On 26 August 2025, the Ministry of Finance issued Decision No. 2915/QĐ-BTC, which will take effect from 15 September 2025, introducing amendments and abolishment of several administrative procedures under its management to support innovative startup investment funds. This regulatory reform is a clear signal from the Vietnamese Government of its commitment to reducing administrative burdens and facilitating capital flow to innovation-driven businesses.
Decision 2915 targets cumbersome notification requirements for startup investment funds and seeks to simplify how they interact with the provincial registration authorities and the Ministry of Finance. Among the key changes are modifications to five provincial-level procedures: notifying establishment, capital increase/decrease, extension of operation period, dissolution (including results), and transfer of investors’ capital contributions.
Simultaneously, it abolishes the central-level requirement to publish information (such as establishment, changes of capital, operation extension, dissolution etc.) on the National Information Portal for SMEs and innovative startups. This removes duplication, reduces delays, and lowers compliance cost for fund managers. Under the new regime, provincial-level business registration agencies become the focal point for receipt and processing of applications. They are also responsible for forwarding necessary data to the Ministry of Finance solely for monitoring purposes.
A further modernising measure is the option for applications to be submitted online via the systems of the provincial People’s Committee or directly at the business registration agency in the locality of the fund’s head office. This enhances transparency, speeds up procedures, and supports digital transformation efforts across regulatory bodies.
All the amended and supplemented procedures under Decision 2915 are subject to a 15-working-day time limit for processing from the date a complete and valid application is received. If an application is found invalid or incomplete, the receiving agency must issue a written notice explaining the deficiencies and specific guidance on corrections.
With over three decades of observation of regulatory cycles in Vietnam, we see Decision 2915 as particularly significant for several reasons:
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Lower Barriers for Innovation Funds: Startup investment funds often struggled with heavy procedural obligations, especially publication and reporting. Removal of such central-level publication duties eases the administrative load and reduces risk in non-compliance.
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Speed & Certainty: The 15-working-day deadline imposes predictable timing for approvals, which is essential for fund managers and investors planning launches, deal structuring, or capital commitments.
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Decentralisation & Localisation: Shifting responsibilities to provincial agencies improves accessibility for funds headquartered outside Hanoi. It reduces reliance on central authorities and can accelerate processes at local levels.
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Digital Transformation & Transparency: The option of online submission aligns with broader Government mandates on e-government. This should reduce in-person visits, minimize document handling inefficiencies, and increase procedural transparency.
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Strategic Positioning for Startups & SMEs: Startups, especially those recognised as “innovative funds,” will find it easier to form, adjust, extend, or dissolve operations. They can allocate more resources toward innovation and investment rather than regulatory overhead.
Although the reforms are beneficial, several caveats deserve attention:
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Completeness and Validity of Application: With stricter timeframes, any ambiguity in documentation or omissions become riskier. Funds must have their dossier preparation reviewed carefully.
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Interpretation and Implementation Differences: Provinces may interpret notification requirements, online submission modalities, and dossier validation differently. Legal counsel should provide local guidance.
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Monitoring Obligations Remain: Even though publication duty is removed for central portal, data forwarding and State monitoring responsibilities persist. Funds must maintain records and ensure compliance if audits or checks arise.
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Transition Period: For funds in process or recently established under old procedures, understanding which rules apply during overlap or transitional phases will be important.
Decision 2915/QĐ-BTC marks a meaningful step in Vietnam’s regulatory reform for supporting innovation and startup ecosystem. It shows maturity in policy design, focusing on practical relief for administrative burdens while strengthening transparency and accountability. For domestic and foreign investors alike, the Decree opens a more predictable and accessible path to structuring innovative startup investment funds.
Legal advisers should review existing procedures, adjust internal workflows, and ensure that clients are ready to leverage these changes from 15 September 2025. Doing so will maximize the benefit of the new reforms—both in speed and regulatory certainty.
