Global Vietnam Lawyers would like to introduce our valued readers to an article by Mr. Tran Minh Quyet titled “Electronic signatures in investment registration dossiers: Inevitability and practical challenges” published in The Saigon Times, No.3-2026 (1.831) on January 15, 2026.
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Digital transformation is accelerating in Vietnam, resulting in significant changes in the way investment dossiers are managed and processed. One notable milestone is the regulation on mandatory use of electronic signatures in investment registration dossiers. This measure is not merely a technical solution but a strategic move aimed at enhancing transparency, security, and efficiency in investment activities.
Mandatory requirement effective from September 2025
Pursuant to Decree No. 239/2025/ND-CP, from September 3th 2025, dossiers submitted for investment procedures must include an electronic version bearing a valid digital signature. This regulation affirms that electronic dossiers are as legally valid as paper dossiers, while allowing investors to choose among in-person submission, online submission, or submission via public postal services. However, in the event of any discrepancy between the paper and electronic versions, the paper dossier prevails as the final legal basis.
The adoption of electronic signatures offers a range of tangible benefits. Businesses can significantly save time and costs by eliminating the need for printing, physical delivery, and storage of paper dossiers. Digital signatures also enhance transparency and data security, reducing the risk of forgery and fraud. In particular, for foreign investors, the ability to sign and submit dossiers remotely helps minimize geographical barriers and transaction costs.
Practical challenges in implementation
Despite its advantages, the implementation of electronic signatures still faces a number of challenges. Some electronic dossier receiving systems remain unstable, resulting in technical errors or interruptions that may affect project timelines. Foreign investors may also encounter difficulties in having foreign-issued digital certificates and signatures recognized in Vietnam, which can lead to dossier rejection if the signature is deemed invalid. In addition, the risk of inconsistencies between paper and electronic versions persists, requiring enterprises to maintain strict control over their digitization processes.
Although law mandates digital signatures for electronic dossiers, certain investment registration agencies have applied flexible mechanisms to support investors whose legal entities have not yet been established in Vietnam. In such cases, investors may submit paper dossiers to expedite the grant of in-principal approval of investment or the issuance of investment registration certificates. Once the legal entity is established and assigned an enterprise code, the use of digital signatures becomes mandatory for subsequent procedures. This pragmatic approach helps ease the burden on foreign investors while demonstrating the State authorities’ flexibility in fostering a more investor-friendly environment.
Solutions and recommendations for enterprises
To adapt to the new regulatory requirements, enterprises should proactively standardize their internal processes. First, they must ensure the use of valid digital signatures by registering with reputable certification service providers such as VNPT-CA, Viettel-CA, or FPT-CA. At the same time, enterprises should carefully verify consistency between paper and electronic versions before applying digital signatures, in order to avoid discrepancies that could give rise to legal risks.
The mandatory use of electronic signatures in investment dossiers represents a critical step toward making Vietnam’s investment ecosystem faster, more transparent, and more secure, while aligning it with international standards for electronic transactions. To turn this legal requirement into a competitive advantage, enterprises need to invest in technical infrastructure and staff training, and closely coordinate with legal advisors. Only then can digital transformation in the investment sector truly deliver optimal results.
