Conditional Business Lines and Sub-Licenses

Quite a few people setting up a company think that simply registering an extra industry code on the enterprise registration certificate is enough to be permitted to do business in that line. For most ordinary lines that is true. But for conditional investment and business lines, registering the industry code is only the first step — the company must still go through another door, usually at another authority, before it may formally operate.

Short answer: the enterprise registration certificate confirms that the company legally exists and has registered an industry code, but it does not mean the company has met the conditions to do business in that line if the line is on the list of conditional investment and business lines. A conditional line needs an additional license, eligibility certificate, or separate declaration/approval procedure under sector law — issued by the sector authority, not by the Business Registration Office at the same time as the enterprise registration certificate.

Why is registering an industry code not enough to do business?

Under the Law on Investment, a conditional investment and business line is one in which carrying out investment and business activity must meet necessary conditions for reasons of national defense, national security, social order and safety, social morality and public health. These are areas where the State does not stop at recording that the company exists, but also wants to control whether the company has the capacity, facilities and professional personnel before it is allowed to actually operate.

For this reason, the process for a conditional line usually has two layers:

Layer 1 — enterprise registration: establishing the legal entity, industry codes, legal representative and head office. Issued by the Business Registration Office under the Department of Finance (formerly under the Department of Planning and Investment).
Layer 2 — sector license/eligibility certificate: confirming that the company (and the specific facility, people and equipment) meets the conditions of that line. Issued by the sector authority — which may be health, public security, construction, culture, etc., depending on the field.

A company that has registered the industry code “retail of pharmaceuticals” on its enterprise registration certificate but does not yet have a certificate of eligibility for pharmaceutical business is still not permitted to open for sale, even though the enterprise registration certificate records that industry code correctly.

The list of conditional business lines changes over time

The list of conditional investment and business lines is set in an appendix to the Law on Investment and reviewed and amended by the National Assembly from period to period — some lines are removed from the list (no longer conditional), and some are added. The 2025 Law on Investment (Law No. 143/2025/QH15, passed by the National Assembly on 11 December 2025) takes effect from 1 March 2026; the provisions on conditional investment and business lines apply from 1 July 2026, with a list that has been reviewed and cut compared with the list under the 2020 Law on Investment.

Because the list may change, a business needs to look up the current list when preparing its dossier — on the National Business Registration Portal or in the current legal text — instead of relying on old understanding of which lines are conditional and which are not. A line that needed a sub-license a few years ago may have had its conditions abolished, and vice versa.

Practical examples: each line has its own authority and dossier

Pharmaceutical business

Pharmaceutical business is a conditional investment and business line under the Law on Pharmacy. Besides an enterprise registration certificate with a pharmaceutical industry code, a pharmaceutical business facility (a pharmacy, a drug counter, a distribution company) must have a certificate of eligibility for pharmaceutical business issued by the state health management authority, with conditions on a professionally responsible person holding a suitable pharmacy practice certificate and on facilities meeting the standard. Law No. 44/2024/QH15 amending and supplementing the Law on Pharmacy (effective 1 July 2025) continues to provide that the certificate of eligibility for pharmaceutical business is a mandatory condition, separate from registration of the business line; it also adds conditions for facilities organizing pharmacy chains and selling medicines by e-commerce.

Food production and trading

Food production and trading is a conditional line under the Law on Food Safety. Besides the food industry code on the enterprise registration certificate, a food production or trading facility must also have a food safety eligibility certificate, except in a number of cases listed in clause 1, Article 12 of Decree No. 15/2018/NĐ-CP (for example trading in pre-packaged food, small-scale trading, facilities that already hold a valid HACCP, ISO 22000 or equivalent certification). The conditions for issuance include having registered a food business line in the enterprise registration certificate — meaning the two layers of paper are linked and not completely separate. The issuing authority depends on the product type: the health sector, the agriculture sector (now the Ministry of Agriculture and Environment), or the industry and trade sector. A facility that has registered a food production industry code but does not yet have a food safety eligibility certificate (and is not in an exempt case) still does not meet the conditions to operate lawfully.

Do not merge different kinds of paper

A common mistake is to assume that having a food safety eligibility certificate automatically allows business in every type of beverage, or that having a freight transport business license automatically allows carrying passengers. Each sector license is only valid within the scope granted — the right type of business, the right location, the right scope of activity registered with that licensing authority. A business expanding into a new conditional field, or opening a new business location for a conditional line, should look up and prepare the dossier for the corresponding sector license layer before formally operating, instead of assuming “having the enterprise registration certificate is enough”.

Fire prevention and fighting (PCCC) and the environmental permit: attached conditions, not “line licenses”

Many facilities confuse conditional business line licenses with conditions attached to a work or physical facility such as fire prevention and fighting (PCCC) or the environment. These two usually apply by the scale, area and use function of the work — not by the business industry code. A plant, a food production facility, or another conditional business facility may need both a license/eligibility certificate for the line (if that line is on the conditional list) and to complete PCCC design appraisal and acceptance under the fire prevention and fighting rules corresponding to the scale of the work. These two procedures are managed by two different systems of authorities and cannot substitute for one another: having a line license does not mean the work has met PCCC requirements, and vice versa.

When expanding lines, review from the start

A company already in operation that wants to add a new line to its enterprise registration certificate should first determine whether that line is on the list of conditional investment and business lines, and if so, which authority issues the sector license, what the dossier includes, and whether the professionally responsible person (if the line requires one) already holds a suitable certificate. This should be done before investing in premises and equipment, or signing a lease for a location for the new line — to avoid a situation where the business has invested and put up a sign but does not yet meet the conditions to operate lawfully, leading to suspension or penalty when the authorities inspect.

For lines with many layers of conditions (for example needing a sector license, PCCC, and conditions on location under local regulations), a business should make a list of the papers required, the issuing authority, and the expected time to complete each, instead of focusing only on the enterprise registration certificate and discovering a missing sub-license after it has already started operating.

How Thái Tín supports you

Thái Tín is the coordinating point that helps a business determine from the outset whether its intended line is on the list of conditional investment and business lines, and what else it needs to prepare beyond the enterprise registration certificate:

Looking up the current list of conditional lines corresponding to the business’s actual activity, before registering an industry code or adding a new line.
Connecting suitable sector partners for each sub-license layer (health, public security, PCCC, culture, etc.) depending on the specific line the business needs.
Tracking dossier progress across sector authorities, helping the business not miss any step before formally opening or opening a new location.

The sector authority is the place that reviews and issues licenses. Planning to do business in a conditional line or open an additional location? Send the intended line and location so Thái Tín can advise on the list of papers to prepare.

Questions and answers

Is registering an industry code on the enterprise registration certificate the same as being permitted to do business in that line?

Not on its own, if it is a conditional investment and business line. The enterprise registration certificate only confirms that the company legally exists and has registered that industry code under the Vietnam Standard Industrial Classification. For a conditional line, the company must meet the statutory conditions and be issued a license or eligibility certificate by the competent authority, or complete the declaration/approval procedure under that sector's own rules, before it may formally operate.

Is the list of conditional business lines fixed?

No. The list is set in an appendix to the Law on Investment and amended from period to period to cut or add lines. The 2025 Law on Investment (Law No. 143/2025/QH15) takes effect from 1 March 2026, with the provisions on conditional investment and business lines applying from 1 July 2026, with a list that has been reviewed and cut compared with the previous list. Because the list changes over time, a business should look up the current list when preparing its dossier, and not rely on old information.

Does a newly opened branch at another location have to reapply for the sector license?

Usually yes, for many conditional lines, because sector licenses (for example a certificate of eligibility for security and order, or a certificate of eligibility for pharmaceutical business) are usually tied to a specific business location that the sector authority has inspected, and do not automatically apply to another location even under the same legal entity. The specific rules of each sector should be checked for each new location before opening.

Are fire prevention and fighting (PCCC) and the environmental permit conditional business line licenses?

Fire prevention and fighting (PCCC) and the environment are usually conditions attached to the facility or work (for example area, use function, scale), which may apply in parallel with business line conditions, and are not always within the list of conditional investment and business lines. A facility may need both a business line license (if that line is conditional) and PCCC design appraisal and acceptance according to the scale of the work — the two types of procedure may be managed by two different authorities.

Legal basis · verification date

Verified 29 September 2026 · next review 29 December 2026. The content is general guidance and does not replace advice for a specific case.

Law on Investment No. 61/2020/QH14, on conditional investment and business lines and the principles for applying conditions for investment and business.
2025 Law on Investment, Law No. 143/2025/QH15, passed by the National Assembly on 11 December 2025 — effective from 1 March 2026; the provisions on conditional investment and business lines and conditions for investment and business apply from 1 July 2026, with the list of conditional lines in the appendix reviewed and cut compared with the previous list.
National Business Registration Portal (dangkykinhdoanh.gov.vn) — for looking up the Vietnam Standard Industrial Classification and conditional investment and business lines.
Law on Pharmacy No. 105/2016/QH13 and Law No. 44/2024/QH15 amending and supplementing a number of articles of the Law on Pharmacy (passed by the National Assembly on 21 November 2024, effective 1 July 2025) — providing that the certificate of eligibility for pharmaceutical business is issued by the state health management authority, separate from registration of the business line.
Law on Food Safety No. 55/2010/QH12, Article 34 (conditions for issuing the food safety eligibility certificate, including the condition of having a registered food business line), Article 35 (issuing authority by managing sector).
Decree No. 15/2018/NĐ-CP detailing the Law on Food Safety, Article 11 (subjects required to have the food safety eligibility certificate), Article 12 (cases not subject to issuance). In 2026, Decree No. 46/2026/NĐ-CP was issued to replace Decree No. 15/2018/NĐ-CP but was suspended by Resolution No. 15/2026/NQ-CP (6 April 2026); Decree No. 15/2018/NĐ-CP continues to apply until the amended Law on Food Safety and new guiding decrees take effect.
Decree No. 168/2025/NĐ-CP on enterprise registration — the provincial business registration authority is the Business Registration Office under the Department of Finance.