Latest Procedures for Investment Project Adjustment under the Law on Investment 2025

I. Cases for Investment Project Adjustment

1. Investment Project Adjustment Rights: According to Article 33 of the Law on Investment 2025 regarding Investment Project Adjustment, during the implementation of an investment project, investors have the following rights:

- Adjust objectives in accordance with the provisions of the law;

- Transfer part or all of the investment project in accordance with the law;

- Merge projects or split/separate a project into multiple projects; consolidate, merge, or convert the type of economic organization; or use land use rights and assets attached to land within the investment project to contribute capital for enterprise establishment, business cooperation, or other contents in accordance with the law.

2. Investors shall carry out procedures to adjust the Investment Registration Certificate (IRC) if the project adjustment changes the main contents of the project specified in the IRC.

3. Investors with projects that have received Investment Policy Approval must undergo procedures for Approval of Investment Policy Adjustment in the following cases:

a) Changing or adding contents or objectives subject to investment policy approval as specified in the investment policy approval document;

b) Changing the scale of land use area as prescribed by the Government or changing the investment location;

c) Extending the project implementation schedule by more than 24 months as prescribed in Clause 4 of this Article;

d) Adjusting the project’s operational duration;

e) Changing the investor of a project that received investment policy approval concurrently with investor approval before the project operation, or changing conditions applicable to the investor (if any).

4. For projects with investment policy approval, investors shall not extend the implementation schedule by more than 24 months compared to the schedule specified in the initial investment policy approval, except in the following cases:

a) To remedy consequences in events of force majeure as prescribed by civil and land laws;

b) Adjusting the schedule due to delays in land allocation, land lease, or permission for change of land use purpose by the State;

c) Adjusting the schedule at the request of state management agencies or due to delays in administrative procedures by state agencies;

d) Adjusting the project due to changes in planning by state agencies;

e) Changing objectives specified in the investment policy approval; adding objectives subject to investment policy approval;

f) Increasing total investment capital by 20% or more, leading to a change in project scale;

g) Other cases as prescribed by the Government.

5. The state agency with the authority to approve the investment policy shall have the authority to approve the adjustment of said policy.

6. If a proposed adjustment leads to the project becoming subject to investment policy approval, the investor must fulfill the procedures for investment policy approval.

II. Procedures for Investment Project Adjustment under the Approval Jurisdiction of the Chairperson of the Provincial People's Committee

1. The investor submits 01 set of documents as prescribed in Clause 1, Article 52 of Decree No. 96/2026/ND-CP, along with an electronic copy, to the Investment Registration Agency.

2. Adjustment Procedure:

a) Within 02 working days of receiving a valid dossier, the Investment Registration Agency sends the dossier to relevant state agencies (as per Clause 7, Article 35 of Decree 96) for comments on the adjustment contents.

b) Within 07 working days of receipt, the consulted agencies provide comments within their scope of state management.

c) Within 14 working days of receiving a valid dossier, the Investment Registration Agency prepares an appraisal report on the adjustment contents to submit to the Chairperson of the Provincial People's Committee.

d) Within 03 working days of receiving the dossier and appraisal report, the Chairperson of the Provincial People's Committee decides on the investment policy adjustment approval.

3. Expedited Procedures for Schedule/Location Updates: For adjustments related to schedules/duration under Clause 5, Article 28 of Decree 96, or updating locations due to administrative unit restructuring:

a) The investor submits the dossier to the Investment Registration Agency.

b) Within 02 working days, the agency reports to the Chairperson of the Provincial People's Committee for a decision without needing the full process in Clause 2.

c) Within 03 working days, the Chairperson issues the approval decision.

4. Adjusting Projects before Investor Selection: For projects with approved policies where an investor has not yet been selected, the competent state agency prepares the adjustment dossier and follows the timeline specified in Clause 2.

III. Procedures for Investment Project Adjustment with an Issued IRC Not Subject to Investment Policy Adjustment Approval

1. Administrative Changes (Name, Investor Name, Schedule, Duration):

a) Dossier: Written request for adjustment and supporting documents (e.g., certificates of name change, land handover documents for schedule extensions, or administrative restructuring explanations).

b) Timeline: Within 03 working days of receiving the request and relevant documents, the Investment Registration Agency shall adjust the IRC for the investor.

2. Other Changes: For adjustments not mentioned in Clause 1, the investor submits a dossier as per Article 52 of Decree 96. Within 07 working days of receiving a valid dossier, the agency shall adjust the IRC.

IV. Conclusion

It is evident that the process for investment project adjustment under the new regulations has been clearly concretized in terms of timelines and documentation, particularly with the distinct decentralization of authority to Management Boards and local authorities. Proactively reviewing conditions regarding schedules (not exceeding 24 months) and force majeure cases will help investors avoid unnecessary legal risks when changing project details.

We hope this summary of Article 33 of the Law on Investment 2025 and related provisions in Decree No. 96/2026/ND-CP provides a comprehensive overview for our readers. If your business encounters difficulties in drafting dossiers or requires deeper consultancy on investment policy adjustment procedures, please contact our team of legal experts for timely and accurate support.

See more at:

1) Investment Procedures in Danang Hi-Tech Park 2026;

2) Procedures for Investment Policy Approval and Investment Registration Certificate (IRC) in Da Nang Hi-Tech Park 2026 (2)

3) List of Projects Attracting Investment into Da Nang City for the 2026-2030 Period

4) Projects Subject to Investment Policy Approval under the Law on Investment 2025

5) Guidelines on procedures for establishing foreign-invested enterprises in Ho Chi Minh City, Vietnam (2026)