FDI Project Location Adjustment Vietnam refers to the process of changing the registered location of a foreign-invested investment project in Vietnam. During the project lifecycle, an investor may need to move a factory, office, warehouse, production facility, or other project location because of changes in land availability, business plans, production needs, infrastructure, or local development plans.

I. What Is FDI Project Location Adjustment Vietnam?

1.1 Understanding Project Location Adjustment

FDI Project Location Adjustment Vietnam means changing the registered location of an existing foreign-invested investment project.

The location is an important part of an investment project because it can affect land use, construction, environmental requirements, local planning, taxes, and the authority responsible for managing the project.

A location adjustment may involve:

• Moving the project to another address
• Moving the project to another industrial park
• Moving the project to another province or city
• Changing the land area used by the project
• Adjusting the location together with the project scale
• Updating the project location after a change in administrative boundaries

Therefore, investors should first identify the exact nature of the location change before preparing the application.

1.2 Why Do Foreign Investors Change Project Locations?

Foreign investors may change a project location for many practical reasons. For example, the existing factory may no longer provide enough space for expansion. Similarly, an investor may find a more suitable industrial park with better infrastructure and transportation.

Common reasons include:

• Lack of available land
• Expansion of production
• Relocation to an industrial park
• Better transportation infrastructure
• Changes in local planning
• Factory construction requirements
• Business restructuring
• Changes in project scale
• Environmental or technical requirements

As a result, a location adjustment can help the investor align the registered project with its current business plan.

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II. When Does an FDI Project Need Location Adjustment?

2.1 Moving to a New Location

The most obvious case occurs when an investor wants to move the project to another location.

For example, a foreign-invested manufacturing company may currently operate a factory in Province A. The investor may later decide to move the entire project to Province B.

This is a significant change because the new location may involve a different investment registration authority, land regulations, planning requirements, and local policies.

Therefore, the investor should review the legal requirements before moving the project in practice.

2.2 Moving Within the Same Province

A location change does not always involve a different province.

An investor may move a project from one industrial park to another location within the same province. Even though the provincial authority remains the same, the new location may have different land, planning, construction, and environmental conditions.

For this reason, the company should still complete the required investment procedures before treating the new location as the official project location.

2.3 Changing the Land Area

A location adjustment may also involve a change in the amount of land used by the project.

For example, an investor may initially register 20 hectares for a manufacturing project. Later, the investor may need only 12 hectares because the production plan has changed.

Conversely, an expansion may require additional land.

Under the current investment regulations, certain changes in the land area of a project that has received investment policy approval can require adjustment of the investment policy approval. Decree No. 96/2026/ND-CP provides specific rules for these cases. III. FDI Project Location and Investment Policy Approval

3.1 When Is Investment Policy Adjustment Required?

One of the most important questions in FDI Project Location Adjustment Vietnam is whether the investor needs to adjust investment policy approval.

Article 33 of the Law on Investment 2025 provides cases where an investment project that has received investment policy approval must obtain an adjustment of that approval.

These cases can include certain changes to the project’s location and land area, as well as other major project changes.

Therefore, investors should first determine whether their project has investment policy approval and then compare the proposed location change with the applicable rules.

3.2 Moving Across Provincial Boundaries

Moving an FDI project from one province to another can create additional issues.

The investor may need to review:

• New land availability
• Local planning
• Investment registration authority
• Construction requirements
• Environmental requirements
• Project infrastructure
• Local investment policies

In addition, the investor should consider whether the move changes other project information.

For example, moving a factory may also increase the land area and production capacity. In that case, the investor may need to adjust the project location, scale, and investment capital together.

3.3 Location and Project Objectives

The new location must also support the project’s registered objectives.

For example, a manufacturing project may require a location that satisfies industrial planning requirements. Similarly, a project involving logistics, healthcare, education, or other regulated activities may need to meet specific location requirements under specialized regulations.

Therefore, the investor should check the proposed location against both investment law and sector-specific regulations.

IV. FDI Project Location Adjustment Vietnam Procedure

4.1 Step 1: Review the Current Investment Documents

Before making a location adjustment, the investor should review the existing project information.

The company should check:

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

After that, the investor can identify which information will change together with the project location.

4.2 Step 2: Confirm the New Location

The investor should prepare clear information about the proposed location.

This may include:

• New address
• Land area
• Land use purpose
• Industrial park information
• Lease information
• Infrastructure information
• Construction plan
• Relevant land documents

At the same time, the investor should check whether the new location is suitable for the proposed project objectives.

A location that does not meet planning or sector requirements may create problems during the investment adjustment process.

4.3 Step 3: Review Land and Planning Requirements

Land and planning are important parts of a location adjustment.

The investor should determine whether the new location is suitable for the project under the applicable land and planning rules.

For example, a manufacturing project may need land located in an appropriate industrial area. Similarly, a project involving construction may need to comply with local planning and construction requirements.

Therefore, the investor should review the new location before finalizing the investment application.

4.4 Step 4: Determine the Applicable Investment Procedure

After reviewing the project, the investor should determine whether the location change requires:

• Adjustment of investment policy approval
• Adjustment of the Investment Registration Certificate
• Changes to other investment documents
• Additional procedures under specialized laws

Decree No. 96/2026/ND-CP provides procedures for adjusting investment projects, including projects that have investment policy approval and projects that do not require adjustment of investment policy approval. (thuvienphapluat.vn)

Therefore, investors should determine the correct procedure before preparing the final application.

4.5 Step 5: Prepare and Submit the Application

The investor should prepare the required documents based on the project and the proposed change.

The application may contain information about:

• Existing project location
• Proposed new location
• Reason for relocation
• Land area
• Project objectives
• Project scale
• Investment capital
• Implementation schedule
• Financial capacity
• Project implementation plan

After preparing the documents, the investor submits the application to the competent authority according to the applicable procedure.

V. Important Issues When Changing an FDI Project Location

5.1 Land and Lease Arrangements

The investor should carefully review the land arrangements at the new location.

For example, a company moving to an industrial park may need to sign a new land sublease agreement or update existing land-related documents.

The company should ensure that the new land arrangement supports the registered project objectives.

In addition, the investor should review the project schedule because land handover delays can affect construction and project implementation.

5.2 Environmental Requirements

A location change can also affect environmental requirements.

For example, a manufacturing project may move to a larger facility with higher production capacity. As a result, environmental requirements may also change.

The investor should review whether the new location affects:

• Environmental impact assessment
• Environmental permits
• Waste treatment
• Production technology
• Environmental protection measures

Therefore, environmental compliance should form part of the location adjustment review.

5.3 Construction and Infrastructure

The investor should also review construction requirements at the new location.

A new factory or facility may require changes to:

• Construction plans
• Factory design
• Production lines
• Utilities
• Waste treatment systems
• Fire prevention and fighting systems

Therefore, the company should coordinate investment, construction, engineering, and legal teams before moving the project.

5.4 Project Scale and Investment Capital

A location change may also affect project scale and investment capital.

For example, moving to a larger industrial site may allow the investor to increase production capacity. Consequently, the company may need additional machinery and capital.

In another situation, the investor may move to a smaller site and reduce the project scale.

The company should therefore review whether the location adjustment also requires changes to:

• Investment capital
• Production capacity
• Land area
• Factory area
• Number of employees
• Project objectives
• Implementation schedule

VI. Accounting and Compliance After Location Adjustment

6.1 Update Investment and Corporate Records

After completing the location adjustment, the company should update its internal records.

Relevant documents may include:

• Investment Registration Certificate
• Investment policy approval
• Land documents
• Lease agreements
• Corporate records
• Internal project records
• Investment reports

At the same time, the company should inform relevant departments about the new project location.

6.2 Review Accounting and Tax Records

A project relocation can affect accounting and tax information.

For example, moving a factory may involve transferring fixed assets, construction costs, equipment, inventory, and other project-related assets.

The accounting team should therefore review the financial impact of the relocation.

The company should also check whether the change affects:

• Tax registration information
• Invoices
• Accounting records
• Fixed asset records
• Depreciation
• Local tax obligations

As a result, the company can keep its financial records consistent with the updated investment project.

6.3 Update Investment Reports

The company should also use the new project location in future investment reports.

Investment reporting can include information about project implementation, investment capital, business results, employment, and other project indicators.

Therefore, the company should ensure that the location shown in investment reports matches the updated investment documents.

6.4 Continue Monitoring Project Compliance

Completing the location adjustment does not end the investor’s compliance obligations.

The company should continue monitoring:

• Project implementation
• Land use
• Construction
• Investment capital
• Project scale
• Environmental compliance
• Investment reporting

If the company later changes the project again, it should review whether another investment adjustment is required.

VII. Conclusion

FDI Project Location Adjustment Vietnam is an important procedure for foreign investors that need to move or change the registered location of an existing investment project.

Investors may change project locations because of factory expansion, land availability, infrastructure, business restructuring, local planning, or changes in production needs. However, a location change can affect many other aspects of the project, including land use, project scale, investment capital, construction, environmental requirements, and implementation schedules.

MVA VIETNAM ACCOUNTING AND AUDITING COMPANY LIMITED