FDI Project Objective Change Vietnam refers to the process of changing or adding the registered objectives of a foreign-invested investment project in Vietnam. During the project lifecycle, an investor may want to add a new business activity, remove an existing objective, expand into a new product line, or change the purpose of the project to match its actual business plan. Therefore, foreign investors should review the proposed objective change together with the project’s business lines, scale, location, capital, and applicable market access conditions.

I. What Is FDI Project Objective Change Vietnam?

1.1 Understanding Project Objective Change

FDI Project Objective Change Vietnam means changing the objectives registered for an existing foreign-invested investment project.

The project objectives normally describe the main business activities that the investor plans to carry out. Depending on the project, these objectives may cover manufacturing, processing, trading, technology, logistics, real estate, education, healthcare, or other activities.

A foreign investor may request to:

• Add a new project objective
• Remove an existing objective
• Replace an existing objective
• Change the description of an objective
• Adjust an objective to match the actual business model

The exact procedure depends on the nature of the proposed change and the legal status of the project.

1.2 Why Do FDI Investors Change Project Objectives?

Business conditions can change significantly during the life of an FDI project. Therefore, the original project objectives may no longer fully reflect the investor’s current plans.

Common reasons include:

• Expanding into a new business activity
• Adding a new product or service
• Changing the production model
• Removing an activity that the company no longer operates
• Developing a new business line
• Restructuring the investment project
• Responding to changes in market demand
• Aligning the project with the company’s global business strategy

For example, a foreign manufacturer may initially focus on producing industrial parts. Later, it may decide to add assembly and testing services. In this case, the investor should check whether the new activity requires an adjustment to the registered project objectives.

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II. When Does an FDI Project Need Objective Adjustment?

2.1 Adding a New Project Objective

Adding a new objective is one of the most common cases.

For example, an FDI company may currently operate a project for manufacturing machinery. The investor then wants to add machinery maintenance and repair services.

The company should first determine whether the new activity:

• Is allowed for foreign investors
• Has market access conditions
• Requires a specific license
• Falls under a conditional business line
• Affects investment incentives
• Changes the nature or scale of the existing project

As a result, the company should not simply add a business code without reviewing the investment regulations.

2.2 Removing an Existing Project Objective

An investor may also remove an objective that it no longer plans to carry out.

For instance, a company may register several manufacturing activities when it first establishes the project. After reviewing its business strategy, the investor may decide to discontinue one activity.

In this situation, the company can review the possibility of removing that objective from the investment project.

This can help keep the IRC and actual business operations consistent.

2.3 Changing the Nature of an Existing Objective

Sometimes, the investor does not completely add or remove an objective. Instead, the investor wants to change the way an existing objective is described.

For example, a project may initially focus on manufacturing one product group. Later, the investor may expand into a broader range of products. The company should determine whether the change only updates the wording or actually creates a new investment objective. This distinction is important because a material change may trigger a different investment procedure.

III. Foreign Investor Market Access and Project Objectives

3.1 Check Market Access Conditions

Before changing project objectives, foreign investors should check whether the proposed business activity has market access conditions for foreign investors.

This is particularly important when the new objective relates to a regulated sector.

The Law on Investment 2025 continues to regulate market access conditions for foreign investors. Foreign investors must comply with applicable conditions when investing in sectors where Vietnam imposes market access restrictions.

Therefore, the investor should check the proposed activity before preparing the adjustment application.

For example, depending on the activity, the investor may need to consider:

• Foreign ownership limits
• Investment methods
• Scope of business activities
• Professional qualifications
• Other conditions under specialized laws

3.2 Check Conditional Business Lines

The investor should also determine whether the new objective belongs to a conditional business line.

A new project objective may require additional licenses or approvals before the company can actually conduct the activity.

For example, activities in areas such as education, healthcare, logistics, finance, or certain trading sectors may have additional requirements. Therefore, obtaining an adjusted IRC does not always mean that the company can immediately start every new activity. The investor should also review the relevant specialized regulations.

3.3 Review Investment Incentives

A change in project objectives can also affect investment incentives.

For example, the investor may add a new activity that qualifies for investment incentives. However, the company should not assume that the entire project automatically receives the new incentive.

Investment incentives depend on the applicable conditions and the actual implementation of the project.

Therefore, the company should review:

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

This review is especially important when the investor plans to make a large additional investment.

IV. FDI Project Objective Change Vietnam Procedure

4.1 Step 1: Review the Existing Project

Before applying for an objective change, the investor should review the current investment documents.

The company should check:

• Investment Registration Certificate
• Investment policy approval, if applicable
• Current project objectives
• Investment capital
• Project scale
• Project location
• Implementation schedule
• Project duration
• Investment incentives

The investor should then compare the current information with the proposed business plan.

This helps identify whether the objective change also affects other project contents.

4.2 Step 2: Identify the Proposed Objective

The investor should clearly describe the new, changed, or removed objective.

The proposed objective should accurately reflect the actual activity that the company plans to conduct.

At this stage, the investor should also review the appropriate economic activity classification and relevant industry regulations.

For example, a company should distinguish between manufacturing, processing, wholesale, retail, consulting, technology, and service activities when defining the project objective.

A clear description can help reduce questions during the investment registration process.

4.3 Step 3: Determine Whether Investment Policy Adjustment Is Required

This is one of the most important steps.

Article 33 of the Law on Investment 2025 provides that investors may adjust project objectives during implementation. However, if the project has received investment policy approval, the investor must carry out investment policy adjustment procedures when the change or addition involves objectives that fall within the scope of investment policy approval.

Decree No. 96/2026/ND-CP provides further guidance. In particular, Article 51 states that a project with investment policy approval must follow the investment policy adjustment procedure when the proposed change falls under Article 33 of the Law on Investment.

Therefore, investors should determine the project’s approval status before choosing the procedure.

4.4 Step 4: Prepare the Application

After determining the procedure, the investor should prepare the relevant documents.

Depending on the project, the application may explain:

• Current project objectives
• Proposed objectives
• Reason for the change
• Current project implementation
• Proposed business plan
• Investment capital
• Project scale
• Implementation schedule
• Financial capacity
• Other related changes

The investor should also prepare supporting documents when the new objective requires proof of financial capacity, technology, qualifications, or other conditions.

4.5 Step 5: Submit to the Competent Authority

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

Under the Law on Investment 2025, Management Boards of industrial parks, export processing zones, high-tech zones, concentrated digital technology zones, and economic zones generally handle IRC matters for projects within their jurisdiction. Provincial-level Departments of Finance generally handle projects outside those areas, subject to the exceptions provided by law.

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

V. Important Issues When Changing FDI Project Objectives

5.1 The New Objective Must Match Actual Operations

The project objective should reflect what the company actually intends to do.

For example, if an investor registers a manufacturing objective but later mainly provides consulting services, the company should review whether its investment information still matches its actual operations.

Keeping the registered objectives accurate can help reduce compliance risks during inspections and investment reporting.

5.2 Objective Change May Affect Project Scale

A new objective may also increase the scale of the project.

For example, a manufacturer may add a new production line after adding a new product objective. As a result, the investor may need more machinery, factory space, employees, and investment capital.

In this case, the investor should review all related changes instead of submitting an objective adjustment alone.

5.3 Objective Change May Affect Investment Capital

Some new objectives require additional investment.

For example, a company may need to purchase new machinery or build a new facility before starting the new activity.

Therefore, the investor should check whether the objective change also requires:

• Increasing investment capital
• Changing the capital contribution schedule
• Adjusting project expenses
• Updating financial capacity information

If capital also changes, the investor should include the relevant information in the adjustment process where appropriate.

5.4 Objective Change May Affect the Implementation Schedule

A new objective can require additional time to implement.

For example, a new manufacturing activity may require construction, equipment installation, environmental procedures, recruitment, and testing. As a result, the company should review whether the existing project implementation schedule remains realistic. The Law on Investment 2025 provides specific rules for project schedule adjustments. In certain cases, an adjustment of project objectives can also be an exception to the general limit on extending an approved project’s implementation schedule by more than 24 months. Therefore, investors should assess the schedule together with the objective change.

VI. Accounting and Compliance After Objective Change

6.1 Update Corporate Records

After completing the investment adjustment, the company should update its internal records. Relevant departments should receive the new investment information so that the company can use consistent information in future activities.

The company should review:

• Investment documents
• Corporate records
• Internal business plans
• Accounting information
• Tax records
• Investment reports
• Business licenses

Keeping these records consistent can make future compliance work easier.

6.2 Review Accounting and Tax Implications

A new project objective may create new revenue streams or expenses.

For example, adding a manufacturing activity may result in new machinery purchases, inventory costs, depreciation, and production expenses. Similarly, adding a service activity may create different invoicing and tax requirements. Therefore, the accounting team should review the tax and accounting treatment before the company starts the new activity.

6.3 Update Investment Reporting

The company should also use the updated project objectives in future investment reports. Investment reporting may include information about project implementation, investment capital, business results, employment, and other project indicators. Therefore, the investment report should remain consistent with the updated project information.

6.4 Review Licenses and Specialized Approvals

Finally, the company should check whether the new objective requires additional licenses. An adjusted IRC does not automatically replace all licenses required under specialized laws. Depending on the activity, the company may need additional approvals or operating conditions. For this reason, the investor should complete the investment adjustment first and then review the specific requirements for the new business activity.

VII. Conclusion

FDI Project Objective Change Vietnam is an important procedure for foreign investors who want to modify the business objectives of an existing investment project.

Investors may change project objectives when they expand into new products or services, remove activities, restructure the business, or adapt the project to new market conditions. However, the investor should review the proposed change carefully because a new objective may also affect market access, project scale, investment capital, implementation schedule, land, licenses, and investment incentives.

MVA VIETNAM ACCOUNTING AND AUDITING COMPANY LIMITED