The digitalization of investment procedures is an inevitable trend in administrative reform. However, following the promulgation of the Decree amending and supplementing regulations on investment registration procedures, many investors have encountered significant difficulties in digitally signing and submitting investment applications entirely through the electronic system. Although this is an important step forward in the digital transformation process of state management agencies, the actual implementation has revealed various obstacles that affect business planning.
New regulations on electronic submission of investment applications
Pursuant to Decree No. 239/2025/NĐ-CP, which amends and supplements Decree No. 31/2021/NĐ-CP guiding the implementation of certain provisions of the Law on Investment, effective from September 3, 2025, several new provisions on electronic submission of investment applications have been introduced as follows:
– When carrying out investment registration procedures, the electronic application must bear a valid digital signature and must ensure legal validity equivalent to the paper-based application.
Accordingly, any application without a valid digital signature shall be rejected or required to be resubmitted by the competent authority. This constitutes the initial step in the investment registration certificate application process, which must be completed before the investor submits the paper-based dossier directly to the Department of Finance.
Consequently, when the process of electronic submission encounters technical difficulties, the subsequent procedures for submission and presentation of the paper-based dossier are also delayed, thereby affecting the entire timeline for investment application processing.
Difficulties faced by investors
– Foreign investors face difficulties in registering a legally recognized digital signature in Vietnam.
– Technical errors in the electronic submission system – the website of the National Investment Information System frequently experiences interruptions, system hangs, or non-responsiveness, which disrupts the uploading and digital signing of documents.
Impacts on investors
– When the electronic system malfunctions or the application has not been duly verified (due to digital signature errors, file upload issues, or data synchronization failures), the investment registration authority cannot accept the dossier. This results in delays in the issuance of the Investment Registration Certificate (IRC) and Enterprise Registration Certificate (ERC).
– Delays in obtaining the IRC/ERC consequently lead to delays in subsequent stages of the project, such as opening an investment capital account, contributing capital, leasing land, applying for construction permits, or entering into contracts with partners. As a result, the project cannot proceed according to the committed investment schedule.
– Additional expenses may arise during the investment registration process, including costs for technical support services, digital signature registration, and administrative expenses incurred due to resubmission of dossiers or repeated travel.
Electronic investment application support services at Siglaw
Siglaw Firm provides comprehensive services supporting investors in the process of electronic investment registration, including:
– Consulting, preparing, and reviewing electronic applications in compliance with current regulations;
– Assisting in the registration and use of legally recognized digital signatures in Vietnam;
– Acting as an authorized representative to liaise with investment registration authorities, minimizing the risk of application rejection.
With extensive experience in handling hundreds of domestic and foreign investment applications, Siglaw is committed to helping investors save time and ensure that their applications are received promptly and deemed legally valid.
