The recent legislative update introduces critical adjustments regarding prohibited and conditional business sectors, directly impacting how enterprises and foreign investment participants determine their operational conditions. This article by Viet An Law will provide comprehensive information on the amended Investment Law 2026 on conditional business lines in Vietnam and the key regulations that businesses and investors must note. As part of our corporate legal advisory services, we aim to guide you through these shifts in business licensing requirements.
Information on the amended Investment Law 2026
The amended Investment Law 2026 is Law No. 24/2026/QH16, passed by the 16th National Assembly on August 24, 2026, amending and supplementing a number of articles of Investment Law No. 143/2025/QH15. The law focuses on adjusting certain regulations on prohibited business lines, conditional business sectors, and transitional provisions related to activities implemented before the law takes effect.
Law No. 24/2026/QH16 takes effect on March 1, 2027. However, some new regulations under the Investment Law 2026 in Vietnam apply earlier, starting January 1, 2027, especially the N2O business regulations in Vietnam regarding N2O gas used for human inhalation.
The promulgation of the amended Investment Law 2026 contributes to updating the legal framework on foreign investment and business, while clarifying the management scope for certain business lines that directly impact the operations of enterprises and investors.
Overview of the changes to Vietnam Investment Law 2026
Law No. 24/2026/QH16 (Amended Investment Law 2026) does not comprehensively amend the Investment Law 2025 but focuses on several specific contents. Among them, the notable regulations include:
- Adding the business of N2O gas for human inhalation to the list of prohibited business lines in the Investment Law 2026, except for certain purposes prescribed by law;
- Assigning the Government to detail the N2O business activities within the regulated scope;
- Replacing Appendix IV on the list of conditional business sectors of the Investment Law 2025 with 137 conditional business lines applicable from March 1, 2027.
Thus, the focus of the amended law is to update the scope of prohibited business lines and conditional business sectors.
N2O business as a prohibited business line in Vietnam from January 1, 2027
One of the notable contents of the amended Investment Law 2026 is the addition of regulations to Article 6 of the Investment Law 2025 regarding prohibited business lines in the Investment Law 2026.
Accordingly, Law No. 24/2026/QH16 adds Point m after Point l, Clause 1, Article 6 of the Investment Law 2025, stipulating:
“Business of N2O gas for human inhalation, except for medical, food technology, testing, scientific research purposes, and other purposes as prescribed by the Government.”
Under this regulation, the business of N2O gas for human inhalation belongs to the list of prohibited business lines. However, the prohibition does not apply to cases used for medical, food technology, testing, scientific research purposes, and other purposes as prescribed by the Government.
Consequently, the list of prohibited business lines is supplemented with one additional business line, raising the total number of prohibited business lines from 11 to 12. This N2O business regulation provision takes effect on January 1, 2027, earlier than the general effective date of the law.
Therefore, organizations and individuals with activities related to the business and use of N2O gas must note the specific scope of activities and continue to monitor government regulations to determine the cases permitted for implementation.
List of 137 conditional business lines in Vietnam 2027 starting March 1, 2027
The amended Investment Law 2026 replaces Appendix IV of Investment Law No. 143/2025/QH15 with a new Appendix issued together with Law No. 24/2026/QH16.
According to the new Appendix, from March 1, 2027, the list of conditional business lines in Vietnam 2027 consists of 137 business lines.
This list covers multiple fields of economic activity, ranging from business sectors related to security, order, finance, banking, securities, insurance, real estate business, education, health, and transportation to the fields of natural resources, environment, and specialized service business lines.
| Group of fields | Business lines |
| Security and order | Seal production; supporting tools business; security service business; pawn service business |
| Finance | Securities business; insurance; price appraisal; lottery; prize-winning games; credit rating |
| Commerce | Petroleum business; multi-level marketing; e-commerce |
| Education | Early childhood education, general education, higher education, continuing education activities; operations of foreign educational institutions |
| Transportation | Air transport; activities related to aircraft, unmanned aircraft; airports, airfields |
| Justice | Law practice; notarization; asset auction; bailiff services; asset management and liquidation |
| Health | Pharmaceutical business; medical equipment business; medical examination and treatment services and related activities |
| Natural resources and environment | Certain business activities related to water resources, minerals, and the environment |
Determining whether an activity belongs to the list of conditional business sectors is of great significance in determining market entry conditions and organizing business operations. Therefore, enterprises and foreign investment actors must cross-reference their intended business lines with the new Appendix IV when the law is applied.
Transitional provisions to note of the amended Investment Law 2026 in Vietnam
The amended Investment Law 2026 contains transitional provisions to handle activities, contracts, licenses, and dossiers that arose before the date the law takes effect.
For N2O business contracts
According to Clause 1, Article 3 of Law No. 24/2026/QH16, for contracts on the business of N2O gas for human inhalation, except for purposes excluded under the provisions of the law, which have already been entered into, the contracts shall terminate their validity from January 1, 2027.
From the date the contract terminates its validity, the parties have a maximum period of 45 days from January 1, 2027, to liquidate the contract in accordance with civil law and relevant legal regulations.
This provision holds significant importance for organizations and individuals currently conducting N2O business activities that fall under prohibited cases. The parties must proactively review signed contracts, determine the scope of activities, and execute the liquidation within the prescribed time limit.
For business lines no longer classified as conditional
For business lines that no longer belong to the list of conditional business sectors under the new Appendix IV, the law stipulates a transitional mechanism aimed at facilitating organizations and individuals to continue their operations.
Accordingly:
- Organizations and individuals are allowed to continue their investment and business activities in these business lines without having to satisfy business investment conditions from the time the new regulations of the Investment Law 2026 Vietnam are applied.
- Regarding business licensing, certificates, practicing certificates, confirmation documents, or documents permitting business investment previously issued by competent authorities, if there is a need, organizations and individuals are permitted to continue using them until the expiration of the document without having to perform procedures for issuance, adjustment, or extension.
- For dossiers requesting the issuance, adjustment, or extension of licenses, certificates, practicing certificates, confirmation documents, or documents permitting business investment that were validly received by competent authorities before March 1, 2027, but have not yet returned results, the competent authority shall notify the cessation of processing and return the dossiers to the submitting organizations and individuals.
Thus, enterprises currently operating in a business line removed from the list of conditional business sectors must review their licenses, business conditions, and ongoing dossiers to determine the appropriate handling method according to the transitional provisions.
Frequently Asked Questions
Does the list of 137 conditional business lines replace the 142 conditional business sectors under Resolution 66.17/2026/NQ-CP?
From March 1, 2027, Appendix IV issued together with Law No. 24/2026/QH16 replaces Appendix IV of Investment Law No. 143/2025/QH15 and becomes the basis for determining the list of conditional business lines in Vietnam in 2027. Accordingly, the list applicable from this point consists of 137 business lines.
Resolution No. 66.17/2026/NQ-CP holds significance during the transitional period from July 1, 2026, to the end of February 28, 2027. Read the full update on: Conditional Business Lines: Vietnam’s Official List of Viet An Law.
What should enterprises do if their current business is no longer in the new Appendix IV?
From March 1, 2027, organizations and individuals are permitted to continue business investment activities in business lines that no longer belong to the list of conditional business sectors without having to meet the business investment conditions under this list.
However, enterprises still need to review the provisions of other relevant specialized laws to determine whether their specific activities must still meet other management requirements, standards, or conditions.
Is it necessary to reissue business licensing for business lines no longer classified as conditional?
If there is a need, organizations and individuals are permitted to continue using the licenses, certificates, practicing certificates, confirmation documents, or documents permitting business investment that have been issued by competent authorities until the expiration of that document without having to perform the procedures for issuance, adjustment, or extension of business licensing.
This provision helps enterprises make suitable choices during the transitional phase, especially for licenses granted before the business line was removed from Appendix IV.
What should enterprises do to prepare when the amended Investment Law 2026 takes effect?
Enterprises should proactively review their business lines, licenses, business conditions, and ongoing dossiers to determine which activities continue to fall under conditional business, which activities are excluded from the list, and which activities are subject to the new regulations. For activities related to N2O gas, it is necessary to pay special attention to the January 1, 2027 deadline and the transitional provisions of the law.
Viet An Law is always ready to support enterprises and foreign investment participants in updating and executing legal procedures related to the Vietnam Amended Investment Law 2026 on conditional business lines, ensuring that investment and business operations are implemented in accordance with regulations.
