Appendix IV is not a foreign-investor list. It covers conditional business lines that apply regardless of nationality: activities any company may run, but only once it meets the conditions. Some need a licence or certificate first, others are checked after you start. Since 1 July 2026 the list has carried 142 lines.
A food business may need a food-safety certificate. A warehouse or factory, fire-prevention approval. A school or clinic, a sector licence. Our three-question test for business lines asks whether an activity is prohibited, conditional or actually allowed.
Confusing this list with the foreign-investor list is one of the costliest mix-ups we see. Foreign investors face a separate layer of market-access restrictions, and the two lists answer completely different questions. Updates on the reform also appear in English on the Government’s official news site.
TL;DR – Appendix IV is a menu of 142 activities that are legal only once you meet the conditions, and it binds every company in Vietnam, not just foreign ones. The count is 142 today and 137 from March 2027. Foreign investors must separately clear the negative list in Decree No. 96/2026/ND-CP before committing capital.
This is our fifth article in our ongoing legal series. You may refer to the others here:
- Vietnam’s 142 Conditional Business Lines, Named, and What the July 2026 Cut Removed
- The Three-Question Test: Is Your Business Line Prohibited, Conditional, or Actually Allowed in Vietnam?
- Closed or Conditional? Vietnam’s Market-Access List for Foreign Investors, Explained
What Even Is Appendix IV?
Think of Appendix IV as a menu, not a fence: 142 activities that are perfectly legal to run, but only once you meet the conditions.
The annex sits inside Law on Investment No. 143/2025/QH15, passed on 11 December 2025 and in force since 1 March 2026, replacing the Law on Investment 2020. The Official Gazette record carries the full text, and the Government News portal carries an English translation of the Law on Investment 2025.
What makes a line conditional? The state allows the activity, but attaches conditions to protect national defence, security, public order, social ethics or public health. In plain English: you may do the business, but the conditions come first.
- Food businesses may need a food-safety certificate.
- Restaurants, warehouses and factories may need fire-prevention approval.
- Construction work needs permits.
- Schools, clinics and telecoms operators may need their own sector licences.
A condition rarely blocks entry outright, but it is more than paperwork: some involve real eligibility, capital or personnel requirements. Each one adds steps, documents and weeks to your launch plan, so treat it as a workstream.
Does Appendix IV Apply to Foreigners Too?
Yes, and to everyone else too. Appendix IV draws no line between a Vietnamese owner and a foreign one. If your activity is on the list, the same approvals apply. That assumption is the most common misconception about the list.
How Is Appendix IV Different From the Foreign-Investor List?
Foreign investors do face an extra layer: market-access restrictions, which decide whether foreign capital may enter at all, and on what terms. Different list, different test, different paperwork.
Two Different Lists: Conditional Lines Versus Foreign Market Access
| Point | Conditional Business Lines | Foreign Market-Access Restrictions |
|---|---|---|
| Who it applies to | Everyone, domestic and foreign | Foreign investors; over 50% foreign charter capital triggers foreign-investor investment rules for further investment |
| What it requires | Extra approvals or sub-licences (food-safety, fire-prevention) | Entry conditions: closed, capped, or fully open to foreign capital |
| Governing instrument | Appendix IV of the Law on Investment (Law No. 143/2025/QH15) | Appendix I of Decree No. 96/2026/ND-CP, plus World Trade Organization (WTO) commitments and treaties |
| Example | Food trading needs a food-safety certificate either way | Notarial practice: closed to foreign investors, open to Vietnamese firms under licence |
A sector can be legal for a Vietnamese company and capped for a foreign one, and the reverse holds too: a line can be conditional for everyone and still wide open to foreign capital. Decree No. 96/2026/ND-CP, issued 31 March 2026 (ND-CP is short for Government Decree), implements the new law, and its Appendix I is the consolidated negative list. It replaced Decree No. 31/2021/ND-CP and Decree No. 239/2025/ND-CP, both lapsed on 1 March 2026. Treaty-covered investors may choose the more favourable treatment. Our review of what changed from the 2020 law explains the wider framework.
How Many Conditional Business Lines Are There in 2026?
The number moves fast, so quote it with a date. As of October 2026 the answer is 142:
- About 227 lines under the original 2020 framework, amended up to 236 before the reset, and still in force until 30 June 2026.
- 198 in the statutory list that came with the Law on Investment 2025.
- 142 today, from 1 July 2026, under Resolution No. 66.17/2026/NQ-CP.
- 137 from 1 March 2027, under Law No. 24/2026/QH16.
The timing needs one clarification. Article 7 and Appendix IV of the new law took effect on 1 July 2026, and the Government’s Resolution No. 66.17/2026/NQ-CP, dated 15 May 2026, cut the 198-line statutory list to 142 on that same day. The resolution runs to 28 February 2027 while sector rules catch up, and where it conflicts with another document, authorities apply the resolution. The Government News list sets out all 142 in English.
Fewer conditional lines can mean fewer upfront approvals, though the real impact depends on how each sector is regulated. Licences for cut lines stay valid to their expiry dates. But dropping a line does not drop every rule: ministries move those activities to technical standards and post-inspection instead.
What Changes From 2027?
Law No. 24/2026/QH16 passed on 24 August 2026 and takes effect on 1 March 2027, with nitrous oxide rules from 1 January 2027. Two changes matter:
- The conditional list drops to 137. Measured against the 198-line statutory list, accountancy, alcohol and gas trading, duty-free retail and petroleum drop out; one new line covers authorised visa-support services.
- Selling nitrous oxide (N2O), the gas in laughing-gas balloons, for human inhalation joins the prohibited sectors from 1 January 2027, bar medical, food-technology, testing and research uses.
What Is Actually on the List?
What Is in Appendix IV?
Appendix IV is long, which surprises people who assume a short list of sensitive sectors. The 142 lines fall into six categories:
- Professional services: law practice, notary, judicial expertise, auditing, price appraisal.
- Finance and banking: commercial banks, credit institutions, gold trading, crypto services, payment intermediaries.
- Security and defence: security services, military equipment, industrial explosives, blasting.
- Transport and vehicles: road transport, automobile production and import, vehicle inspection, driving schools.
- Trade and commerce: food, tobacco, rice export, e-commerce platforms, multi-level marketing, petroleum.
- Health, education, environment: massage, drug rehabilitation, vocational education, waste treatment, mineral exploitation, scrap import.
If your plan sounds like anything there, budget for at least one sub-licence and check the exact wording first.
Which Mistakes Cost Founders Months?
Four patterns cause most of the trouble we see, as of October 2026:
- Treating a conditional line as foreigner-only, or a foreign-restricted line as merely conditional. Two lists, two questions.
- Forgetting the sub-licences. The conditional line means nothing until any required food-safety, fire-safety or sector approvals are in hand.
- Relying on pre-2026 numbers. If your memo still cites Decree No. 31/2021/ND-CP or counts 227 lines, it describes a dead regime.
- Missing hidden foreign ownership. Add up every foreign shareholding before you test the line, because minority stakes held by different foreign partners count together.
Our article on the common mistakes when setting up a business in Vietnam covers the rest.
What Should You Check Before Picking a Business Line?
Run three checks before you commit capital, in this order:
- Prohibited? Check Article 6. If the activity is on that list, no structure will save it.
- Conditional? Check Appendix IV, 142 lines today and 137 from 2027, then list every sub-licence it triggers and who issues it.
- Foreign market access? Check Appendix I of Decree No. 96/2026/ND-CP, your treaty position, and any banking or aviation ownership cap. Above 50% foreign charter capital, treat the company as foreign.
The order matters: a line can clear one test and fail another. Article 6 of the Law on Investment 2025 bans outright activities such as narcotics, prostitution, human cloning, firecrackers, debt collection, and e-cigarettes or heated tobacco. A conditional line is the opposite: everyone may do it once the conditions are met. Three questions, three different lists, and answering only one is how projects stall.
Since 1 March 2026 a foreign investor may also register the company first and take the investment registration certificate (IRC) within 12 months. Our guide to the two documents that create a project in Vietnam explains that rule, and our step-by-step guide to setting up a business in Vietnam walks through the rest.
Conclusion
Appendix IV is a licensing checklist for everybody, not a gate for foreigners. The cuts from 227 lines to 142 and finally 137 can make entry cheaper, but the conditions that remain still bind every company in Vietnam.
Foreign investors clear both lists, and the paperwork comes from different authorities. Treat the three checks as part of your feasibility work, and date-stamp every list you rely on. The rules moved three times in 2026 alone, and a plan built on last year’s numbers will meet this year’s licensing desk.
Thinking about entering or expanding in Vietnam? Contact United Consulting to discuss Vietnam’s conditional business lines and whether Appendix IV applies to your business.
