In December 2025, the National Assembly of Vietnam passed amendments to the Law on Investment, with the clear objective of substantially improving the ease of doing business. A key pillar of this reform is the overhaul of conditional business lines, resulting in the abolition of 38 conditional business lines and the revision of 27 others.
The article below highlights these new developments and explains how they are intended to encourage foreign investment, in line with the policy direction set out in Resolution No. 68-NQ/TW and Resolution No. 198/2025/QH15 on promoting and strengthening the private sector in Vietnam.
What are conditional business lines?
In Vietnam, companies are permitted to conduct business only within the scope of their registered business lines. Business lines refer to the specific activities a company is authorised to carry out, as recorded in its Enterprise Registration Certificate (ERC) and, where applicable, its Investment Registration Certificate (IRC). Conditional business lines are sectors in which companies may operate only after satisfying certain statutory requirements. These conditions typically relate to matters such as minimum charter capital, professional qualifications, technical standards, or the requirement to obtain additional sublicenses or approvals from competent authorities. Vietnam imposes such conditions because these activities may affect national security, public order, social ethics, public health, or the broader public interest. As a result, these sectors are considered sensitive, and enterprises must demonstrate compliance before being permitted to operate fully.
The regulatory framework for conditional business lines is governed primarily by the Law on Investment, which sets out the official list of conditional business lines in Appendix IV. Under the Law on Investment 2020, this list comprises more than 200 conditional business lines, ranging from major sectors such as finance and energy to more specialised or technical activities. Where a business line does not fall within the conditional list and is not prohibited, it is treated as an ordinary business line. In such cases, a company may lawfully conduct the activity simply by registering it with the licensing authority, without the need to obtain sublicenses or satisfy special operating conditions.
Update on conditional business lines from 2026
In December 2025, the Vietnamese National Assembly passed the amended Law on Investment, introducing a significant reform of the conditional business lines regime. Under this amendment, 38 conditional business lines have been abolished, mostly services, in which all necessary permits/sub-licenses are suggested to be removed; and 27 conditional business lines have been revised. As a result, the total number of conditional business lines will be reduced from 237 to 198.
Following the reform, the remaining conditional business lines are largely concentrated in sensitive and regulated sectors, including:
- Finance, banking, and insurance;
- Agriculture and related activities;
- Construction;
- Transportation and logistics; and
- Certain other industries subject to sector-specific management.
| No. | Conditional business line to be removed | Business sector |
|---|---|---|
| 1. | Tax procedure services | Finance, Accounting, Commerce |
| 2. | Customs procedure services | Finance, Accounting, Commerce |
| 3. | Insurance auxiliary services | Finance, Accounting, Commerce |
| 4. | Commercial inspection services | Finance, Accounting, Commerce |
| 5. | Temporary import and re-export of goods subject to excise tax | Finance, Accounting, Commerce |
| 6. | Temporary import and re-export of frozen food | Finance, Accounting, Commerce |
| 7. | Temporary import and re-export of used goods | Finance, Accounting, Commerce |
| 8. | Energy auditing | Finance, Accounting, Commerce |
| 9. | Employment services | Culture, Society and Health |
| 10. | Labour outsourcing services | Construction, Transportation |
| 11. | Automobile warranty and maintenance services | Construction, Transportation |
| 12. | New building, conversion, repair, and restoration of inland waterway vehicles | Construction, Transportation |
| 13. | Maritime safety assurance services | Construction, Transportation |
| 14. | Sea towing services | Construction, Transportation |
| 15. | New building, conversion, and repair of ships | Construction, Transportation |
| 16. | Flight operation assurance services | Construction, Transportation |
| 17. | Multimodal transport services | Construction, Transportation |
| 18. | Architectural services | Construction, Transportation |
| 19. | Construction activities by foreign contractors | Construction, Transportation |
| 20. | Cost management services for construction investment | Construction, Transportation |
| 21. | Management and operation services for apartment buildings | Construction, Transportation |
| 22. | Management and operation services for cremation facilities | Culture, Society and Health |
| 23. | Data centre services | Technology, Land |
| 24. | Study abroad consulting services | Culture, Society and Health |
| 25. | Breeding and planting of wild species listed under CITES and the endangered species lists | Agriculture, Forestry, Fisheries |
| 26. | Breeding common wild animals | Agriculture, Forestry, Fisheries |
| 27. | Export, import, re-export, transit, and introduction from sea of natural specimens of species under CITES and endangered species lists | Agriculture, Forestry, Fisheries |
| 28. | Export, import, and re-export of artificially propagated or bred specimens under CITES and endangered species lists | Agriculture, Forestry, Fisheries |
| 29. | Processing, trading, transporting, advertising, displaying, and storing specimens of species under CITES and endangered species lists | Agriculture, Forestry, Fisheries |
| 30. | Trading food under the specialised management of the Ministry of Agriculture and Rural Development | Agriculture, Forestry, Fisheries |
| 31. | Animal quarantine services | Agriculture, Forestry, Fisheries |
| 32. | Cosmetic surgery services | Culture, Society and Health |
| 33. | Calibration, testing, and verification services for measuring instruments | Technology, Land |
| 34. | Art performance, fashion shows, beauty contests, and modelling services | Culture, Society and Health |
| 35. | IT infrastructure construction and software development for land information systems | Technology, Land |
| 36. | Land database construction services | Technology, Land |
| 37. | Printing and minting money | Finance, Accounting, Commerce |
| 38. | Archiving services | Finance, Accounting, Commerce |
38 conditional business lines will be abolished, meaning that businesses operating in these sectors will no longer be required to meet certain requirements as a prerequisite for operation. It is important to note that although the amended Law on Investment is scheduled to take effect from March 2026, the revised List of Conditional Business Lines will only apply from 1 July 2026. This transitional period is intended to allow competent authorities to issue detailed implementing guidance and to give businesses sufficient time to prepare for the new regulatory framework.
The reduction in the number of conditional business lines is not merely a technical legal adjustment, but it has tangible implications for the speed and ease of market entry and business expansion in Vietnam. Sectors that were previously subject to strict licensing requirements are expected to see increased activity and new market entrants. By way of example, data centre services, employment services, and human-resources-related businesses are among the areas where the foreign-owned companies may now enter the market more readily, provided that they comply with applicable technical and professional standards during actual operations. This regulatory shift creates additional room for innovation and growth in service sectors that were previously difficult for smaller enterprises to access.
At the same time, while lower entry barriers are likely to intensify competition, they also offer Vietnam companies a more level playing field, enabling them to participate in markets that were formerly dominated by larger entities.
Ready to seize new opportunities in Vietnam?
With the abolition of 38 conditional business lines and revisions to 20 others, the regulatory landscape is changing fast. From July 2026, market entry will be easier than ever – but preparation is key. You can also refer to the full Conditional & restricted business sectors for foreign investors in Vietnam (2026) here.
Partner with Vieter Vietnam today to navigate these reforms confidently. Our experts will help you update your business strategy, ensure compliance, and unlock growth in newly liberalised sectors.
Contact us now to discuss how these changes can benefit your business.
Rizwan Khan – Managing Partner – r.khan@Vieter.com
Thao Nguyen – Senior Manager – Licensing and Corporate Secretarial – thao.nguyen@Vieter.com
Cuong Doan – Associate – Licensing and Corporate Secretarial – cuong.doan@Vieter.com