The Amended Investment Law 2026 is a new document passed by the National Assembly to amend and supplement a number of provisions of the Investment Law No. 143/2025/QH15, notably the addition of a business line banned from investment and business activities relating to N2O gas and the replacement of the entire Appendix IV on the List of conditional business lines. These changes directly affect the determination of market entry conditions and the organization of operations of enterprises and investors, including those carrying out foreign investment projects. Therefore, updating the new points of the Amended Investment Law 2026 in Vietnam is necessary to proactively review and ensure compliance with legal regulations during the investment and business process.
New points of the Amended Investment Law 2026 in Vietnam
On August 24, 2026, the 16th National Assembly passed Law No. 24/2026/QH16 amending and supplementing a number of articles of the Investment Law. The Law takes effect from March 1, 2027, and a number of provisions take effect earlier, from January 1, 2027.
The Law was issued on the basis of the Investment Law No. 143/2025/QH15 and focuses on amending a number of contents relating to prohibited business lines in Vietnam and conditional business lines.
The changes to Vietnam Investment Law 2026 include:
- Adding the N2O gas business to the list of business lines banned from investment and business activities;
- Adding a provision assigning the Government to detail the N2O gas business line;
- Replacing Appendix IV on the List of conditional business lines;
- Transitional provisions for a number of business lines and activities carried out before the effective date of the Law.
The Amended Investment Law 2026 adds the N2O gas business to the list of prohibited business lines in Vietnam
One of the most notable contents of Law No. 24/2026/QH16 is the amendment and supplementation of Article 6 of the Investment Law 2025.
Accordingly, the Law adds point m after point l of Clause 1, Article 6 of the Investment Law 2025, providing for one more business line banned from investment and business activities. Specifically:
“Trading in N2O gas for human use by inhalation, except for medical purposes, food technology, testing, scientific research and other purposes as prescribed by the Government.”
Thus, the business of N2O gas for human use by inhalation is placed in the group of business lines banned from investment and business activities. Accordingly, the list is supplemented with 01 business line, raising the total number of banned business lines from 11 to 12.
However, this provision does not apply absolutely to every activity relating to N2O gas. The Law identifies a number of exceptions, including:
- Medical purposes;
- Food technology purposes;
- Testing purposes;
- Scientific research purposes;
- Other purposes as prescribed by the Government.
The specific stipulation of exceptions aims to distinguish the business of N2O gas for human use by inhalation from the use of N2O gas for professional, technical and scientific purposes permitted by law.
The Government is assigned to provide detailed rules on the N2O gas business in Vietnam
In addition to adding point m, Clause 1, Article 6, the Amended Investment Law 2026 also adds Clause 2a after Clause 2, Article 6 of the Investment Law 2025 and establishes an open provision: “The Government shall detail point m, Clause 1 of this Article.”
This provision is significant in specifically determining the scope and management method for N2O gas business activities that fall within the cases excluded from the ban. It is the basis for the N2O gas business regulations in Vietnam will apply in practice.
Thus, for organizations and individuals conducting or planning to conduct activities relating to N2O gas, in addition to studying the Amended Investment Law 2026 directly, it is necessary to keep monitoring the Government’s detailed documents in order to accurately determine which activities are permitted.
Only 137 conditional business sectors remain in Vietnam from March 1, 2027
The list of conditional business lines through amendments and supplements
| Document name | Application period | List of conditional business lines |
| Investment Law 2020, amended in 2022 and 2024 | Before March 1, 2026 | 236 |
| Investment Law 2025 | From March 1, 2026 to the end of June 30, 2026 | 198 |
| Resolution No. 66.17/2026/NQ-CP | From July 1, 2026 to the end of February 28, 2027 | 142 |
| Amended Investment Law 2026 | From March 1, 2027 | 137 |
From March 1, 2027, only 137 conditional business lines remain
Another important content of the Amended Investment Law 2026 is the replacement of Appendix IV on the List of conditional business lines of the Investment Law No. 143/2025/QH15.
Pursuant to Article 1 of Law No. 24/2026/QH16, Appendix IV is replaced by the Appendix issued together with Law No. 24/2026/QH16. Compared with Resolution No. 66.17/2026/NQ-CP, from March 1, 2027, the list of conditional business lines in Vietnam from 2027 applies decreases from 142 to 137. Some specific changes are as follows:
| Content | Resolution No. 66.17/2026/NQ-CP | Law No. 24/2026/QH16 |
| Education activities are consolidated | Divided into business lines: Preschool education activities; General education activities; Higher education activities; Continuing education activities. | Consolidated into one business line: “Preschool education, general education, higher education and continuing education activities”. |
| Unmanned aircraft activities are restructured | Separated: import, temporary import for re-export, temporary export for re-import; research and manufacture, testing, repair, maintenance… | Consolidated into one broader business line: “Trading in, importing, temporarily importing for re-export, temporarily exporting for re-import, testing, repairing and maintaining unmanned aircraft…” |
| The customs-related business line has a narrowed title | Trading in locations for customs clearance, gathering, inspection and customs supervision | Trading in locations for gathering, inspection and customs supervision |
| The pension fund management activity is rephrased | Trading in voluntary pension fund management services | Trading in supplementary retirement insurance fund management services |
Note the transitional provisions in Vietnam for business lines no longer subject to conditions
The Amended Investment Law 2026 also sets out transitional provisions for business lines that are no longer conditional, as follows:
- Organizations and individuals may carry out investment and business activities in these business lines without having to satisfy investment and business conditions;
- Where they wish to do so, organizations and individuals may continue to use the licenses, certificates, practising certificates, written confirmations or other written approvals for investment and business already granted by competent state agencies until the expiry of such documents, without carrying out procedures for issuance, adjustment or extension;
- Where a dossier requesting the issuance, adjustment or extension of licenses, certificates, practising certificates, written confirmations or other written approvals for investment and business was validly received by a competent state agency before March 1, 2027 but no result has been returned, the competent state agency shall notify the suspension of processing and return the dossier to the individual or organization that submitted it.
- Where a dossier was validly received by a competent state agency before March 1, 2027 but no result has been returned, the competent agency shall notify the suspension of processing and return the dossier to the organization or individual that submitted it.
This provision aims to ensure that dossiers are handled in line with the change in the list of conditional business lines, including those involved in foreign investment projects.
Transitional provisions for N2O gas business contracts in Vietnam
One of the notable transitional contents is the handling of N2O gas business contracts that have already been entered into.
Pursuant to Clause 1, Article 3 of Law No. 24/2026/QH16, for contracts on the business of N2O gas for human use by inhalation, except for the purposes excluded under the Law, that have been entered into, such contracts terminate from January 1, 2027.
Within a maximum of 45 days from January 1, 2027, the contracting parties shall liquidate the contract in accordance with civil law and other relevant legal regulations.
Organizations and individuals with business activities relating to N2O gas should pay special attention to this provision in order to proactively review signed contracts and prepare appropriate handling plans.
What should enterprises note about regulatory licenses & approvals in Vietnam when the Amended Investment Law 2026 is issued?
Although Law No. 24/2026/QH16 does not comprehensively amend the Investment Law 2025, the contents relating to the list of conditional business lines may directly affect the operations of enterprises, including FDI licensing procedures.
Therefore, enterprises should proactively:
- Review business lines: enterprises need to check whether the business lines in which they are operating fall under the new Appendix IV list of conditional business sectors.
- Review licenses and business conditions: for business lines that remain on the conditional list, enterprises must continue to fully satisfy the conditions under specialized laws and maintain valid regulatory licenses & approvals.
- Review business lines removed from the list: if the business line being operated is no longer in the new Appendix IV, the enterprise needs to determine the time and scope of exemption from investment and business conditions.
- Review dossiers in progress: enterprises with dossiers applying for the issuance, adjustment or extension of licenses relating to business lines removed from the list, including FDI licensing dossiers, should note the dossier-return rule under the transitional mechanism.
- Review contracts relating to N2O gas: for N2O gas business activities falling within the banned cases, enterprises should pay special attention to the date of January 1, 2027 and the 45-day time limit for liquidating contracts as prescribed.
Frequently asked questions about the Amended Investment Law 2026
When does the Amended Investment Law 2026 take effect?
Law No. 24/2026/QH16 generally takes effect from March 1, 2027, which is also when the list of conditional business lines in Vietnam from 2027 applies takes effect. However, the provisions on the N2O gas business apply from January 1, 2027.
Is the N2O gas business banned from 2027?
Under the Amended Investment Law 2026, the business of N2O gas for human use by inhalation is added to the list of business lines banned from investment and business activities, but purposes such as medical, food technology, testing, scientific research and other purposes as prescribed by the Government are excluded. The N2O gas business regulations in Vietnam applies take effect from January 1, 2027.
Do business lines removed from Appendix IV still have to satisfy business conditions?
Under the transitional provisions, organizations and individuals may carry out investment and business activities in the business lines removed from Appendix IV without having to satisfy investment and business conditions. However, they should continue to review other specialized regulations relating to the specific activity
Do licenses already granted for business lines that are no longer conditional have to be re-applied for?
Where they wish to do so, organizations and individuals may continue to use the licenses, certificates, practising certificates, written confirmations or written approvals for investment and business already granted until the expiry of such documents, without carrying out procedures for issuance, adjustment or extension.
The new points of the Amended Investment Law 2026 in Vietnam focus on updating the business lines banned from investment and business activities and the list of conditional business lines. The changes to Vietnam Investment Law 2026 require enterprises and investors to proactively review their business activities to ensure compliance with the new regulations. Viet An Law Firm is ready to support enterprises and investors in advising on and carrying out related legal procedures, ensuring that investment and business activities are implemented in accordance with regulations and effectively.
