Vietnam Resolution No. 66.17/2026/NQ-CP on Conditional Business Sectors: What Foreign Investors Should Check

Vietnam has cut back the list of business activities that need special approval. Vietnam Resolution No. 66.17/2026/NQ-CP on Conditional Business Sectors took effect on July 1, 2026. It applies for a limited period, and a further revision of the list is expected.

A company should check the list whenever it starts a new activity, adds a service or buys another business. Compare the planned work against the current list first, then check the separate rules that apply to that sector.

What Vietnam Resolution No. 66.17/2026/NQ-CP on Conditional Business Sectors Changes for a New Project

The Resolution temporarily replaces the list used under the Vietnam Investment Law 2025. The list is now shorter. It has come down from close to two hundred entries to a little over one hundred. Some older entries have been dropped, some merged, and some reworded. Any of these can change the answer for a new project, an expansion or the purchase of an existing company.

A shorter list may mean less licensing work. It does not give every removed activity a free pass. A separate law may still set rules for the product, the people doing the work, the premises or the way the service is delivered.

Some activities still need a license or certificate before the business can start. Others only need a filing, and the authorities check the company later. The Resolution does not set one common process for every activity. The sector rule still decides.

Factories should keep checking product, safety and environmental rules. Those duties can survive even when the main activity is no longer named on the list.

Digital businesses should be careful how they describe their service. A company planning to run an exchange should check the separate rules for data exchange services under Decree No. 314/2026/ND-CP. A company that only uses data in its own daily work is usually in a different position.

Existing permits are worth a second look. A permit for an activity that has come off the list can still be used until it expires, if the holder wants to keep it. If an application is still pending and the approval is no longer needed, ask the authority for a written reply and keep it in the company file.

A Simple Check Before Entry or Expansion

Check what the company will actually do, in plain business language. Name the products, the services and the customers the company expects to have. Then compare that description against the current list of conditional investment sectors in Vietnam. Broad wording in the registration papers rarely shows the full picture.

If an activity is on the list, find the rule behind it. The company may need qualified staff, suitable premises, minimum capital, technical equipment or a separate approval. All of these are far easier to arrange before the company signs a lease, hires a team or fixes a launch date.

Check foreign ownership separately. A business may still carry an ownership cap, a local partner requirement or an approval step for a share purchase. Compare the proposed structure against the rules on foreign ownership and market access in Vietnam.

If the company is buying a Vietnamese business, look at what the target sells and how it earns its money. Check the main contracts, the permits and any recent inspection records. Registered business lines are often too general to rely on.

The shorter list may make entry easier for some projects. Management should still ask what other rules apply. A short written check now can save weeks of delay after the lease is signed or the purchase money has moved.

What Management Should Ask Now

The business team should sit down with legal or compliance and answer these questions:

What will the company actually make, sell or provide in Vietnam?

Is any part of that work still on the current conditional business list?

What approval, staff, premises or equipment is needed before work starts?

If an activity was removed or renamed, what other sector rule still applies?

Do the planned foreign ownership and management rights need a separate approval?

Answer and solutions to such will help management track the work and explain the decision later.

Frequently Asked Questions About Vietnam Resolution No. 66.17/2026/NQ-CP

Q1: Does a shorter list mean fewer licenses?

Sometimes. It depends on the sector rule. Another approval, standard or filing may still apply even after an activity comes off the investment list.

Q2: Can the company rely on its enterprise registration certificate?

No. The certificate is useful, but its business lines can be broad. The company should check the products and services it actually plans to provide, together with the rules for those activities.

Q3: Should a longer-term project be checked again before it starts?

Yes. This Resolution is a temporary measure and a replacement list is expected. A project that will not begin for some time should be checked again before the company makes a final investment decision.

Conclusion

Vietnam Resolution No. 66.17/2026/NQ-CP on Conditional Business Sectors changes where management should start when planning a new project or an expansion. Describe the planned business clearly, check whether a special condition still applies, and confirm any separate foreign ownership rule. That is usually enough to tell management whether the project can move ahead or needs more work first.

About the Author

About ANT Lawyers, a Law Firm in Vietnam

Founded in 2012, ANT Lawyers is a Vietnam law firm with offices in Hanoi, Ho Chi Minh City and Da Nang. Our corporate lawyers advise on company formation, investment licensing, M&A and corporate governance in Vietnam. We combine legal analysis with practical understanding of Vietnam’s regulatory environment and local administrative practice.

General Disclaimer

This article is for general informational purposes only, does not constitute legal advice, and does not create a lawyer-client relationship. Vietnamese laws, regulations and administrative practice change over time, and the correct position for any matter depends on its specific facts and the rules in force when action is taken. Verify the current position before relying on anything stated here, and consult qualified counsel on your specific situation.