RESOLUTION NO. 66.17/2026/NQ-CP: A MAJOR CUT TO CONDITIONAL BUSINESS LINES

1. Issuance and Background

On 15 May 2026, the Government issued Resolution No. 66.17/2026/NQ-CP, providing for the reduction and amendment of conditional business lines listed in Appendix IV of the 2025 Investment Law. It forms part of a broader series of administrative-reform resolutions (alongside Resolutions 66.16/2026/NQ-CP and 66.13/2026/NQ-CP) aimed at cutting business conditions and shifting regulatory oversight from pre-inspection to post-inspection.

2. Key Changes Compared to Prior Regulations

Under the previous framework — Appendix IV of the 2025 Investment Law, which listed 198 conditional business lines — Resolution 66.17/2026/NQ-CP reduces the number to 142, effectively abolishing or amending 56 business lines. The cuts focus on business lines where the existing conditions were assessed as:

• No longer genuinely necessary for state management purposes;
• Overlapping with other specialized legal regulations;
• Suitable for conversion from a pre-licensing (ex-ante) mechanism to a post-inspection (ex-post) monitoring mechanism.

This is regarded as one of the largest-scale reforms of business investment conditions in recent years, with direct implications for market entry procedures across the affected sectors.

3. Amended or Superseded Legal Instruments

Resolution 66.17/2026/NQ-CP directly amends and reduces the content of Appendix IV — the List of Conditional Business Lines — issued together with the 2025 Investment Law. Sector-specific legal instruments (decrees and circulars detailing licensing conditions for the affected business lines) will also need to be reviewed and adjusted accordingly to ensure consistency during implementation.

4. Effective Date and Transitional Guidance

The Resolution takes effect from 1 July 2026 through 28 February 2027, unless superseded earlier by another legal instrument issued and taking effect within that period — a transitional mechanism similar to that applied under Resolution 66.16/2026/NQ-CP. This reflects a “bridging” legislative approach: the Resolution applies on an interim basis pending the issuance of formal implementing decrees or circulars that will permanently codify the reduction. Businesses and regulators should continue monitoring for further implementing or amending instruments during this transitional window.

5. Practical Notes for Businesses and Regulated Entities

• Businesses operating in sectors where conditions have been abolished should review their internal compliance procedures; the removal of a licensing condition does not equate to the elimination of all compliance obligations, as many sectors will shift to technical-standard-based, post-inspection management.
• Businesses currently applying for licenses or eligibility certificates should cross-check the updated list of conditional business lines to confirm whether a given procedure still applies, avoiding unnecessary filings.
• Since the Resolution’s effect is temporary (through 28 February 2027), businesses should proactively track subsequent replacement instruments to avoid any gap in the applicable legal basis.
• Local regulatory authorities should promptly issue implementing guidance to ensure consistent interpretation and application across jurisdictions.