The Largest Administrative Reform in Vietnam’s FDI System in Over a Decade

Vietnam’s ongoing institutional reform — driven by the Government’s programme to reduce the number of government ministries from 18 to fewer than 15 — has produced one of the most consequential changes to the day-to-day administration of foreign investment since the Investment Law framework was introduced. The Ministry of Planning and Investment (MPI) has been merged into the Ministry of Finance (MOF), and at the provincial level, Departments of Planning and Investment (DPI) have been merged into provincial Finance Departments (STC — Sở Tài chính).

For foreign-invested enterprises with existing IRCs, this reform is not just an organisational chart change. It has changed the technical systems through which investment reporting is processed, the project code formats used for system identification, the administrative routing for IRC amendments and monitoring report filings, and — in Ho Chi Minh City — the number of portals on which companies are required to file investment reports. ECOVIS Vietnam Law is advising FDI clients on the specific steps required to restore system access, update administrative routing, and comply with the new dual-portal obligation.

The IRC Project Code Migration Gap

Every IRC issued to a foreign-invested enterprise carries a project code — the identifier that links the investment project to the investment registration authority’s database, the national investment information system, and the foreign exchange management records at the commercial bank. Before the merger, these project codes followed the format of the DPI that issued the IRC.

The national investment information system under the MOF now uses a new 10-digit project identifier format. Old DPI-format project codes are not automatically mapped to new 10-digit identifiers in the MOF backend. Companies that attempt to log into the national investment reporting portal using their old project codes — to file investment monitoring reports, to check their registration status, or to initiate an IRC amendment — find that the old code either does not return a result or returns an error indicating that the project is not found in the current system.

This is not an error in the company’s records. It is a data migration gap in the government’s system transition. The old project codes exist in the legacy DPI database; they have not yet been linked to new records in the MOF national system. To obtain a new 10-digit identifier linked to their existing IRC, companies must submit a formal administrative letter (công văn) to the provincial Finance Department requesting data synchronisation and the assignment of a new project code. The letter should reference the original IRC number, the issuing DPI, and the last known system access date.

The HCMC Dual-Portal Obligation

For companies operating in Ho Chi Minh City, the institutional reform has introduced an additional compliance obligation that does not apply in all provinces: a dual reporting requirement across two separate systems.

Investment monitoring reports for HCMC-based FIEs must now be filed on the national portal managed by the Ministry of Finance (mpi.gov.vn and its successor portal under the MOF framework) AND on the HCMC Finance Department’s local portal. The HCMC Finance Department (STC HCMC) has maintained its own investment supervision portal and reporting workflow, and the integration between the national MOF portal and the HCMC local portal has not been fully completed. Until the two systems are technically synchronised, companies in HCMC cannot satisfy their reporting obligation by filing on one portal only — a report submitted only to the national portal does not appear in the HCMC STC’s records, and vice versa.

The practical consequence is that HCMC companies that filed investment monitoring reports on only one portal during the transition period — or companies that could not file on either portal due to the project code migration gap — have monitoring report gaps in at least one system and potentially both. As discussed in ECOVIS Vietnam Law’s earlier analysis of investment monitoring report obligations, these gaps carry penalty and revocation risk under Decree 122/2021.

IRC Amendment Routing During the Transition

For companies that need to amend their IRC during the merger transition period — to change charter capital, update business lines, change the legal representative, or extend the investment project term — the administrative routing for the amendment application has changed. Applications that would previously have been submitted to the provincial DPI are now submitted to the provincial Finance Department’s investment management division.

The acceptance procedures, document requirements, and statutory timelines remain the same as under the DPI. However, the new STC investment management divisions have in some cases inherited a backlog of pending files from the DPI that was not fully completed before the merger, and some officials have transitioned from planning to finance ministry supervision with limited time to acclimate to existing pending applications. Companies with IRC amendments in progress at the time of the merger should confirm in writing with the STC that their application has been received and is being processed under the new structure, and request written confirmation of the processing timeline.

What Companies Should Do Now

The first step is to confirm your company’s current system access status. Log into the national investment reporting portal and test whether your existing project code returns your IRC details. If it does not, file the administrative letter requesting data synchronisation with the provincial Finance Department as promptly as possible — the longer the gap before synchronisation is resolved, the further behind investment monitoring report filings will fall.

HCMC companies should also check their status on the HCMC STC local portal specifically, and confirm whether investment monitoring reports filed during the DPI era are visible in the current STC system. Where they are not, a supplementary filing may be required to ensure the records are complete on both the national and local systems.

Companies with pending IRC amendments should contact the STC investment management division to confirm that their files were transferred from the DPI and are being processed. Where a transfer cannot be confirmed, re-submitting the amendment application with a cover letter referencing the original submission date is advisable to preserve the original application timeline.

Frequently Asked Questions

Do companies need to obtain a new IRC after the DPI-STC merger?

No. Existing IRCs remain valid — the merger does not invalidate previously issued investment registration certificates. What changes is the administrative routing (applications and reports go to STC, not DPI), the system portal (new national MOF portal), and the project identifier format (old codes need migration to new 10-digit IDs). The IRC document itself does not need to be reissued solely because of the institutional merger.

How long does the project code data synchronisation request take?

Processing time varies by province. In HCMC, where the volume of existing FIE records is highest, the STC has been processing synchronisation requests on a case-by-case basis; some companies receive their new project codes within two to three weeks, while others with more complex registration histories (multiple amendments, ownership changes) take longer. Engaging a legal representative to liaise directly with the STC investment management division can accelerate the process.

Has the reform changed the competent authority for industrial park IRC applications?

For projects located in industrial parks, export processing zones, and high-tech zones, the competent licensing authority has generally remained the Industrial Park Management Board (Ban Quản lý Khu công nghiệp) or the equivalent zone management authority — these boards have not been merged into the Finance Department structure. The reform primarily affects the licensing authority for non-industrial-park investments previously administered by the provincial DPI. Companies in industrial parks should confirm the current administrative routing for any pending or planned applications with the relevant zone management authority.

Is the dual-portal obligation for HCMC permanent or temporary?

The current dual-portal obligation reflects an interim state during the technical integration of the national MOF system and the HCMC STC local system. The government’s intention is full integration, but no confirmed completion date has been announced. Until integration is confirmed and the HCMC STC announces that national portal filings are fully mirrored to local records, companies in HCMC should continue filing on both portals to ensure compliance in both systems.

Has your company’s IRC project code been migrated to the new MOF system — and are your HCMC investment monitoring reports visible on both portals? Contact Attorney Vu Manh Quynh at ECOVIS Vietnam Law for a system access review and administrative routing update. Email: vietnam@ecovislaw.vn | Website: www.ecovislaw.vn

This material is for general informational purposes only and does not constitute legal, tax or professional advice. Investors should seek specific advice based on their business sector, ownership structure and investment location in Vietnam. Legal and regulatory references reflect the institutional position as of August 2026 following the MPI-MOF merger.

Attorney Vu Manh Quynh is the Managing Partner of ECOVIS Vietnam Law, advising international investors on Foreign Direct Investment (FDI), corporate governance, and regulatory compliance in Vietnam. Email: vietnam@ecovislaw.vn | Website: www.ecovislaw.vn