Decree 239: Vietnam streamlines investment procedures and encourage digital & semiconductor sectors
On 3 September 2025, the Government issued Decree No. 239/2025/ND-CP (“Decree 239”), amending Decree No. 31/2021/ND-CP guiding the implementation of the Law on Investment. Compared with previous regulations, Decree 239 represents a major policy shift aimed at addressing practical challenges and aligning investment regulations with Vietnam’s new socio-economic development strategy.
A key reform is the reduction of processing times for investment procedures. The timeline for issuing an Investment Registration Certificate has been shortened from 15 days to 10 days. Likewise, the appraisal and approval periods for investment policy decisions have been reduced to 38 days for projects under the authority of the Prime Minister and 26 days for those under the authority of provincial People’s Committees. These reforms are expected to cut administrative time, reduce costs for investors, and enhance Vietnam’s competitiveness.
Another notable change is the prioritization of digital technology and semiconductors. For the first time, the concept of a “digital technology zone” has been introduced, with a legal status equivalent to industrial zones, export processing zones. Projects in these zones will enjoy similar incentives, procedures, and management frameworks. In addition, the list of sectors eligible for investment incentives has been expanded to cover activities such as AI data centers, semiconductor chip R&D, design, manufacturing, packaging, and testing, as well as digital startups and infrastructure for digital technology zones. This marks a significant step in strengthening Vietnam’s legal foundation for digital infrastructure and the semiconductor supply chain.
Important revisions also concern projects involving land use. New regulations of Decree 239 provide that investment project terms and implementation schedules will now be calculated from the date of actual land handover, rather than from the date of investment approval. If land handover is delayed by the authorities, investors are not required to adjust their approval decision or IRC; instead, project timelines will follow the land handover record. This change is designed to prevent project delays caused by administrative bottlenecks.
Market access rules for foreign investors have also been eased. Sectors related to the production and trading of weapons, explosives, support tools, and certain military equipment have been moved from the “restricted market access list” to the “conditional market access list.” Accordingly, foreign investors may now enter these sectors subject to compliance with specific conditions and requirements.
Overall, Decree 239 represents a comprehensive improvement of Vietnam’s investment framework. By shortening appraisal timelines, linking project schedules to actual land handovers, expanding incentivized sectors—particularly in digital technology, AI, and semiconductors—and enabling conditional foreign market access in defense-related industries, the Decree is expected to reduce costs, improve legal certainty, and attract high-value investments. At the same time, investors should be aware of potential transitional risks, such as differing interpretations across localities, technical requirements for digital systems, and sector-specific compliance conditions.
