Tiếng Việt
中文Short answer: For an investment project with only an Investment Registration Certificate (IRC) and not subject to investment policy approval, the law does not impose a 24-month limit on timeline adjustments. The limit of “not adjusting the implementation timeline by more than 24 months compared to the timeline in the initial investment policy approval document” (Clause 4, Article 41 of the Law on Investment 2020, as amended by Law No. 57/2024/QH15) applies only to projects subject to investment policy approval.
Legal basis
- Law on Investment 2020 (as amended and supplemented by Law No. 57/2024/QH15) — Article 41 (adjustment of investment projects), Article 42 (principles of project implementation).
Regulations on adjusting investment projects
Under Article 41 of the Law on Investment 2020 (as amended by Law No. 57/2024/QH15):
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- During implementation, investors may adjust objectives, transfer part or all of the project, merge, divide, or split the project, and adjust other contents in accordance with the law;
- Investors carry out the procedure for adjusting the Investment Registration Certificate when the adjustment changes the Certificate’s contents;
- Investors with projects that have obtained investment policy approval must carry out the procedure for approving the adjustment of investment policy in the statutory cases (change of objectives; change of land area by more than 10% or more than 30 ha; change of total investment capital by 20% or more; timeline extension causing the total duration to exceed the timeline in the initial approval document by more than 12 months; adjustment of the operation term; change of technology; change of investor, etc.).
The 24-month limit applies only to projects subject to investment policy approval
Clause 4, Article 41 provides: for investment projects granted investment policy approval, investors may not adjust the implementation timeline by more than 24 months compared to the timeline in the initial investment policy approval document, except in cases of: force majeure; delayed land allocation, land lease, or land use purpose conversion permission by the State; requests by state management authorities or delayed administrative procedures by state authorities; state authorities changing the planning; changes/additions of objectives; increases in total investment capital of 20% or more changing the project scale.
Accordingly, the 24-month restriction does not apply to projects operating solely under an Investment Registration Certificate without being subject to investment policy approval. For such projects, timeline adjustments follow the IRC adjustment procedure, complying with Article 42 (implementation in accordance with the Investment Registration Certificate and relevant laws).
Frequently asked questions
Does adjusting the timeline require re-approval of investment policy?
Only when the project is subject to investment policy approval and the adjustment falls into the statutory cases. A project with only an Investment Registration Certificate follows the IRC adjustment procedure.
May a timeline extension lead to project revocation?
Delays may lead to handling measures under investment and land law (such as termination of project operations in statutory cases). Investors should proactively complete the timeline adjustment procedure before expiry.
To adjust your project timeline in compliance and avoid handling risks, you should contact ANT Legal’s lawyers at 0966.475.966 for dossier review and advice before proceeding.
