Some legal notes when investing in industrial zones located in merged provinces (effective from July 1, 2025)

From July 1, 2025, the official implementation of Resolution No. 76/2025/UBTVQH15 issued by the Standing Committee of the National Assembly on administrative unit reorganization will result in the merger of several centrally governed provinces and cities. This change in administrative boundaries raises a number of legal concerns, especially for investors who are or will be implementing projects in industrial zones (IZs) located in affected localities. 

This article summarizes key legal issues to be considered during the process of investment surveying, registration, and project implementation in IZs located in newly merged provinces, including planning policies and investment procedures. 

1. Impacts on the implementation of administrative procedures 

After the merger, provincial-level administrative agencies – such as the Department of Finance or Management Boards of IZs – may change due to the newly defined administrative boundaries.  

• Before July 1, 2025: Investors submit applications to the competent authorities at the IZ’s original locality (e.g., Management Board of Binh Duong Industrial Zones). 

• After July 1, 2025: Applications will be received and processed by the new authority of the merged province (e.g., Binh Duong is merged into Ho Chi Minh City, then investment applications for Mapletree Binh Duong IZ will be handled by the Ho Chi Minh City IZ Management Board). 

In addition, during the transitional period, changes in forms, responsible personnel, and data transfer between the former and new authorities may result in longer-than-usual processing times.
Therefore, investors should carefully verify the newly assigned competent authorities, updated transaction locations, and revised administrative procedures to avoid errors in submitting applications, which may lead to unnecessary delays and costs. 

2. Update project addresses and administrative place 

Following the merger, names of administrative units (districts, provinces, cities) may change. When indicating project site addresses or IZ locations, investors must ensure that:  

• The address is consistent with the officially published new administrative names; 

• Outdated or abolished place names are not used. 

For projects that were licensed prior to July 1, 2025, under Official Letter No. 4370/BTC-DNTN dated April 5, 2025, issued by the Ministry of Finance, enterprises may continue to use their current business registration certificates and other operation licenses without being required to immediately update their addresses. Address updates may be made voluntarily or concurrently with other change registration procedures. 

3. Review the legal status and planning of the IZ after the merger 

A core issue following the merger is the adjustment of socio-economic development master plans and land use plans to fit the new administrative framework.  

Investors should: 

• Proactively request detailed information from the IZ infrastructure investor or local authorities regarding the review and possible adjustments of the IZ’s 1/500 zoning plan. This helps investors assess potential impacts on land lease areas, land use purposes, and public utility infrastructure. 

• Carefully verify legal documents related to the IZ investor’s land use rights, particularly documents on land-use conversion approval and land lease decisions. In the context of administrative transitions, delays or errors in transferring cadastral records may arise and should be cautiously monitored and confirmed by the new competent authority. 

• Stay informed about new pricing policies, as land price frameworks and infrastructure usage fees may be adjusted post-merger. 

• Carefully assess the industrial development orientation of each province/city after the merger to select appropriate business sectors for investment, thereby increasing the likelihood of investment policy approval and optimizing access to infrastructure, human resources, and sector-specific incentive policies. 

4. Impacts on investment incentives and business support policies 

• Each locality previously applied its own investment incentives and business support policies to attract investment. After the merger, these may be unified or revised to align with the development orientation of the new administrative unit. Investors should consult with the new local authorities to confirm whether previous incentive policies will continue. If changes are introduced, investors must understand the transition mechanisms and timelines to avoid disruption. 

• Labor and social welfare policies (e.g., regional minimum wages, social insurance schemes, support programs) may differ among the pre-merger localities. Changes could directly affect human resource budgets and employee benefits. Investors need to stay updated and adjust labor planning accordingly. 

5. Recommendations 

To minimize risks and maximize opportunities in this new context, we recommend that investors: 

• Proactively monitor legal developments and updated administrative procedures; 

• Carefully review land lease contracts and investment incentive decisions; 

• Work closely with IZ infrastructure investors and local authorities to promptly adjust investment plans and resolve any issues that arise; 

• Seek legal consultation to ensure that investment documents comply with the new administrative nomenclature and planning, and to properly assess and mitigate risks. 

The administrative unit reorganization is a strategic step aimed at streamlining the state apparatus and promoting regional development. For investors targeting IZs in merged localities, it is particularly important to pay close attention to administrative procedures, planning, and the proper use of administrative names to avoid unnecessary risks. With legal awareness, accurate information, and a proactive approach, investors can seize sustainable development opportunities in this new phase. 

Date written: 20/07/2025

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