Short answer: An enterprise may not register changes to its enterprise registration content when it is in special legal situations such as: undergoing dissolution procedures, having received a decision to revoke its Enterprise Registration Certificate, or being subject to a written request from a court, enforcement agency or tax authority to suspend change registration. Detailed provisions are in Decree 168/2025/ND-CP.
Legal basis
- Decree 168/2025/ND-CP on enterprise registration (effective from 01/07/2025).
Cases where change registration is not allowed
- The enterprise is undergoing dissolution under the owner’s decision;
- There is a decision to revoke the Enterprise Registration Certificate;
- There is a written request from a court, arbitration body or enforcement agency to suspend change registration for litigation or enforcement purposes;
- The tax authority requests a suspension in writing because the enterprise is under tax enforcement or has absconded from its registered address;
- The enterprise is in bankruptcy proceedings (corresponding restrictions apply).
How does the Business Registration Office handle this?
- It issues a refusal notice stating the reasons for refusing the change registration;
- The enterprise may appeal the refusal under the complaints law procedures;
- After the cause is resolved (dissolution completed, obligations fulfilled, etc.), the enterprise repeats the procedure under the general rules.
What should the enterprise do?
- Check the enterprise’s legal status on the National Enterprise Registration Portal before filing;
- If refused: read the reasons carefully and work with the requesting authority to resolve the suspension;
- Do not file change applications when known to fall under a prohibited case — to avoid wasting time and incurring other legal risks.
If you need to determine the appropriate approach for your specific situation, you should discuss it with a lawyer beforehand to have your file reviewed and a suitable solution advised.
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