Comprehensive Service for Changing Outward Investment Projects in Vietnam

The enactment of the Law on Investment 2025 has marked a major turning point in administrative procedures by officially abolishing business licenses for 38 industries from July 1, 2026. Although the license barrier has been removed, enterprises wishing to change project contents must still strictly comply with new management mechanisms on reporting, foreign exchange transactions, and tax obligations. To help clients remove confusion during the legal transition period and save maximum time, we provide a comprehensive service for changing outward investment projects in Vietnam – a comprehensive legal solution, ensuring every international step of yours is always solid and lawful. During this process, seeking investment legal consulting is highly recommended to easily navigate the complexities.

Cases requiring procedures to adjust offshore investment

According to Clause 1, Article 23 of Decree 103/2026/ND-CP, investors must carry out procedures to adjust outward investment registration certificate in the following cases:

Cases requiring procedures to adjust offshore investment

• Changing the Vietnamese investor;
• Changing the investment form;
• Increasing capital for outward investment; changing investment capital sources, investment capital forms;
• Changing the location of investment activities for investment projects requiring an investment location;
• Changing the main objectives of investment activities abroad;
• Using profits from investment abroad to increase investment capital.

However, in case of changing contents other than the above provisions, investors must update on the National Investment Information System.

In case the National Investment Information System has an error and cannot update the changed information, the investor shall send a written request to confirm the changed contents to the Foreign Investment Agency, Ministry of Finance to confirm the changed contents.

Procedures to modify outward investment project in Vietnam

Forms of making investments

Pursuant to Clause 1, Article 39 of the Law on Investment 2025, investors carry out outward investment activities in the following forms:

• Establishing economic organizations in accordance with the law of the investment-receiving country;
• Investing in the form of a contract abroad;
• Contributing capital, buying shares, buying capital contributions of economic organizations abroad to participate in managing such economic organizations;
• Buying and selling securities, other valuable papers or investing through securities investment funds, other intermediary financial institutions abroad;
• Other investment forms in accordance with the law of the investment-receiving country.

Procedures to change outward investment certificate on the National Information System

Pursuant to Article 26 of Decree 103/2026/ND-CP, the sequence of issuing and adjusting the outward investment registration certificate online on the National Investment Information System is carried out as follows:

Procedures to modify outward investment project

Sequence of updating outward investment project information

• Within 01 month from the time the outward investment project has changed contents that are not subject to adjusting the outward investment registration certificate or the project is not subject to issuing an outward investment registration certificate, the investor must update the changed contents on the National Investment Information System.
• In case the National Investment Information System has an error and cannot update the changed information, if necessary, the investor shall send a written request to confirm the changed information, along with relevant documents to the Foreign Investment Agency, Ministry of Finance to confirm the changed contents.
• The written confirmation of the changed contents is sent to the investor within 03 working days from the date of receiving the investor’s written request.

For the contents recorded on the outward investment registration certificate that have been updated and changed by the investor according to the above provisions, the Ministry of Finance shall record such contents in the adjusted outward investment registration certificate when the investor carries out procedures to adjust outward investment registration certificate.

Project group not requiring certificate adjustment (Only foreign exchange transaction registration)

Pursuant to Clause 3, Article 42 of the Law on Investment 2025, if your project falls into one of the following cases, clients do not have to carry out procedures to change outward investment certificate, but only need to carry out procedures for foreign exchange transaction registration as prescribed:

• Projects with a capital level smaller than the level prescribed by the Government and not belonging to conditional investment lines.
• Projects associated with national defense and security under agreements between the Government of Vietnam and other countries.
• Projects of state-owned corporations, general companies, or other economic organizations (under specific regulations of the Government).

Project group for making adjustments at the Ministry of Finance

Pursuant to Clause 1, Article 42 of the Law on Investment 2025, for normal non-exempt projects (projects reaching the capital level prescribed by the Government or belonging to conditional industries):

• Receiving and processing agency: Ministry of Finance (or organizations under the Ministry of Finance if delegated).
• Procedures: Investors submit dossiers requesting an adjustment of the outward investment registration certificate directly at the Ministry of Finance.

Large-scale or special mechanism project group (Requiring Prime Minister’s approval)

Pursuant to Clause 2, Article 42 of the Law on Investment 2025, for projects with a large capital scale or proposing to apply special support policies and mechanisms:

• Step 1: Submit to the Prime Minister: The Ministry of Finance will report to the Prime Minister to consider and approve the contents of project adjustments.
• Step 2: Adjust the Certificate: Only after the Prime Minister’s approval, the Ministry of Finance will proceed with the procedures to adjust the outward investment registration certificate for the investor.

Important notes on transitional provisions of the Law on Investment 2025

According to Article 52 of the Law on Investment 2025, investors do not have to redo procedures for approval or adjustment of investment guidelines for projects:

• Already decided or approved for investment guidelines before March 1, 2026
• Already legally implemented before the effective date of the Law on Investment 2025
• Already winning land use right bidding or auctions
• Already granted Investment Licenses, Investment Certificates, or Investment Registration Certificates

Only when the investor has a demand for adjustment, or the adjusted content is subject to applying for guidelines under the Law on Investment 2025, will new procedures arise.

Important notes on transitional regulations in 2026 when using an offshore investment adjustment service

The year 2026 marks the phase of comprehensive application of new regulations. To ensure the legality and project progress, investors need to pay special attention to the following transitional issues:

• Processing pending dossiers: Project adjustment dossiers submitted before the effective date of the Law on Investment 2025 but not yet licensed will be reviewed and processed according to transitional clauses, requiring investors to possibly supplement explanatory documents to meet new standards.
• Reviewing investment conditions: Projects belonging to conditional outward investment sectors need to be fully re-evaluated to ensure they meet the latest international standards and commitments updated in the Law on Investment 2025.
• Updating reporting regimes: The process of changing projects in this period must be accompanied by strict compliance with the regime of reporting outward investment activities on the National Information System under the new management mechanism.

Some related questions

Does the current adjustment dossier submission process compulsorily require submitting hard copies?

According to Decree 103/2026/ND-CP, the process has been fully digitized to reduce administrative procedures. Investors (or authorized units) only need to declare information and upload electronic documents signed with public digital signatures onto the National Investment Information System. Hard copies are not required unless the System encounters insurmountable technical incidents or there is a special cross-checking request from functional agencies. To safely navigate this digital transformation, utilizing our comprehensive service for changing outward investment projects in Vietnam is highly recommended.

For minor changes such as changing the project name or changing the head office address of the investor in Vietnam, what is the processing procedure?

For administrative change contents not falling into the 6 cases prescribed in Article 23 of Decree 103/2026/ND-CP, investors do not need to carry out procedures to apply for an adjusted Certificate. Instead, enterprises only need to log into the National Investment Information System to directly update new information. Utilizing an offshore investment adjustment service can support reviewing and performing this update operation to ensure enterprise data is always synchronized with management agencies.

What do investors need to prepare to meet conditions to adjust offshore investment to increase outward investment capital in 2026?

Besides legal dossiers, investors need to note the following 3 conditions:

• Financial confirmation: A document from the tax authority confirming the fulfillment of tax obligations up to the time of adjustment.
• Foreign currency source: Having a written commitment to self-balance foreign currency sources or a written approval from a lending credit institution or bank for investment capital.
• Reporting compliance: Ensuring the project has fully implemented periodic reporting regimes on the National Investment Information System from the start of implementation to the present.

Comprehensive Service for Changing Outward Investment Projects in Vietnam – Viet An Law Firm

To help enterprises avoid legal risks and save maximum time during the transition phase to the new law, Viet An Law Firm will help clients:

• Save maximum time: A team of experts deeply understanding the Law on Investment 2025 processes dossiers quickly, avoiding the need to travel and supplement multiple times.
• Protect legal capital flows: Ensuring 100% of money transferred abroad and profits brought back are legalized through standard foreign exchange registration steps.
• Absolute confidentiality: All information regarding the project’s business and financial strategies is strictly kept confidential.

When choosing Viet An Law Firm, enterprises will be comprehensively supported from strategic consulting to actual completion of procedures:

• Accurate project evaluation and classification: Based on capital scale and investment field, our experts will accurately advise whether clients’ projects need to carry out procedures for certificate adjustment or only need to register foreign exchange transactions.
• Drafting multilingual legal dossiers: Supporting drafting internal minutes, resolutions, explanatory documents, and preparing forms under the latest detailed regulations of the Government.
• Comprehensive authorized representation: Representing enterprises to work directly with the Ministry of Finance, the State Bank, and relevant departments and agencies to submit dossiers, closely follow the progress, and receive results.
• Post-adjustment capital flow management consulting: Accompanying enterprises in reporting to tax authorities and updating the National Information System, ensuring all inward/outward cash flows are legal and transparent.

Above is Viet An Law Firm’s advice on our full-package services. If clients have any related questions or a need for investment legal consulting, please contact Viet An Law Firm for the best support!