Official Letter No. 2519/BTC-PC: Temporary Continued Application of Investment Procedures under the 2020 Law on Investment
On 11 December 2025, the National Assembly passed the Law on Investment No. 143/2025/QH15 (“Investment Law 2025”), which took effect on 1 March 2026 and replaces the Law on Investment No. 61/2020/QH14. This marks a significant update to the legal framework governing investment activities in Vietnam.
However, as the implementing regulations guiding the Investment Law 2025 have not yet been fully issued to facilitate the application of new investment procedures, on 4 March 2026, the Ministry of Finance issued Official Letter No. 2519/BTC-PC to provide guidance on the implementation of the Investment Law 2025, ensuring continuity in state administration and the handling of administrative procedures in the investment sector without disruption.
Accordingly, the provisions under Decree No. 31/2021/ND-CP guiding the Law on Investment and Decree No. 19/2025/ND-CP on special investment procedures will continue to apply during the transitional period until the official implementing regulations of the Investment Law 2025 are promulgated. In addition, existing guiding circulars (including Circular No. 03/2021/TT-BKHĐT) will remain in effect.
To ensure continuity in the receipt and processing of investment dossiers, the Ministry of Finance requests competent authorities, as well as enterprises and investors, to continue applying the procedures and processes under the aforementioned existing regulations. This approach helps minimize legal gaps and avoid practical difficulties during implementation.
Official Letter 2519/BTC-PC reflects a clear “soft transition” approach adopted by the regulatory authorities in the course of reforming the investment legal framework. In this context, enterprises and investors should take note of the following key points:
- Continue applying the current investment regulations under Decree No. 31/2021/ND-CP, Decree No. 19/2025/ND-CP, and relevant circulars until the implementing regulations for the Investment Law 2025 are issued;
- Proactively monitor forthcoming implementing regulations of the Investment Law 2025 to promptly update and adjust investment activities, thereby mitigating compliance risks once the new rules take effect;
Assess the priority and timing of planned investment projects to determine whether to proceed with investment registration under the current framework or defer until the new implementing regulations on investment procedures are issued.
