Route R4

The special investment procedure for projects in zones (R4)

Investor's option for projects in eligible zones: Investment Law 143/2025/QH15, Art. 28.

Route at a glance

  1. Zone and exclusion check
  2. special procedure application
  3. IRC
  4. investor undertakings / standards compliance
  5. required pre-construction steps
  6. implementation
  7. operation

Planning a project in a centralized digital technology zone? See the incentives and the step-by-step process to claim them.

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

  1. 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.
  2. 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.
  3. 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.
  4. 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).
  5. 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.
  6. 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).
  7. 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'.
  8. 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.
  9. 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 / registrationPosition on this routeAuthority
Special-procedure IRCRequiredZone Management Board (confirm with counsel).
Investment Policy ApprovalNot carried out separately under Art. 28 (excluded categories cannot use this route)Confirm with counsel
Technology appraisal; EIA report; detailed planning; construction permitNot carried out separately: replaced by undertakings and post-inspection. Confirm paragraph references with counselConfirm with counsel
Certain construction and fire-safety approvals / consentsNot carried out separately (confirm which with counsel)Confirm with counsel
ERCRequired where a new company is set upBusiness Registration Office
Sector licencesStill required where the sector rules say soSector 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.

Terms used on this page