Somewhere in your Investment Registration Certificate (IRC) application there is a table that looks harmless. A column for the business line. A column for its VSIC code, the Vietnam Standard Industrial Classification that defines what your business does.
And, where the line is specified in CPC, the United Nations Central Product Classification, a column for that code too. It is the language Vietnam’s market-access commitments are written in.
The IRC and the Enterprise Registration Certificate (ERC) create your company. These codes decide what it may do.
Two classification systems for one activity. When they disagree about what you do, the dossier stalls. The scope gets rewritten. Or the certificate comes back narrower than the business you planned.
The mismatch is fixed with words, not forms. The codes live in Decision No. 36/2025/QD-TTg (VSIC 2025) and the World Trade Organization (WTO) schedule of commitments, and the wording between them is yours to draft.
Our guide to the two documents that create a project explains where the table sits. This article explains how to fill it.
TL;DR – The IRC and ERC create your company. The VSIC and CPC codes decide what it may do, and they have to fit your actual business exactly and use the current numbering. VSIC is Vietnam’s domestic industry classification, now VSIC 2025. CPC is the United Nations Central Product Classification, the language Vietnam’s WTO commitments speak. Your IRC objectives carry both. Draft the scope description first in plain activity terms. Then map it to VSIC level-4 codes, the four-digit entries for your exact activity, and add CPC codes wherever the line is defined that way. Too narrow and your invoices fall outside your registered scope. Too broad and you have triggered conditions you cannot meet. Any IRC written under the old VSIC 2018 numbering needs a mapping check before you amend it.
This is our ninth article in our ongoing legal series. You may refer to the others here:
- The Two Documents That Create a Project in Vietnam: Investment Policy Approval and the IRC
- The Three-Question Test: Is Your Business Line Prohibited, Conditional, or Actually Allowed in Vietnam?
- Vietnam Sub-Licenses Explained: The Permits You Need After Company Setup
What Are VSIC and CPC Codes Used For?
VSIC 2025: Vietnam’s Domestic Classification
VSIC is the Vietnam Standard Industrial Classification. It is the domestic taxonomy. Two of its labels get mixed up, so keep them apart.
VSIC 2025 is the edition: The current version of the list, effective from 15 November 2025, which replaced the 2018 edition. Level-4 is the registration level: The four-digit code and name for your exact activity.
The full classification goes deeper with five-digit sub-entries, but business registration runs on level-4. Every business line on the ERC, and every objective on the IRC, is written at that level-4 code and name.
CPC: The Language of WTO Commitments
CPC is the Central Product Classification maintained by the United Nations. Vietnam’s WTO services commitments use its Provisional version, the 1991 edition. It appears in your paperwork for one reason: Vietnam’s schedule of specific commitments in services defines market access by CPC number.
Management consultancy is written as CPC 865 in the commitment documents. Software work sits in the CPC 841 to 845 cluster, where 842 covers implementation. Food service is CPC 642 and drink service is CPC 643.
Neither system is wrong. They were built for different jobs. VSIC classifies what an enterprise does inside Vietnam’s economy. CPC classifies what is traded, for the purpose of negotiating who may supply it.
Where Do VSIC and CPC Codes Meet?
Fitting one activity to both code systems? Email info@unitedconsulting.asia.
What the IRC Objectives Table Asks For
In exactly one place: The business-lines table of the IRC application. Its columns are the line name, the VSIC level-4 code, and the CPC code where the line is specified in CPC.
The form’s own note tells you when CPC is mandatory: When the objective is a conditional business line applicable to foreign investors. The CPC code is the market-access key. Miss it and the authority cannot check your line against Vietnam’s commitments.
The registration rules add a subtlety worth memorizing. Conditional business lines named in other legal documents are written using the names in those documents, not a VSIC label you pick yourself.
How Does the Mismatch Derail an Application?
Five Failure Modes to Check Before Filing
- Too narrow. The registered scope says “custom software development for export” and the company starts selling licenses and support locally. Every invoice outside scope is evidence.
- Too broad. The scope lists thirty lines to cover future possibilities. Two are conditional for foreign investors, so the file now needs market-access conditions satisfied for activities the company does not run.
- IRC and ERC out of step. A line added to the ERC without an IRC amendment is a discrepancy waiting to be flagged.
- CPC filed against the wrong activity. The authority measures your market access against a commitment written for a different service. The scope comes back rewritten or refused.
- The wrong VSIC version. An amendment application quotes a code from the 2018 system on a form built for VSIC 2025. The code no longer resolves to the name you used.
The consequence is rarely a dramatic refusal. It is a request for explanation, a resubmission or a narrower certificate, and it can turn into closer compliance scrutiny when reported revenue sits outside the registered activity.
Which outcome you get depends on the facts and the rules that apply to them. Our round-up of the common mistakes when setting up a business in Vietnam covers the file-level versions of these errors.
What Changed When VSIC 2025 Replaced VSIC 2018?
VSIC 2018 vs 2025: The Code Changes That Matter
The numbering, in places where it matters to foreign investors. Computer programming split: The old 6201 became 6211 for video games, game software and game-software tools, and 6219 for other programming.
Computer consultancy and facilities management moved from 6202 to 6220. Data processing and hosting moved from 6311 to 6310, while web portals moved from 6312 to 6390.
| Old VSIC 2018 | New VSIC 2025 | What Changed |
|---|---|---|
| 6201 Computer programming activities | 6211 Video-game, game software and game-software tools; 6219 Other computer programming | Split into two groups |
| 6202 Computer consultancy and computer facilities management | 6220 Computer consultancy and computer infrastructure management | Renamed and recoded |
| 6311 Data processing, hosting and related activities | 6310 IT infrastructure, data processing, hosting and related activities | Merged into one group |
| 6312 Web portals | 6390 Web search portals and other information services | Moved to a different group |
Sources for the mappings: The VSIC 2018 to VSIC 2025 conversion table published by Vietnam’s national business registration portal, and Decision No. 36/2025/QD-TTg itself for the new codes.
None of this invalidates an existing IRC. It does mean that an IRC granted under the old system and amended under the new one has to be translated line by line.
The safe practice is version discipline: State the classification you are working from when the scope is drafted, translate old codes to new ones before filing, and keep the description text authoritative. The code is a pointer. The description is what the authority approves.
How Should You Draft the Scope Description?
A Scope Description Checklist
- Write the activities first, in plain words. What the company will actually invoice. Production of what, distribution of what, services to whom.
- Include the supporting activities. Import and export, installation, maintenance, testing, technical support. These are real business activities and they need lines.
- Map to VSIC level-4 second. One activity may sit under a code whose generic name looks close enough but is not. Read the code’s definition, not its title.
- Add CPC where the line is defined in CPC. If the line is conditional for foreign investors and the commitment text uses CPC, the code is part of the answer.
- Keep IRC and ERC sentences consistent. The same activity described differently on the two documents is the most common self-inflicted delay.
- Prefer the statutory name for conditional lines. Where another legal document names the line, use that name verbatim and add your detail beneath it.
A scope drafted this way also settles the questions that arrive later: Which sub-licenses apply, whether a new line needs an amendment, and what happens at inspection. Those are the subjects of the two articles beside this one.
Conclusion
The CPC and VSIC columns are two views of one business, and the authority needs both to say yes. The description is the business. The codes are the labels that keep it honest.
One good code cannot carry several activities, because description lines under a code must still match its definition. The scope can be fixed later by amendment, but each amendment reopens market-access review for the changed lines.
And a wide scope is not safer than a narrow one: A precise scope is the safer one. Draft the description in activity terms, map it deliberately to both taxonomies, and the mismatch that derails applications is caught in the draft, not in the file at the counter.
Thinking about entering or expanding in Vietnam? Contact United Consulting to discuss how CPC and VSIC mapping applies to your project. Email info@unitedconsulting.asia.
