This is the most delicate point today. Since 1/7/2026, Investment Law 143/2025 has removed multimodal transport from the conditional business list. However:
- Decree 87/2009/ND-CP has not been repealed — its rules on international multimodal transport business licenses textually remain in place;
- The relationship between the Appendix IV removal and the continued validity of Decree 87/2009 has not been fully clarified.
Therefore, do not firmly conclude that “no license is needed anymore”. Companies should contact the Ministry of Construction directly to confirm the licensing requirements applicable to their specific case during this transition, and monitor further guiding or amending instruments.
6. Foreign-invested logistics companies: market access
For foreign-invested logistics companies, market access follows Vietnam’s WTO commitments and investment law. The law imposes no nationality-specific condition for multimodal transport beyond the general foreign-investment framework — but investors should review the specific market-opening commitments for each logistics sub-sector and complete investment procedures (IRC/ERC) before applying for the sectoral license.
FAQ
Q: Where do we apply for an international multimodal transport license?
A: The Ministry of Construction — under Decree 14/2026/ND-CP (effective 15/1/2026). No longer the Ministry of Transport.
Q: How long does licensing take?
A: 3 working days from receipt of a complete and valid dossier.
Q: Multimodal transport is off the conditional list — is a license still required?
A: We are in a transition period — Decree 87/2009 has not been repealed. Do not conclude on your own that “no license is needed”; confirm with the Ministry of Construction for your specific case.
Q: Can foreign-invested companies provide international multimodal transport?
A: Market access follows WTO commitments and investment law; review the opening commitments for the specific logistics sub-sector and complete investment procedures first.
Q: What financial conditions apply?
A: Financial security in the form of a deposit or bank guarantee is required — check Decree 87/2009 (as amended) for specifics.
Sources
- Decree 87/2009/ND-CP (amended by Decrees 144/2018 and 14/2026 — effective 15/1/2026);
- Investment Law 143/2025/QH15 (Article 7, Appendix IV — effective 1/7/2026);
- Decree 96/2026/ND-CP (31/3/2026) — guiding the Investment Law.
See also: Investment Registration Certificate (IRC) for foreign investors | Visa and residence roadmap for foreign investors | FLAT Law Firm
Contact us
FLAT Law Firm advises foreign-invested logistics companies: investment procedures, international multimodal transport licensing with the Ministry of Construction, WTO commitment reviews, and transition-period issues. Contact: contact us.
This article is for general information only and does not constitute legal advice for your specific situation.
Transparency note: This article was quality-checked (QA) by the editorial team with the support of the AI Legal Council; it has not been reviewed or approved by a licensed attorney.