LAW NO. 24/2026/QH16: VIETNAM OFFICIALLY CUTS 62 CONDITIONAL BUSINESS LINES, EFFECTIVE MARCH 1, 2027

After more than half a year of public consultation since the Ministry of Finance released its second draft, on August 24, 2026 the 16th National Assembly officially passed Law No. 24/2026/QH16 amending and supplementing a number of articles of the Investment Law at an extraordinary session. The Law takes effect on March 1, 2027, and is the largest-scale reduction of investment and business conditions in Vietnam in many years, directly affecting nearly every enterprise and investor currently operating in the country.

1. A major reduction in the list of conditional investment and business lines

1.1. 62 lines eliminated, 14 amended

The most significant change under Law No. 24/2026/QH16 is the elimination of 62 business lines and the amendment of 14 others in the List of Conditional Investment and Business Lines, corresponding to roughly 786 specific business conditions and 232 administrative procedures abolished or simplified^[1]. The number of conditional business lines has accordingly fallen from around 198 to 137.

1.2. Sectors removed from the list

Sectors removed include: paintball equipment trading; specialized ambulance equipment and vehicles; certain asset auction services; several pharmaceutical and mineral activities; and outsourced accounting services. These are activities the Government assessed as manageable through technical standards, post-inspection mechanisms, or other specialized regulatory tools, rather than investment conditions.

1.3. Sectors that remain conditional for public-safety reasons

Sectors directly affecting national security, finance, banking, securities, insurance, energy, transportation, real estate, construction, education, healthcare, agriculture, environmental protection, and information technology remain within the 137-line conditional list, to safeguard state management requirements and public safety.

2. New digital-economy sectors added, and a ban on N₂O gas for inhalation

2.1. New conditional sectors tied to the digital economy

The Law adds several new conditional business lines to keep pace with the digital economy: services related to encrypted assets; data platform services; intermediary products and services; data analysis and aggregation services; and personal data processing services - fields closely linked to the AI and semiconductor incentive mechanism under Decree 96/2026/NĐ-CP. Visa-processing assistance services have also, for the first time, been added to the conditional list^[2].

2.2. A complete ban on N₂O gas for human inhalation

The Law bans trading nitrous oxide (N₂O) gas for human inhalation, except for medical purposes, food technology, testing, scientific research, and other purposes prescribed by the Government^[3]. This ban takes effect earlier than the rest of the Law, from January 1, 2027; existing N₂O trading contracts terminate on that date, with a 45-day period for enterprises to settle related obligations.

3. Transitional provisions and implementation roadmap

3.1. For business lines just removed from the conditional list

Enterprises holding existing licenses or eligibility certificates may continue to use them until expiry, without having to reapply or adjust under the new regulations^[4]. For applications for the issuance, amendment, or extension of licenses in respect of business lines that have been newly abolished, which were validly submitted prior to the effective date of the Law but for which no result has been issued, the competent state authority shall notify the suspension of processing and return the application files^[5].

3.2. For business lines with amended or newly added conditions

Enterprises should refer to the implementing decree, expected before March 1, 2027, to determine the exact conditions that will apply. The more than six-month gap between passage and the effective date (except for the N₂O provisions) gives both state agencies and enterprises time to review and adjust their operations to the new list.

4. What should investors and enterprises prepare?

With Law No. 24/2026/QH16 now passed and set to take effect from March 1, 2027, investors and enterprises should:

4.1. Review all current and planned business lines against the new list of 137 conditional investment and business lines to identify which have been removed, amended, or newly added;

4.2. For business lines just removed from the conditional list, update internal legal records but there is no need to rush a new licence application ahead of the effective date;

4.3. If operating in encrypted assets, data platforms, personal data processing, or visa-processing assistance services, start reviewing the new conditions that will apply from March 1, 2027;

4.4. If trading N₂O gas, review all existing contracts now to plan for termination and settlement of remaining obligations before January 1, 2027;

4.5. Closely monitor the implementing decree for Law No. 24/2026/QH16, expected before the Law's effective date, for the detailed conditions applicable to each specific business line;

4.6. Consult legal advisors to assess the specific impact of these changes on current and planned business lines, particularly during the transition period before March 1, 2027.

The above summarizes the most important new provisions of Law No. 24/2026/QH16 amending and supplementing the Investment Law - the largest-scale reform of investment and business conditions in Vietnam in many years. For advice on investment and business conditions, related legal procedures, or an assessment of how Law No. 24/2026/QH16 affects your specific operations, Lexsol is always ready to accompany you and provide suitable legal solutions.

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