When this route applies
- The investor may CHOOSE this procedure for a project located in: an industrial park; an export processing zone; a high-tech zone; a centralized digital technology zone; a free trade zone; the International Financial Centre; or a functional area within an economic zone (Investment Law 143/2025/QH15, Art. 28).
- There is no general sector test. The exception is negative: projects that must obtain Investment Policy Approval in the cases prescribed by the Government are excluded. Decree 96/2026/NĐ-CP identifies the excluded project categories. Counsel records the conclusion in Questionnaire L3.
- What the investor does NOT have to carry out separately under this procedure: Investment Policy Approval; technology appraisal; the EIA report; detailed planning; the construction permit; and certain approvals and consents in construction and fire prevention and fighting. Exact list and article references (confirm paragraph numbers in Art with counsel). 28 and Decree 96/2026/NĐ-CP.
- What stays: every substantive standard. The investor gives written undertakings to meet the construction, environmental and fire-safety conditions, standards and technical regulations, completes the pre-construction steps that remain, and is subject to State post-inspection. A false or unmet undertaking falls on the investor.
- Market-access limits and sector licences are not relaxed by this procedure.
Step-by-step roadmap
Zone and exclusion check
- Authority
- No filing: internal analysis
- Investor action
- Confirm the site is in one of the seven eligible zone types and that the project is outside the excluded categories of Decree 96/2026/NĐ-CP
- Documents
- Business description; zone documents
- Dependency
- None
- Output
- Availability memo (Questionnaire L3)
- Can next step start?
- Yes
- Critical issue
- Two tests only: eligible zone, and not an excluded category. There is no sector list to satisfy.
Market-access check
- Authority
- No filing: internal analysis
- Investor action
- As in R1
- Dependency
- None
- Output
- Go / no-go
- Can next step start?
- Yes
- Critical issue
- The special procedure does not relax market-access limits.
Special procedure application
- Authority
- Zone Management Board (confirm with counsel).
- Investor action
- File the registration dossier with the required undertakings
- Documents
- Application; project proposal; investor documents; written undertakings on construction, environment and fire-safety standards (confirm content with counsel)
- Dependency
- Steps 1-2
- Output
- Dossier accepted
- Can next step start?
- No
- Critical issue
- Undertakings must be specific; they are the basis for later inspection.
IRC
- Authority
- Zone Management Board (confirm with counsel).
- Investor action
- Receive the IRC
- Dependency
- Step 3
- Output
- IRC
- Can next step start?
- Yes
- Critical issue
- Statutory time limit is short compared with the ordinary route (confirm with counsel).
ERC (if a new company is needed)
- Authority
- Business Registration Office
- Investor action
- Incorporate
- Documents
- As in R1
- Dependency
- Confirm sequence with counsel
- Output
- ERC
- Can next step start?
- Yes
- Critical issue
- ERC = company exists; nothing more.
Investor undertakings / standards compliance
- Authority
- Investor (self-certification); zone and specialist authorities inspect
- Investor action
- Design the project to the applicable technical regulations and standards; keep evidence
- Documents
- Design files; standards compliance evidence
- Dependency
- IRC
- Output
- Compliance file
- Can next step start?
- Yes
- Critical issue
- Breach of an undertaking can lead to suspension or termination (confirm sanctions with counsel).
Required pre-construction steps
- Authority
- Zone Management Board; specialist authorities
- Investor action
- Give the notices and lodge the documents that the special procedure still requires before works start (confirm list with counsel)
- Dependency
- Step 6
- Output
- Works may start
- Can next step start?
- No
- Critical issue
- Do not assume 'no permit' means 'no paperwork'.
Implementation (construction, installation)
- Authority
- Inspections by competent authorities
- Investor action
- Build in line with the undertakings
- Documents
- Site records
- Dependency
- Step 7
- Output
- Completed facilities
- Can next step start?
- Partly
- Critical issue
- Post-inspection replaces pre-approval, so records matter.
Sector licences, operational registrations, go-live
- Authority
- Sector regulator; tax; labour
- Investor action
- As in R1
- Dependency
- All above
- Output
- READY TO OPERATE
- Critical issue
- Sector licences are not waived by the special procedure (confirm any exceptions with counsel).
Required approvals
| Approval / registration | Position on this route | Authority |
|---|---|---|
| Special-procedure IRC | Required | Zone Management Board (confirm with counsel). |
| Investment Policy Approval | Not carried out separately under Art. 28 (excluded categories cannot use this route) | Confirm with counsel |
| Technology appraisal; EIA report; detailed planning; construction permit | Not carried out separately: replaced by undertakings and post-inspection. Confirm paragraph references with counsel | Confirm with counsel |
| Certain construction and fire-safety approvals / consents | Not carried out separately (confirm which with counsel) | Confirm with counsel |
| ERC | Required where a new company is set up | Business Registration Office |
| Sector licences | Still required where the sector rules say so | Sector regulator |
Document checklist
Typical: the authority may ask for more.
- Documents in R1 for IRC / ERC
- Written undertakings to satisfy construction, environmental and fire-safety conditions, standards and technical regulations (confirm form with counsel)
- Proposal assessing conformity with zone planning
- Evidence that the site is inside an eligible zone; counsel note that the project is not an excluded category
Critical risks
- Misjudging the excluded categories and losing time before reverting to the ordinary route.
- Treating the undertaking as a formality; liability shifts to the investor.
- Lenders and insurers may still ask for conventional approvals or third-party certification.
When the investor may legally start operations
The investor may start a given business activity only when ALL of the following are in place for that activity: (1) the investment procedure is complete (IRC / approval, where required); (2) the company or other vehicle legally exists (ERC or equivalent); (3) capital has been contributed through the correct account and on schedule; (4) the premises may lawfully be used for the activity; (5) construction, environmental and fire-safety steps that apply are complete; (6) every sector-specific licence for that activity has been issued; and (7) tax, invoicing and employment registrations are done. Use the GO-LIVE CHECKLIST to confirm.
Common mistakes
- Assuming the procedure exempts the project from environmental or fire-safety law.
- Assuming it relaxes foreign-ownership limits.
- Poor record-keeping ahead of post-inspection.
Statutory time limits are not shown on this page. Confirm the current period and its legal basis with counsel: practical timing is usually longer than the statutory period. Legal status reviewed as of 18 September 2026.