56 conditional business lines removed under Resolution No. 66.17/2026/NQ-CP

On 15 May 2026, the Government issued Resolution No. 66.17/2026/NQ-CP (“Resolution 66.17”) on the removal and amendment of conditional business lines set out in Appendix IV to the Law on Investment 2025. Effective from 1 July 2026 to 28 February 2027, the Resolution marks a significant step in Vietnam’s ongoing reform of its investment and business regulatory framework. 

1. Removal of 56 conditional business lines 

Pursuant to Resolution 66.17, the number of conditional business lines has been reduced from 198 to 142, representing the removal of 56 conditional business lines. 

The reduction primarily covers service sectors, including: 

Finance, accounting and commerce: business services relating to tax procedures; customs brokerage services; insurance auxiliary services; commercial assessment services; temporary import for re-export of goods subject to special consumption tax; temporary import for re-export of frozen food; temporary import for re-export of used goods on the prescribed list; energy auditing services; currency printing and minting activities; and document and archive storage services. 

Culture, social affairs and healthcare: employment services; management and operation of cremation facilities; overseas study consulting services; cosmetic surgery services; and artistic performance services, fashion shows, and beauty and model competitions. 

Construction and transportation: labour outsourcing services; automobile warranty and maintenance services; construction, conversion, repair and restoration of inland waterway vessels; maritime safety assurance services; towage services; construction, conversion and repair of seagoing vessels; air navigation support services; multimodal transportation services; architectural services; construction activities carried out by foreign contractors; construction cost management consulting services; and condominium management and operation services. 

Technology and land administration: data centre services; inspection, calibration and testing services for measuring instruments and standards; information technology infrastructure development and software development for land information systems; and land database development services. 

Agriculture, forestry and fisheries: breeding and cultivation of wild fauna and flora listed under the CITES Appendices and Vietnam’s endangered, precious and rare species lists; breeding of common forest animals; import, export, re-export, transit and introduction from the sea of specimens listed under the CITES Appendices; import and export of captive-bred, artificially propagated and ranched specimens under the CITES regime; processing, trading, transportation, advertising, exhibition and storage of specimens of listed species; food business activities under the management of the Ministry of Agriculture and Rural Development; and quarantine and isolation services for animals and animal products. 

2. Shift from ex ante licensing to ex post supervision 

Pursuant to Articles 3.2 and 4.2 of Resolution 66.17, the removal of conditional business lines does not signify the relaxation of State management over these sectors. Rather, it reflects a policy shift from an ex ante licensing regime to an ex post supervisory framework. 

Accordingly, instead of requiring enterprises to satisfy licensing conditions prior to commencing operations, the competent authorities will focus on promulgating technical standards and sector-specific regulations while strengthening inspection, supervision and compliance monitoring throughout the operational lifecycle of enterprises. 

This regulatory approach is expected to facilitate market entry by shortening licensing procedures and reducing administrative burdens. However, businesses will be required to maintain continuous compliance with applicable technical standards and sector-specific regulations. As a result, legal risks will shift from the licensing stage to the operational stage. Enterprises that fail to comply with the applicable standards, technical regulations or sector-specific requirements may be subject to administrative sanctions, temporary suspension or suspension of their business operations. 

3. Recommendations for investors and enterprises 

To take full advantage of the new regulatory framework while mitigating legal risks, investors and enterprises are advised to: 

  • Review their existing or proposed business lines to determine whether they fall within the scope of the simplified regulatory regime under Resolution 66.17; 
  • Closely monitor forthcoming technical standards, technical regulations and sector-specific guidance expected to be issued by the competent authorities; and 
  • Establish and maintain robust compliance management systems to ensure ongoing regulatory compliance and preparedness for inspections and audits conducted by competent State authorities. 

The reduction of conditional business lines represents a positive development in Vietnam’s efforts to improve its investment and business environment. Nevertheless, to fully benefit from these regulatory reforms, enterprises should shift their compliance focus from obtaining pre-operation licences to maintaining continuous compliance throughout the course of their business operations. 

Submission date: 20/7/2026

Related posts

  1. Some important changes of the draft law on business investment for foreign investors
  2. Outward investment with capital under 7 billion VND to establish a company operating in non-conditional business lines
  3. Changes to the business conditions for employment services from mid-2026

Disclaimers:

This article is for general information purposes only and is not intended to provide any legal advice for any particular case. The legal provisions referenced in the content are in effect at the time of publication but may have expired at the time you read the content. We therefore advise that you always consult a professional consultant before applying any content.

For issues related to the content or intellectual property rights of the article, please email cs@apolatlegal.vn.

Apolat Legal is a law firm in Vietnam with experience and capacity to provide consulting services related to Business and Investment and contact our team of lawyers in Vietnam via email info@apolatlegal.com.



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