FDI Project Scale Adjustment Vietnam refers to the process of changing the registered scale of a foreign-invested investment project in Vietnam. During the project lifecycle, an investor may need to expand or reduce the project’s scale because of changes in market demand, production capacity, investment capital, land use, equipment, or business plans. For example, a foreign manufacturer may initially register a factory with a production capacity of 50,000 units per year. Later, the investor may decide to increase capacity to 100,000 units. In another case, weaker market demand may lead the investor to reduce the planned production scale. Under the current Law on Investment No. 143/2025/QH15, investors can adjust investment projects during implementation. However, some changes to project scale may also affect investment policy approval, land use, investment capital, or other registered project information. Therefore, foreign investors should review the full project before making a FDI Project Scale Adjustment Vietnam application.

I. What Is FDI Project Scale Adjustment Vietnam?

1.1 Understanding Project Scale Adjustment

FDI Project Scale Adjustment Vietnam means changing the size or scope of an investment project after the project has already been approved or registered.

Project scale can relate to different aspects depending on the type of investment. For example, a manufacturing project may define its scale through production capacity, factory size, or annual output. Meanwhile, a real estate project may focus on land area, construction area, number of units, or total floor area.

Other projects may define scale through:

• Production capacity
• Number of products or services
• Factory or office area
• Number of employees
• Number of facilities
• Annual output
• Project investment value
• Land area
• Other measurable project targets

Therefore, investors should first identify exactly which part of the project scale they want to change.

1.2 Why Do Foreign Investors Adjust Project Scale?

Foreign investors may adjust project scale for many business reasons. For example, a company may increase production capacity after receiving more orders. Similarly, an investor may reduce the scale when the original business plan is no longer suitable for market conditions.

Common reasons include:

• Expanding production capacity
• Increasing the number of production lines
• Reducing production capacity
• Expanding or reducing factory space
• Adding new facilities
• Changing the size of a real estate project
• Increasing the number of products or services
• Adjusting the project to match actual market demand

As a result, project scale adjustment can help the registered investment project better reflect the investor’s actual business plan.

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II. When Does an FDI Project Need Scale Adjustment?

2.1 Expansion of Production Capacity

Increasing production capacity is one of the most common reasons for FDI Project Scale Adjustment Vietnam.

For instance, a foreign-invested manufacturer may initially register annual production of 100,000 products. After several years, the company may receive new orders and decide to increase production to 250,000 products per year.

In this situation, the investor should compare the new production capacity with the scale recorded in the investment documents. If the proposed change affects other registered project information, the company should consider adjusting those details at the same time.

2.2 Reduction of Project Scale

An investor may also reduce the project scale.

This can happen when the company experiences lower demand, changes its business strategy, or decides to cancel part of the original investment plan.

For example, an investor may initially plan to build two factories but later decide to operate only one. The investor may then need to reduce the project scale and possibly adjust the investment capital and implementation plan.

Therefore, reducing project scale does not necessarily mean closing the entire project. The investor can review whether a partial adjustment is more suitable.

2.3 Changes in Land Area or Project Location

Land is another important factor when adjusting project scale.

A project may require a larger or smaller land area after the investor changes its business plan. However, changes in land use can involve additional requirements under investment and land regulations.

Under Decree No. 96/2026/ND-CP, certain changes in the land area of a project that has received investment policy approval can require adjustment of the investment policy approval. In particular, the regulation refers to changes in the area of land used by more than 10% or more than 30 hectares in specified cases.

Therefore, investors should review land issues carefully before applying for a project scale adjustment.

III. Project Scale and Investment Capital

3.1 How Project Scale Relates to Investment Capital

Project scale and investment capital often change together.

For example, a manufacturer that increases its production capacity may need additional machinery, factory space, employees, and working capital. As a result, the investor may also need to increase the registered investment capital.

However, an increase in capital does not always mean that the project scale will increase.

An investor may add working capital without changing production capacity. Conversely, the investor may change production capacity while keeping the total investment capital relatively stable.

Therefore, investors should assess both items separately before preparing the adjustment application.

3.2 Capital Increase That Changes Project Scale

The Law on Investment 2025 specifically recognizes a situation where an increase in total investment capital of 20% or more changes the scale of the investment project. This situation can affect the rules for adjusting the project’s implementation schedule.

This point is important for investors planning a major expansion.

For example, a project with registered capital of USD 10 million may increase its total investment capital to USD 13 million. If this increase also results in a significant change in the project scale, the investor should review the applicable adjustment requirements rather than treating the change as a simple capital amendment.

IV. FDI Project Scale Adjustment Vietnam Procedure

4.1 Step 1: Review the Current Investment Documents

Before making any adjustment, the investor should review the current investment documents.

The company should compare the actual project with information recorded in:

• Investment Registration Certificate
• Investment policy approval, if applicable
• Investor approval documents, if applicable
• Project implementation records
• Capital contribution records
• Relevant land documents

At the same time, the investor should identify every project item that will change.

This approach can prevent the company from submitting an application that only addresses the project scale while leaving other related information unchanged.

4.2 Step 2: Determine the Type of Scale Change

The investor should clearly define whether the proposed change involves:

• Increasing production capacity
• Reducing production capacity
• Increasing or reducing land area
• Expanding factory or construction area
• Adding facilities
• Changing project output
• Increasing the number of products
• Reducing project activities

After that, the investor should determine whether the change also affects capital, project objectives, location, implementation schedule, or other registered information.

4.3 Step 3: Determine Whether Investment Policy Adjustment Is Required

Not every project scale adjustment requires investment policy approval adjustment.

Under Article 51 of Decree No. 96/2026/ND-CP, investors can adjust investment projects during implementation. For projects that already received investment policy approval, the investor must follow the relevant adjustment procedure when the proposed change falls within the cases requiring adjustment under Article 33 of the Law on Investment.

For example, certain changes to approved project objectives, land area, location, project duration, or investor information can require investment policy adjustment.

Therefore, the investor should determine the legal status of the project before preparing the final dossier.

4.4 Step 4: Prepare the Adjustment Application

After identifying the required changes, the investor can prepare the relevant documents.

Depending on the project, the application may contain information about:

• Current project scale
• Proposed project scale
• Reason for the adjustment
• Current implementation progress
• Proposed implementation plan
• Investment capital
• Capital contribution schedule
• Land use
• Financial capacity
• Other related changes

The exact documents depend on the project’s status and the type of adjustment.

For this reason, investors should prepare the application based on the actual project rather than relying on a standard checklist for every FDI project.

4.5 Step 5: Submit the Application

The competent authority depends on the type and location of the investment project.

For projects subject to investment policy approval, Decree No. 96/2026/ND-CP provides different procedures depending on whether the authority is the Prime Minister or the provincial-level authority. The decree also provides procedures for adjusting projects that do not require investment policy approval adjustment.

Therefore, investors should identify the correct authority before submitting the application.

V. Important Issues When Adjusting Project Scale

5.1 Project Objectives

Project scale and project objectives can be closely connected.

For example, a company may initially register a project to manufacture one type of product. Later, the company may want to add another product line.

In this situation, the company should determine whether it is simply changing the project scale or also adding a new investment objective.

If the change affects an objective that falls under investment policy approval, the investor may need to follow an additional approval procedure.

Therefore, investors should review project objectives together with project scale.

5.2 Project Implementation Schedule

A larger project may require more time to complete.

For example, expanding a factory may require additional construction, machinery installation, environmental procedures, and recruitment.

However, investors should carefully review the rules on project implementation schedules.

Under the current investment law, a project subject to investment policy approval generally cannot extend its implementation schedule by more than 24 months compared with the original approved schedule, except for specific cases provided by law. One such case is an increase in total investment capital of 20% or more that changes the project scale.

Therefore, investors should review the project schedule whenever they plan a major scale expansion.

5.3 Land and Construction

Scale adjustment can also affect construction and land matters.

For example, expanding production may require additional factory space. As a result, the investor may need to consider whether the existing land area is sufficient.

Similarly, an increase in construction area may require the company to review construction permits and other relevant requirements.

Therefore, the investor should not treat project scale as an isolated investment issue.

5.4 Investment Incentives

Changes in project scale can also affect investment incentives.

The investor should review whether the expanded or reduced project still meets the conditions for applicable incentives.

In particular, the company should check the effect of the adjustment on:

• Corporate income tax incentives
• Import duty incentives
• Land-related incentives
• Other investment support

Investors should not assume that all additional investment automatically receives the same incentives as the original project.

VI. Accounting and Compliance After Scale Adjustment

6.1 Update Accounting Records

After the project scale changes, the company should review its accounting and financial records.

If the scale increase also increases investment capital, the company should properly record additional capital contributions and project expenses.

Similarly, if the project scale decreases, the company should review whether planned expenses, assets, and capital commitments also need adjustment.

Maintaining consistent records can make future investment and tax reporting easier.

6.2 Update Investment Reports

The company should also reflect the updated project information in future investment reports.

For example, if the registered production capacity increases from 100,000 to 200,000 units per year, future reports should use the updated project information where applicable.

At the same time, the company should ensure consistency between:

• Investment documents
• Accounting records
• Tax records
• Investment reports
• Internal business plans

This is especially important for FDI companies with large projects and multiple reporting requirements.

6.3 Monitor Further Changes

After completing a scale adjustment, the company should continue monitoring the project.

Future changes may involve:

• Investment capital
• Project objectives
• Project location
• Land area
• Production capacity
• Project duration
• Implementation schedule
• Investor information

If another major change occurs, the company should review whether another investment adjustment is necessary.

VII. Conclusion

FDI Project Scale Adjustment Vietnam allows foreign investors to update the registered size and scope of an investment project when the actual business plan changes.

Investors may increase project scale because of market growth, higher production demand, new machinery, or business expansion. On the other hand, investors may reduce the scale when market conditions change or the original investment plan becomes too large.

However, project scale should not be reviewed separately from other investment information. A change in scale may also affect investment capital, project objectives, land use, construction, implementation schedule, and investment incentives.

Under the current Law on Investment 2025 and Decree No. 96/2026/ND-CP, investors can adjust investment projects during implementation, but certain major changes require investment policy adjustment before the investor proceeds with related changes to the project or IRC.

Therefore, before applying for FDI Project Scale Adjustment Vietnam, foreign investors should review the existing investment documents, identify every proposed change, assess its effect on capital and project objectives, and determine the correct procedure.

As a result, a well-prepared adjustment process can help the investor keep the registered project information consistent with actual operations and reduce future investment compliance risks.

MVA VIETNAM ACCOUNTING AND AUDITING COMPANY LIMITED