38 Business Lines Removed in Vietnam: 2026 Guide

38 Business Lines Removed in Vietnam: What Changed in 2026?

Vietnam removed 38 activities from its list of conditional business lines as part of the 2026 reform of the Law on Investment. The changes cover tax and customs services, employment services, construction, transportation, data centres, agriculture, healthcare and several other sectors.

However, being removed from Appendix IV does not necessarily mean that an activity is free from every licence, technical standard or compliance requirement. A company may still need sector approval, qualified personnel, a suitable facility, product permits or foreign investment approval.

The 38 business lines removed also represent only one stage of the reform. Resolution No. 66.17/2026/NQ-CP subsequently replaced the 198-line list with an interim list of 142 conditional business lines from July 1, 2026. Businesses should therefore review both the removed activities and Vietnam’s current list of 142 conditional business lines.

Key Takeaways

• Vietnam removed 38 activities as separate conditional business lines under the 2025 Law on Investment reform.

• The relevant changes applied from July 1, 2026.

• The 38 removed activities cover finance, trade, employment, construction, transportation, technology, healthcare and agriculture.

• The number 38 is different from the later reduction of the list from 198 to 142 under Resolution 66.17.

• Removal from Appendix IV does not automatically cancel every sector licence or operating requirement.

• Foreign investors must separately review foreign ownership and market-access conditions.

• Existing licences and certificates may continue to be used until their expiration date.

• Resolution 66.17 applies through February 28, 2027, unless another legal document replaces the relevant provisions earlier.

Quick Answer

The 38 business lines removed in Vietnam are activities that ceased to be listed as separate conditional business investment lines following the revision of Appendix IV to the Law on Investment. They include tax procedure services, customs procedure services, employment services, labour outsourcing, data centre services, architectural services, study-abroad consulting, cosmetic surgery and several transport, agricultural and land-information services. This change can reduce pre-operation licensing barriers. However, companies must still check specialised legislation, technical standards, post-licensing inspections and foreign investment restrictions before beginning operations.

Why Are There Both 38 and 56 Business Lines in the 2026 Reform?

The figures refer to two separate stages of Vietnam’s regulatory reform.

The figures should not be added together to conclude that 94 or 95 industries became completely unregulated. Some entries were removed, while others were narrowed, merged into broader categories or moved to management through technical standards and post-operation inspections.

The practical question is not simply how many lines disappeared. A company must identify whether its exact activity remains regulated under:

• the current list of 142 conditional business lines;

• another specialised law;

• technical or occupational standards;

• foreign investor market-access rules; or

• product-, facility- or project-level licensing requirements.

Full List of 38 Business Lines Removed in Vietnam

Finance, Accounting and Commercial Services

These activities are no longer treated as separate conditional business lines in Appendix IV. Nevertheless, removal from the list does not necessarily eliminate the regulations governing the actual service.

For example, tax agents and customs service providers may still have professional, registration, reporting or personnel obligations under tax and customs legislation. Temporary import and re-export activities remain subject to customs procedures, import-export controls and product-specific rules.

Insurance support services may still be regulated under insurance legislation, while energy auditing may remain subject to technical and professional standards. Printing and minting money should not be interpreted as an activity opened to private businesses merely because it was removed from the conditional list. State monopoly and specialised rules may continue to apply.

Employment, Social, Cultural and Health Services

Employment and education-related businesses may benefit from fewer market-entry barriers, but they should continue reviewing labour, education, advertising and consumer-protection rules.

Cosmetic surgery remains a healthcare activity. Medical establishment licences, practitioner certificates, facility standards and patient-safety requirements may still apply under medical examination and treatment legislation.

Organisers of performances, fashion shows or beauty contests may no longer face the former industry-level condition, but individual events may still require notification, approval or compliance with cultural and advertising regulations.

Construction and Transportation

This group contains some of the most commercially important changes, but it also illustrates why removal from Appendix IV should not be confused with complete deregulation.

A foreign construction contractor may still need to comply with bidding, construction capability, tax and project approval requirements. Architects and other professionals may still require individual practice certificates. Maritime, aviation and vehicle-related activities remain subject to specialised safety and technical legislation.

Labour outsourcing is also governed by employment law. Companies should not begin supplying outsourced workers solely because the activity was removed as a separate entry from Appendix IV. They should check whether the Labour Code, implementing regulations or later guidance continues to impose operating conditions.

Technology, Measurement and Land Information

Removing data centre services from the conditional business list may make market entry easier for technology investors. However, a data centre project can still involve requirements relating to construction, electricity, fire prevention, environmental protection, cybersecurity, telecommunications and personal data protection.

Foreign investors must also review the legal structure of the project, land or premises arrangements, foreign ownership rules and whether the project requires an Investment Registration Certificate.

Measurement services may remain subject to technical standards and accreditation requirements. Land information and database projects may also be controlled through public procurement, data security and land-sector regulations.

Agriculture, Forestry and Fisheries

These activities remain highly regulated despite their removal as separate conditional business lines. CITES permits, wildlife protection rules, quarantine procedures and origin documents may still be required.

Food businesses must continue complying with food safety, product quality, labelling, traceability and facility requirements. Animal quarantine activities may remain subject to veterinary and biosecurity standards.

For these activities, removal from Appendix IV mainly changes the classification and regulatory mechanism. It should not be treated as permission to conduct wildlife, food or quarantine activities without specialised approval.

What Does Removal From the Conditional Business List Mean?

Removal generally means that an activity is no longer classified as a separate conditional business investment line under Appendix IV. It may reduce the need for an enterprise to prove certain conditions before market entry.

Depending on the activity, the government may manage risks through:

• national technical regulations;

• occupational or professional standards;

• product-specific approvals;

• facility inspections;

• reporting requirements;

• contractual and civil liability;

• administrative penalties; or

• post-operation inspections.

Under Resolution No. 66.17/2026/NQ-CP, ministries and sector authorities are responsible for developing replacement management measures where necessary. These measures may include technical regulations, professional standards and post-inspection procedures.

Therefore, a removed activity can still be regulated even if it no longer appears as a standalone item in Appendix IV.

Does Removal Mean That No Business Licence Is Required?

Not always. A company may still need one or more approvals depending on its actual operations.

Possible requirements include:

• an operating licence under a specialised law;

• a practising certificate for individual professionals;

• approval for a particular product or transaction;

• fire prevention and firefighting documents;

• environmental approval or registration;

• construction or land approval;

• food safety or quarantine documents;

• CITES or wildlife-related permits;

• cybersecurity or personal data compliance;

• registration of a website or digital platform;

• foreign investment approval; or

• amendment of the company’s IRC or ERC.

The correct question is not simply, “Was this business line removed?” The company should ask, “Which market-entry condition was removed, and which operational requirements continue to apply?”

What Foreign Investors Must Check

Foreign investors have additional obligations beyond the domestic conditional business list.

1. Define the actual business activities

The investor should describe what the company will sell, produce or provide in practice. A broad description such as “consulting,” “technology” or “trading” may not be sufficient to identify all applicable conditions.

2. Select the correct business codes

The proposed activities should be matched with Vietnam’s business classification system. An activity can fall under more than one code or involve several related regulated services.

3. Check the current 142-line list

The company should compare its activities with the wording of the current list under Resolution 66.17. A removed activity may still fall within a broader conditional category.

4. Review specialised legislation

The investor should identify any staff, facility, capital, safety, product, environmental or technical standards under the relevant sector law.

5. Check foreign market-access conditions

Foreign investors must separately review:

• foreign ownership limitations;

• requirements for a Vietnamese partner;

• restrictions on the permitted investment form;

• requirements relating to investor experience or financial capacity;

• treaty commitments applicable to the investor’s nationality; and

• approval procedures for restricted sectors.

Removal from the domestic conditional business list does not automatically remove a foreign ownership restriction.

6. Review the IRC and ERC

An existing foreign-invested company may need to amend its Investment Registration Certificate or Enterprise Registration Certificate before adding a new activity. A new company should ensure that the proposed activities are described consistently throughout its investment and incorporation documents.

7. Confirm post-licensing requirements

The company should confirm which registrations, reports, internal policies and operating records must be completed after incorporation but before commercial operations begin.

What Happens to Existing Licences?

Resolution 66.17 contains a transitional rule for licences and similar approvals connected with activities reduced under the Resolution.

Organizations and individuals may continue using existing:

• operating licences;

• certificates;

• practising certificates;

• written confirmations; and

• other forms of written authorization

until those documents expire.

A business should not surrender or cancel an existing licence simply because its activity was removed from the conditional list. The document may remain relevant under another law, support an inspection or be required by a bank, customer, landlord or business partner.

Before allowing a licence to expire, the company should check whether it must renew, replace or convert the document under new sector guidance.

Opportunities Created by the Reform

Easier market entry for business services

Tax support, customs support, commercial inspection and archiving businesses may face fewer general entry barriers. This may encourage new providers and increase competition.

Expansion of HR and professional services

Employment, outsourcing, architecture and construction consultancy businesses may find it easier to register activities. However, professional qualifications and employment rules may remain relevant.

Increased interest in data centres

Removing data centre services from the list supports Vietnam’s wider digital economy and infrastructure development. Investors must still complete a project-level review covering property, power, construction, security and data compliance.

Lower barriers in construction and logistics

Changes affecting foreign contractors, maritime services, multimodal transport and vehicle services may simplify entry. Technical safety and project requirements will remain central to compliance.

Compliance Checklist for Affected Businesses

A company planning to enter or expand within one of the 38 business lines removed should complete the following steps:

1. Describe the actual products and services the company will provide.

2. Identify the correct Vietnamese business codes.

3. Check the current 142 conditional business lines.

4. Review the specialised legislation governing the activity.

5. Check foreign ownership and market-access conditions.

6. Confirm whether an IRC or ERC amendment is required.

7. Identify any product-, facility- or project-level approval.

8. Review existing licences before allowing them to expire.

9. Prepare staff, safety, technical and operating records for later inspection.

10. Monitor new legal documents issued before March 1, 2027.

    
    

Common Mistakes to Avoid

Assuming that “removed” means “unregulated”

The activity may still be controlled through sector legislation, technical standards or post-operation inspection.

Confusing the figures 38 and 56

The 38 removed business lines relate to the revision of Appendix IV. The reduction from 198 to 142 under Resolution 66.17 is a separate step involving removals, amendments and consolidation.

Ignoring foreign investor restrictions

The domestic conditional list and foreign market-access rules are different legal checks.

Starting operations after registering only the business code

Registration on the ERC does not prove that the company has completed every specialised requirement.

Cancelling an existing licence too early

Existing licences may remain valid and useful until their expiration date.

Failing to prepare for post-licensing inspection

Lower pre-operation barriers may lead to greater responsibility for maintaining records and proving compliance after the business begins operating.

How VINEX Can Help

VINEX assists foreign investors and foreign-invested companies with business-line reviews, market-access assessments and company registration in Vietnam.

Our team can:

• compare your proposed activities with the current 142-sector list;

• identify business codes and specialised licensing requirements;

• review foreign ownership and investment conditions;

• prepare IRC and ERC applications or amendments;

• assess existing licences affected by the reform;

• create a post-licensing compliance checklist; and

• support ongoing accounting, tax, payroll and corporate compliance.

Learn more about company incorporation in Vietnam or contact VINEX for legal and investment advisory support.