Investment Registration Certificate 2026: procedure, time limits and dossier checklist
When an IRC is needed, who issues it, how long it takes and which documents to file under Investment Law 143/2025/QH15 and Decree 96/2026/ND-CP.
In this article
Since 1 March 2026 the Investment Registration Certificate (IRC) procedure follows Investment Law No. 143/2025/QH15 (replacing the 2020 Investment Law) and Decree 96/2026/ND-CP of 31 March 2026, which details and guides the Investment Law (replacing Decree 31/2021/ND-CP). This article covers when an IRC is needed, who issues it, the steps, the time limits and a dossier checklist for FDI factory projects.
Which projects need an IRC?
Under Article 26(1) of the 2025 Investment Law, an IRC is required for:
- investment projects of foreign investors;
- projects of companies covered by Article 20(1), that is, companies in which foreign investors hold more than 50% of the charter capital (or equivalent indirect ownership).
Projects of domestic investors, of companies outside Article 20(1), and capital contributions or share purchases do not need an IRC (Article 26(2)), although the investor may still apply for one (Article 26(4)).
A foreign investor may set up the company before the IRC procedure, provided it meets the market-access conditions of Article 8 at set-up (Article 19(2)).
Who issues it?
- The management board of the industrial, export processing, high-tech or economic zone for projects inside the zone, including concentrated digital technology zones (Article 27(1)).
- The provincial Department of Finance for projects outside such zones (Article 27(2)).
- The registration authority where the project office is located for projects in two or more provinces, projects both inside and outside a zone, or projects in a zone without a management board (Article 27(3)).
Steps and time limits
1. Online declaration
Before filing, the investor declares the project on the National Investment Information System. The dossier must reach the registration authority within 10 working days of the declaration, or the declaration lapses (Article 41(1), Decree 96/2026/ND-CP).
2. Projects that need no investment policy approval
The authority issues the IRC within 10 working days of a valid dossier if the project meets the conditions of Article 39(3) of Decree 96/2026/ND-CP:
- it is not in a prohibited business line;
- the project site is identified (land-use documents, a site lease agreement or equivalent);
- it is consistent with the planning;
- it meets any investment-per-area and labour requirements set by the provincial People's Committee;
- it meets the market-access conditions for foreign investors;
- it meets the technology conditions where a technology opinion is required.
3. Projects that need investment policy approval
For projects listed in Article 24 of the Investment Law, the IRC is issued within 5 working days of receiving the policy approval decision (Article 38, Decree 96/2026/ND-CP). For zone projects within the provincial chairperson's remit and consistent with the planning, the zone management board grants the policy approval (Article 25(4), Investment Law).
4. Online filing
Projects without policy approval may file online, with or without a digital signature (Article 42). The authority asks for corrections within 5 working days and issues the IRC within 10 working days of a valid dossier (Article 43). Without a digital signature, the paper set for cross-checking must arrive within 30 days of the eligibility notice.
IRC dossier checklist
Dossier items under Article 32(1) of Decree 96/2026/ND-CP (also used for the IRC procedure in Article 39):
| No. | Document | Practical notes |
|---|---|---|
| 1 | Request to implement the investment project, including a commitment to bear all costs and risks if the project is not approved | On the authority's form, signed by the investor's legal representative |
| 2 | Documents on the investor's legal status | Parent company certificate of incorporation or passport (individuals); foreign documents usually need consular legalisation and certified translation, confirm with the receiving office |
| 3 | Proof of financial capacity (at least one) | Financial statements for the last 2 years; financial support commitment from the parent company or a financial institution; financial capacity guarantee; other evidence |
| 4 | Investment project proposal | Objectives, scale, capital and funding plan, location, duration, schedule, land and labour needs, incentives requested, socio-economic impact, preliminary environmental assessment (where applicable) |
| 5 | Copy of land-use documents or other proof of the right to use the site | When no land allocation or lease from the State is requested; in an industrial zone this is usually the land or factory sub-lease agreement with the infrastructure developer |
| 6 | Technology explanation | Only for projects subject to technology appraisal under the technology transfer law |
| 7 | BCC contract | Only for projects in BCC form |
| 8 | Other documents on the investor's conditions and capacity, where required | For example a power of attorney and the attorney's papers when filing on the investor's behalf (Article 42(4)) |
Common mistakes
- Data on the system does not match the paper dossier, which allows the authority to refuse (Article 43(2)(h)).
- The paper dossier is not filed within 10 working days of the online declaration.
- The project proposal lacks land needs, schedule or funding plan.
- The industrial-zone lease agreement does not fix the plot, area and lease term.
With the IRC in hand, the project moves on to the feasibility study, design and the construction, fire safety and environmental procedures. See the overview in The 2026 legal roadmap for FDI factory projects.
Legal basis
| Document | Issued | In force | Notes |
|---|---|---|---|
| Investment Law No. 143/2025/QH15 | 11/12/2025 | 01/03/2026 | — |
| Decree 96/2026/ND-CP detailing and guiding the Investment Law | 31/03/2026 | — | — |
Get advice on the legal path for your project
World Steel supports investors from permit preparation, design and fire safety appraisal through to construction and acceptance of factory buildings. Share your project details (location, site area, floor area, target schedule) and our team will contact you to review the legal path for your project.
Note: This article is for general information, based on legislation in force on 25 October 2026, and is not legal advice for any specific project. Vietnamese legal texts are the authoritative versions.
