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Legal Update: April 2026

1. New Law on Enforcement of Civil Judgments

The National Assembly has recently adopted Law No. 106/2025/QH15 on Enforcement of Civil Judgments (the “LECJ 2025”). The LECJ 2025 will be effective on 1 July 2026, except for some provisions that became effective on 20 January 2026, and will replace the Law on Enforcement of Civil Judgments 2008, as amended (“LECJ 2008”). Some notable points of the LECJ 2025 are summarised below.

Enforceable judgments and decisions

Under the LECJ 2025, the following types of judgments and decisions are subject to enforcement:

  • Court’s judgments and decisions on civil matters, bankruptcy; monetary penalties, confiscation of assets, recovery of money or assets obtained through unlawful gains, disposal of exhibits and assets, court fees and rulings on civil matters in criminal judgments and decisions; rulings on assets in judgments and decisions on administrative cases, including: (a) legally effective judgments and decisions (first-instance judgments and decisions, or portions thereof, which are not appealed or protested according to appellate procedures; appellate judgments and decisions; cassation or re-opening decisions; decisions of the Supreme People’s Court to be executed in accordance with the law; civil judgments and decisions by foreign courts, foreign arbitral awards which have been recognized and permitted for enforcement in Vietnam by Vietnamese courts; bankruptcy declaration decisions); (b) judgments and decisions being enforced immediately, notwithstanding that they may be appealed or protested, in accordance with the Civil Procedures Code; and (c) decisions on the application of interim measures;
  • Decisions resolving competition cases, and decisions on complaints against such decisions, that relate to the property of the party subject to enforcement;
  • Arbitral awards and decisions on the application of interim measures by arbitral tribunals in accordance with the Law on Commercial Arbitration;
  • Decisions applying diversion measures for compensation by competent authorities in accordance with the Law on Juvenile Justice; and
  • Other judgments and decisions enforceable in accordance with the

Enforcement procedures

The LECJ 2025 provides general procedures for the enforcement of judgments and decisions, while leaving specific details for future implementing regulations. For instance, the law does not specify the required contents of a request for enforcement or the documents that must be submitted with such request.

Except for cases where heads of civil enforcement agencies proactively issue enforcement decisions under Article 33.2 of the LECJ 2025, the judgment debtor and the judgment creditor (collectively, the “Involved Parties”) may request enforcement of a judgment or a decision. The default statute of limitation for requesting enforcement is 05 years from the date the judgment or decision takes legal effect or the obligation becomes due.

Judgment debtors will have a 10-day voluntary enforcement period, from the date they are properly notified of the enforcement decision (excluding cases enforcing decisions on interim measures). Additionally, the Involved Parties and persons with related rights and obligations may enter into a written agreement on enforcement. If an involved party fail to perform such agreement, the other parties may request enforcement of the remaining unperformed obligations under the judgment/decision.

Measures to secure and coerce judgment enforcement

The LECJ 2025 empowers enforcement officers (“Chấp hành viên” in Vietnamese) and heads of civil enforcement agencies to apply judgment enforcement security measures, including: (a) freezing of accounts and assets in places of deposit; (b) temporary suspension of transaction, temporary suspension of registration, transfer of ownership or use rights, or change of the current status of assets; (c) temporary seizure of assets and documents; and (d) temporary suspension of exit. Enforcement officers may, at their own discretion or upon written request by the Involved Parties, apply the measures (a), (b) and (c). Meanwhile, heads of civil enforcement agencies may apply measure (d).

The LECJ 2025 also provides for judgment enforcement coercive measures and the grounds for their application. Generally, such measures may be applied where the judgment debtor has the capacity to enforce the judgment/decision but fails to do so voluntarily within the prescribed time limit. However, where it is necessary to prevent the dispersal or destruction of assets, other acts aimed at evading enforcement, coercive measures may be applied immediately.

Civil enforcement offices and bailiffs

The LECJ 2025 introduces the framework for civil enforcement offices and bailiffs (“Thừa hành viên” in Vietnamese) to carry out judgment enforcement. Bailiffs are appointed by the Chairperson of the provincial People’s Committee and may establish or co-establish a civil enforcement office in the form of a private enterprise or a partnership, or work under an employment contract with a civil enforcement office.

Civil enforcement offices organize enforcement based on service contracts agreed with the judgment creditor. The standard enforcement procedures under the LECJ 2025 also apply in these cases; however, the authority of heads of civil enforcement offices and bailiffs is more limited. Specifically, they are not permitted to: (i) apply provisions concerning entrustment of judgment enforcement and entrustment of assets handling, (ii) apply judgment enforcement security and/or coercive measures, and (iii) handle cases where civil enforcement agencies are required to proactively issue enforcement decisions.

2. Regulations on planning

On 9 March 2026, the Government issued Decree No. 70/2026/ND-CP (“Decree 70”) implementing the 2025 Law on Planning. Decree 70 took effect from 9 March 2026, with the exception of certain provisions, and replaced Decree No. 37/2019/ND-CP dated 7 May 2019. Below are some key provisions of Decree 70.

Planning systems

The 2025 Law on Planning introduces a planning system comprising six categories: national level planning (including national master planning, national marine spatial planning, national land use planning, and sectoral planning); regional planning; provincial planning; detailed sectoral planning; urban and rural planning; and special administrative-economic zone planning.

Decree 70 requires that (i) the national master planning must be submitted to the National Assembly for approval at its first session in the first year of the planning period, while the national marine spatial planning and national land use planning must be submitted within that first year; (ii) regional plannings and sectoral plannings must be submitted for approval within 3 months after the national master planning is approved, and (iii) provincial planning must be submitted for approval within 3 months after the relevant regional planning is approved. An extension of up to 6 months may be granted under special circumstances.

Assessing the conformity of a project with planning

Under the 2025 Law on Planning, planning serves as the basis for assessing a project’s conformity during the appraisal for investment policy approvals or investment decisions. Decree 70 provides detailed guidance on matching specific projects with their corresponding applicable planning. For example, for residential housing projects and urban zone development projects, the competent State agency will assess the project’s conformity with the relevant approved provincial planning or the urban and rural planning.

When performing an assessment, the competent State authority shall evaluate the project against the relevant viewpoints, vision, objectives, development orientations or directions, spatial arrangement or distribution directions stated in the planning. For a project having construction component(s), the assessment of the project’s conformity with planning shall be conducted in accordance with construction laws.

Decree 70 provides transitional provisions which will affect the assessment of the project’s conformity with planning in practice, specifically:

  • Projects for which the investment policy approval or decision has been issued before 09 March 2026 (i.e. the effective date of Decree 70) shall continue to be implemented in accordance with the relevant laws;
  • Projects for which the appraisal of the investment policy approval or investment decision was completed before 09 March 2026 shall continue to obtain the approval or decision in accordance with laws in force prior to that date;
  • Projects for which the appraisal of the investment policy approval or investment decision has not been completed before 09 March 2026 must undergo conformity assessment in accordance with the provisions of Decree 70;
  • For projects subject to assessment of the conformity with national sectoral plannings or technical and specialised plannings under the 2017 Law on Planning, which have been approved before 09 March 2026, the assessment of the project’s conformity shall comply with the provisions of Decree 70 until the expiry of the planning period or the planning is replaced by the new one (in certain circumstances).

Further clarification on the determination of the applicable planning

Decree 70 establishes grounds to determine which planning prevails in the event of inconsistency between regional and sectoral plannings, provincial and detailed sectoral plannings, or between plannings formulated by different ministries. It also provides the procedures for determining the prevailing planning in the case of inconsistencies.

3. Prize-winning electronic games

On 27 March 2026, the Government issued Decree No. 86/2026/ND-CP (“Decree 86”) amending Decree No. 121/2021/ND-CP dated 27 December 2021 on business in prize-winning electronic games for foreigners (“Decree 121”). Decree 86 takes effect from 15 May 2026. Below are some notable amendments of Decree 86.

Issuance of E-Gaming Business Certificate

Under Decree 121, one of the conditions for an enterprise applying for a Certificate of satisfaction of conditions for conducting business in prize-winning electronic games (“E-Gaming Business Certificate”) is that the enterprise must have charter capital of VND 500 billion or more. Decree 86 amends this by providing that (a) the enterprise must have both charter capital and equity capital of at least VND 500 billion, and (b) if the enterprise applies for E-Gaming Business Certificates for multiple tourism accommodation establishments, its charter capital and equity capital must simultaneously increase by an additional VND 500 billion for each E-Gaming Business Certificate.

Regarding the condition on tourism accommodation establishments, Decree 86 clarifies that tourism accommodation establishments include hotels (excluding floating hotels), tourist villas and tourist apartments, which have been ranked at 5-star class by the competent State agency.

Decree 86 increases the time period within which the Ministry of Finance (MOF) must approve an application file for the E-Gaming Business Certificate from 60 days to 90 days from the date of receipt of a valid application dossier. In case of refusal, the MOF must issue a written refusal explaining the reasons for its refusal.

Decree 86 removes the requirement under Decree 121 that enterprises must register the line of business in prize-winning electronic games with the business registration agency before they apply for an E-Gaming Business Certificate, and instead requires enterprises to notify the business registration agency about a change in the line of business after obtaining this Certificate and before conducting the business.

Stricter conditions for managers and operators

Decree 86 imposes stricter conditions for managers and operators of business locations. Accordingly, they must (a) have full civil act capacity; (b) not be persons who are currently under criminal prosecution, serving imprisonment sentence or being prohibited by the Court from holding positions or practising in the field of prize-winning electronic games; and (c) hold at least a bachelor’s degree and have at least 3 years of experience in the management and operation of prize-winning electronic game business.

Internal regulations of enterprises

Decree 86 requires enterprises to formulate and issue their internal regulations on not only anti-money laundering,  preventing proliferation and financing of weapons of mass destruction, but also preventing and financing of terrorism according to the relevant laws and regulations. Further, enterprises are also required to formulate their rules for the settlement of disputes between players and the enterprise arising from gaming operations at the business location, and publicly post such rules at their business locations or provide them to players in the form of pamphlets.

4. Corporate income tax

On 12 March 2026, the Ministry of Finance issued Circular No. 20/2026/TT-BTC (“Circular 20”) detailing a number of articles of the Law on Corporate Income Tax and its implementing Decree No. 320/2025/ND-CP (“Decree 320”) dated 15 December 2025. Circular 20 became effective on 12 March 2026 and applied from the 2025 corporate income tax (CIT) calculation period onward.

Circular 20 replaces Circular No. 78/2014/TT-BTC dated 18 June 2014 (as amended) on the same matter, and repeals provisions on CIT in Circular No. 103/2014/TT-BTC dated 6 August 2014 guiding tax obligations for foreign organisations and individuals doing business in Vietnam or having income in Vietnam (except for Article 13.1(b.11)).

Dossiers for entitlement to tax incentives

Circular 20 provides that the procedures and dossiers for entitlement to CIT incentives must comply with the laws on tax administration. Enterprises are required to self-assess whether they satisfy the conditions for CIT incentives or not.

If examinations or inspections detect and conclude that an enterprise fails to satisfy the conditions for CIT incentives, the competent agency shall collect tax arrears, calculate late payment charges and impose tax penalties in accordance with laws.

Registered investment capital for expansion investment projects

Circular 20 imposes an obligation on enterprises, upon implementing an expansion investment project, to submit a written notification of the registered investment capital of that project to the directly managing tax agency at the same time as the submission of the CIT finalization declaration of the year in which the expansion investment project is implemented. Additionally, the enterprise must notify the tax agency of any changes to the registered investment capital.

CIT payment by foreign contractors

Circular 20 provides guidelines to the payment of CIT applicable to foreign enterprises with or without permanent establishments in Vietnam, including those engaged in e-commerce activities or digital platform-based business (“foreign contractors and foreign sub-contractors”, collectively) that conduct business in Vietnam or deriving income in Vietnam on the basis of contracts, agreements, or commitments entered into between the foreign contractor and Vietnamese organizations or individuals, or between the foreign contractor and foreign sub-contractors for the performance of a part of the work under a contractor agreement.

However, these guidelines shall not apply to, among others: (i) foreign contractors/sub-contractors supplying certain services that are performed outside Vietnam (as listed in Circular 20); and (ii) foreign enterprises transferring capital in the form of intra-group restructuring transactions which do not result in a change in the ultimate parent company of the parties involved which directly or indirectly own enterprises in Vietnam and no income arises (if all conditions set out in Article 7.2(m) of Circular 20 are met).

The amount of CIT payable shall be calculated by multiplying the CIT-taxable turnover by the percentage (%) of taxable turnover  (as specified in Decree 320). CIT-taxable turnover refers to the total turnover received by the foreign contractor or foreign sub-contractor without deduction of taxes payable. CIT-taxable turnover includes all costs that are paid by the Vietnamese party on behalf of the foreign contractor or foreign sub-contractor (if any).

Circular 20 also clarifies the determination of CIT-taxable turnover in some specific cases such as lease of machinery, equipment and means of transportation; reinsurance services; shipping and air transport; transfer of securities and deposit certificates; and loan interest.