IMPACT OF DECREE 19/2025/ND-CP ON ATTRACTING HIGH-TECH INVESTMENT IN INDUSTRIAL PARKS AND EXPORT PROCESSING ZONES FOR FOREIGN INVESTORS

Decree 19/2025/ND-CP was issued to provide specific guidance on Article 36a of the Law on Investment 2020 regarding special investment procedures. Accordingly, this mechanism only applies to projects in fields specified in Clause 1, Article 36a, including: large-scale investment projects, high-tech projects, innovation centers, and projects of special significance to national socio-economic development. This Decree also affirms that matters not regulated herein shall still apply under Decree 31/2021/ND-CP, ensuring the consistency of the legal system. This design creates a flexible mechanism: eligible special projects benefit from shortened sequences while still complying with state management principles on investment, land, construction, and the environment. Regarding IPs and EPZs, Decree 35/2022/ND-CP stipulates the management mechanism and authority of the Management Board of Industrial Parks and Economic Zones, which acts as the "one-stop, on-site" agency. When combined with the special investment procedures of Decree 19/2025/ND-CP, the receipt, appraisal, and approval of investment dossiers for foreign investors become more synchronized and efficient.

One of the major barriers to high-tech investment in Vietnam has been the duration and complexity of the licensing process. Previously, investors had to go through multiple steps: approval of investment policies (Articles 30–36 of the Law on Investment 2020), environmental assessment (Law on Environmental Protection 2020), fire safety approval (Decree 136/2020/ND-CP), and construction permits (Law on Construction 2014, amended in 2020). Decree 19/2025/ND-CP has consolidated these processes within the same timeframe, assigning the Industrial Park Management Board to lead and coordinate, thereby reducing the "multiple-door" situation. This is particularly important for high-tech projects, as the speed of bringing products to market determines global competitiveness. The Decree also clearly defines the responsibility for coordination between ministries, sectors, and localities in project appraisal. Procedures can be conducted in parallel, helping to reduce licensing time by 25–30% compared to conventional processes. Transparency and consistency in procedures help foreign investors feel more secure when implementing large-value projects.

According to Articles 3 and 4 of Decree 35/2022/ND-CP, IPs and EPZs are areas concentrated with industrial production projects, having defined geographical boundaries, and enjoying preferential mechanisms regarding land, taxes, and customs management. When applying the special investment mechanism, Decree 19/2025/ND-CP has added "administrative synchronicity"—meaning all procedures from investment licensing, infrastructure and environmental appraisal to business registration can be performed at the Management Board without the need to transfer dossiers through provincial-level departments. This has a clearly positive impact on high-tech investors, as projects producing electronic components, semiconductors, and high-tech pharmaceuticals often require multiple processes to be handled in parallel. The "one-stop, on-site" system saves time and costs while increasing security and stability in the investment environment.

The Law on High Technology 2008 (Article 18) stipulates the conditions to be recognized as a high-tech enterprise, including requirements for the ratio of revenue from high-tech products, the ratio of spending on research and development (R&D), and the level of technical labor. Specific criteria are guided in Decision 10/2021/QD-TTg. Decree 19/2025/ND-CP does not change these criteria but creates a favorable procedural mechanism so that enterprises meeting high-tech standards can be licensed faster and gain early access to tax, land, and research support incentives as prescribed in the Law on Investment 2020 and Decree 31/2021/ND-CP. When combining special investment procedures with high-tech policies, foreign enterprises can implement R&D projects and innovation centers within IPs without being hindered by prolonged administrative stages. This approach helps Vietnam increase its competitiveness with regional countries such as Thailand, Malaysia, and Singapore in attracting global high-tech production chains.

Decree 19/2025/ND-CP provides a predictable legal framework, helping foreign investors more clearly calculate compliance time and costs. Clearly defining the scope, conditions, dossiers, and handling authority minimizes overlap between agencies. Furthermore, the coordination between Decree 19/2025/ND-CP and the Law on Investment 2020 (Articles 30–36) creates a seamless chain of procedures: from approval of investment policies, issuance of Investment Registration Certificates, to post-licensing procedures. Investors can predict progress and plan capital mobilization, machinery import, and foreign expert recruitment (according to Decree 219/2025/ND-CP) more accurately. For high-tech projects, this predictability helps reduce financial risks and increases attractiveness during negotiations with global partners.

According to Article 15 of the Law on Investment 2020, projects are entitled to investment incentives if they belong to encouraged sectors or are implemented in encouraged geographical areas. Specifically, Decree 31/2021/ND-CP stipulates forms of incentives: corporate income tax exemptions and reductions, import duty exemptions, land rent exemptions and reductions, and infrastructure support. Decree 19/2025/ND-CP does not introduce new incentives but helps shorten the roadmap to realizing incentives, meaning investors can quickly complete procedures to enjoy incentives early. In the industrial park environment, where investment capital is large and project lifecycles are long, early enjoyment of incentives is a decisive factor for financial efficiency.

According to Article 30 of Decree 35/2022/ND-CP, export processing enterprises enjoy a separate customs mechanism, acting as non-tariff zones and must comply with goods import-export management. When applied in EPZs, Decree 19/2025/ND-CP allows for the integration of investment, customs, and construction licensing procedures in a single process. Consequently, high-tech projects such as those producing chips, electronic components, and medical equipment can import production lines, install, and conduct trial runs faster, avoiding the situation of "being eligible for investment but not yet eligible for export processing status." This impact helps reduce storage costs and equipment depreciation, accelerating the factory’s commercial operation.

IPs and EPZs under Decree 35/2022/ND-CP are planned with synchronous infrastructure, including wastewater treatment systems, transportation, electricity, and worker housing. However, previously, many high-tech projects were delayed due to separate environmental and construction approval processes. Decree 19/2025/ND-CP allows for the integration of these appraisal stages within the same investment dossier, significantly shortening preparation time. This is an important improvement because high-tech projects often require strict environmental and technical standards (clean rooms, sterile air systems, ultrapure water treatment). Grouping appraisal stages into a single focal point helps investors easily meet both domestic requirements and international standards simultaneously.

Overall, Decree 19/2025/ND-CP helps reduce legal compliance costs, accelerate licensing speed, and encourage foreign investors to implement R&D projects in Vietnam. This special mechanism aligns with the national strategy on high-tech industry development until 2030, prioritizing electronics, semiconductors, renewable energy, and biopharmaceuticals. When combined with the Law on High Technology 2008 and Decision 10/2021/QD-TTg, the current legal framework enables Vietnam to shift from attracting investment by quantity to quality—focusing not only on capital scale but also on technology spillover, knowledge transfer, and high-quality human resource development. The coordination between the State – Management Boards – and Enterprises helps form a "smart investment environment," elevating the position of Vietnamese industrial parks in the global supply chain.

Decree 19/2025/ND-CP is an important completion of Vietnam's investment law in the period of deep integration. Although it does not create new financial incentives, this Decree restructures the investment process, helping to shorten time, reduce administrative costs, and enhance transparency and predictability for foreign investors. When operating alongside the Law on Investment 2020, Decree 31/2021/ND-CP, Decree 239/2025/ND-CP, Decree 35/2022/ND-CP, the Law on High Technology 2008, and Decision 10/2021/QD-TTg, Decree 19/2025/ND-CP plays a key role in the chain of policies to attract high-tech investment into industrial parks and export processing zones. From a practical perspective, this special investment mechanism is not only a procedural reform but also a statement of Vietnam's institutional capacity: ready to welcome and accompany high-tech investors in the process of new industrial transformation. This confirms that Vietnam is entering a development stage based on knowledge, innovation, and technology—a sustainable foundation for long-term growth.

References:

[1] Ministry of Justice (MOJ) (Feb 24, 2025). "Detailed regulations of the Law on Investment on special investment procedures", New Policy Documents section, last accessed Oct 10, 2025, https://www.moj.gov.vn/qt/tintuc/Pages/van-ban-chinh-sach-moi.aspx?ItemID=5006

[2] Vietnam Lawyer Online Newspaper (LSVN) (Feb 24, 2025). "New regulations on special investment procedures", last accessed Oct 10, 2025, https://lsvn.vn/quy-dinh-moi-ve-thu-tuc-dau-tu-dac-biet-a153666.html

 

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