Investment Project Modification Vietnam is an important procedure for foreign-invested companies that need to change information or activities relating to an existing investment project. During the operation of an FDI project, investors may need to increase investment capital, change project objectives, expand the project, change the location, or extend the implementation schedule.Vietnam’s investment framework has been updated in 2026. Decree 96/2026/ND-CP, effective from March 31, 2026, provides detailed guidance on investment project adjustments and the procedures for modifying investment projects.Therefore, investors should review the project’s current registration documents before making significant changes.

I. What Is Investment Project Modification Vietnam?

1.1 Understanding Investment Project Modification

Investment Project Modification Vietnam refers to the procedure for adjusting information or activities of an investment project after the project has been registered or approved.

For an FDI company, modifications may affect information recorded in the Investment Registration Certificate (IRC).

Common changes include:

• Investment capital
• Project objectives
• Project scale
• Project location
• Implementation schedule
• Project duration
• Investor information
• Other registered project information

Therefore, companies should determine the exact change before choosing the appropriate procedure.

1.2 Why Is Project Modification Important?

An investment project should generally be implemented according to its approved or registered contents.

However, business plans can change over time.

For example, a company may decide to expand production or add a new business activity. In another case, the investor may need more time to complete the project.

Therefore, completing the appropriate modification procedure helps keep the project information consistent with the company’s actual operations.

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II. Common Types of Investment Project Modification

2.1 Increase or Decrease Investment Capital

Changes to investment capital are common among FDI companies.

For example, an investor may increase capital to:

• Expand production
• Purchase machinery
• Build a new facility
• Increase operating capacity
• Develop new products

Therefore, the company should review whether the change requires modification of its investment project.

Moreover, the proposed capital should be supported by appropriate financial information.

2.2 Change Project Objectives

Businesses may also want to add or change their investment objectives.

For example, a manufacturing company may want to add a new product line or introduce additional services.

However, investors should first check whether the new activity is subject to foreign investment market access conditions.

As a result, the company can avoid registering an activity that requires additional approval or licensing.

2.3 Change Project Location

An investment project may also need to move to another location.

Location changes can involve additional considerations relating to:

• Land
• Construction
• Planning
• Environmental requirements
• Industrial parks
• Local investment conditions

Therefore, investors should review the legal requirements before moving the project.

2.4 Extend the Project Schedule

Project implementation schedules may change because of construction delays, licensing procedures, financing issues, or other circumstances.

Under the 2025 Investment Law, projects subject to investment policy approval generally cannot extend the implementation schedule by more than 24 months from the original approved schedule, except for specific cases provided by law.

Therefore, investors should review the schedule carefully before requesting an extension.

III. When Is Investment Project Modification Required?

3.1 Projects Not Subject to Investment Policy Approval

For an investment project that is not subject to investment policy approval, the investor generally carries out procedures to modify the Investment Registration Certificate where applicable.

Decree 96/2026/ND-CP specifically provides that projects not subject to investment policy approval, or projects already approved but whose changes do not fall into the cases requiring adjustment of investment policy approval, can proceed with IRC modification procedures.

Therefore, the procedure can be simpler than projects requiring investment policy adjustment.

3.2 Projects Subject to Investment Policy Approval

Different procedures apply when the investment project has already received investment policy approval.

Certain changes may require adjustment of the investment policy approval before the IRC or other investment documents can be modified.

These can include significant changes to:

• Approved project objectives
• Project location
• Land area
• Project duration
• Investor
• Other contents subject to investment policy approval

For example, Decree 96/2026/ND-CP identifies certain changes in approved objectives, location, land area, project duration, and investor information as cases requiring investment policy adjustment.

Therefore, investors should determine the project’s original approval status before preparing the application.

IV. Documents for Investment Project Modification Vietnam

4.1 Basic Documents

The exact documents depend on the type of modification.

However, an application may include:

• Request for investment project adjustment
• Report on project implementation
• Investor’s decision on project adjustment
• Explanation of the proposed changes
• Current Investment Registration Certificate
• Supporting documents
• Other project-related documents

For institutional investors, an internal decision approving the proposed modification may also be required.

Decree 96/2026/ND-CP provides specific dossier requirements for investment project adjustments.

4.2 Supporting Documents

Additional documents may be needed depending on the proposed change.

For example:

Capital increase:
Financial statements, bank documents, or other evidence of financial capacity may be relevant.

Location change:
Lease agreements, location documents, or information relating to the proposed site may be required.

Objective change:
Documents explaining the new business activities may be necessary.

Schedule extension:
The investor may need to explain the reasons for the delay and provide information about the remaining project implementation.

Therefore, the application should be prepared based on the specific modification.

V. Investment Project Modification Procedure

5.1 Step 1: Review the Current Investment Documents

First, the investor should review the existing IRC and investment policy approval documents, if any.

The company should identify:

• Current investment capital
• Registered objectives
• Project location
• Project scale
• Implementation schedule
• Project duration
• Investor information

Therefore, the company can clearly identify what needs to be modified.

5.2 Step 2: Determine the Correct Procedure

Next, the investor should determine whether the proposed modification requires:

• Investment policy adjustment
• IRC modification
• Investor approval adjustment
• Other related procedures

This step is particularly important for FDI companies.

If an adjustment causes a project that was previously outside the investment policy approval framework to become subject to such approval, the investor must complete the investment policy approval procedure before modifying the project.

5.3 Step 3: Prepare and Submit the Application

After determining the correct procedure, the investor prepares the relevant documents and submits them to the competent investment registration authority.

For projects subject to investment policy adjustment, the competent authority and procedure depend on the level of approval involved.

For example, Decree 96/2026/ND-CP sets out separate procedures for projects under the authority of the Prime Minister and projects under the authority of the provincial-level People’s Committee.

5.4 Step 4: Receive the Modified Documents

After the application is reviewed and approved, the investor receives the relevant amended investment documents.

The company should then check the updated information carefully.

Moreover, if the investment modification affects enterprise registration information, additional corporate registration procedures may be required.

VI. Important Considerations for FDI Companies

6.1 Keep Investment and Corporate Information Consistent

An FDI company may have both an IRC and an Enterprise Registration Certificate (ERC).

Therefore, investors should check whether the proposed project modification also affects corporate information.

For example, changes to company name, legal representative, or certain corporate details may require a separate enterprise registration procedure.

As a result, keeping the IRC and ERC consistent can reduce compliance risks.

6.2 Review Tax and Accounting Implications

Investment project modifications can also affect accounting and tax matters.

For example, an increase in investment capital may affect:

• Capital contribution records
• Accounting records
• Financial statements
• Bank transactions
• Project expenses

Therefore, the accounting and tax teams should be informed about major investment changes.

6.3 Check Related Licenses

A project modification may create additional licensing requirements.

For example, changing the project objective may introduce a regulated business activity.

Similarly, changing the location may create additional requirements relating to land, construction, environment, or other specialized areas.

Therefore, investors should review related licenses before implementing the modified project.

VII. Conclusion

Investment Project Modification Vietnam allows foreign investors to update their investment projects when business plans or project conditions change. Common modifications include investment capital, project objectives, location, scale, and implementation schedule.

However, not every modification follows the same procedure. The appropriate process depends on whether the project is subject to investment policy approval and the specific nature of the proposed change.

The current framework under Decree 96/2026/ND-CP provides separate procedures for different types of investment project adjustments. Therefore, investors should review their existing investment documents before making changes.

With proper preparation, businesses can update their investment projects more efficiently, maintain consistent corporate information, and reduce potential compliance risks in Vietnam.

MVA VIETNAM ACCOUNTING AND AUDITING COMPANY LIMITED