Nguyen Danh Cong – Partner
Nguyen Thi Thuy Tien – Associate
On 20 October 2026, the Government issued Decree No. 392/2026/ND-CP amending and supplementing certain Decrees relating to administrative procedures and business investment conditions in the field of security and order (“Decree 392”), which takes effect from 15 November 2026. Decree 392 was issued to reform administrative procedures and step up the delegation and decentralization of powers in state management, and to conform to the structure of the local Police as reorganized with from 1 March 2025.
Notable amendments concerning conditional business lines in terms of security and order include the following:
1. Narrowing of the list of conditional business lines in terms of security and order
Under Decree 392, compared with Decree No. 96/2016/ND-CP stipulating security and order conditions for certain conditional business investment lines, as amended and supplemented by Decree No. 56/2023/ND-CP and Decree No. 58/2026/ND-CP (“Decree 96”), the list of conditional business lines in terms of security and order has been reduced from 23 groups to 15 groups of business lines, specifically:
| No. | Business line | Scope | Security and order plan |
| 1 | Manufacture of seals | Seals bearing the National Emblem, symbol and seals without a symbol in accordance with the law on seals. | No |
| 2 | Trading in supporting tools (including repair) | Fabrication, manufacture, repair, import, export, and trading of supporting tools, ammunition and accessories thereof. | Yes |
| 3 | Trading in pyrotechnics of all kinds, except firecrackers | Fabrication, manufacture, import, export, and trading of fireworks, other types of pyrotechnics and pyrotechnic powder.
|
Yes |
| 4 | Pawn services | Lending money where the borrower must bring lawful assets to the establishment to be pledged.
|
No |
| 5 | Massage services | Use of physiotherapy methods to provide massage and traditional body massage for health care purposes. | No |
| 6 | Security guard services | Protection of persons, assets, targets and lawful activities of agencies, organizations and individuals.
|
No |
| 7 | Prize-winning games business | (a) Prize-winning electronic gaming machines for foreigners; (b) prize-winning games in casinos; (c) betting services.
|
Yes |
| 8 | Trading in industrial explosives | Manufacture, import, export, trading, recycling, storage, transportation and destruction.
|
Yes |
| 9 | Trading in explosive precursors | Manufacture, import, export, trading, storage, transportation and destruction.
|
Yes |
| 10 | Business lines using industrial explosives and explosive precursors
|
Use of industrial explosives for construction works, and for the exploration and exploitation of minerals, oil and gas. | Yes |
| 11 | Blasting services | Provision of services using industrial explosives to organizations and individuals with lawful needs.
|
Yes |
| 12 | Printing services, excluding printing of packaging without goods labels | Prepress, printing and post-press finishing to produce: publications; newspapers, magazines; forms, legal papers of state agencies, political organizations and socio-political organizations; anti-counterfeiting stamps; packaging, stamps and labels of pharmaceutical products, pharmaceutical chemicals, medicines and functional foods; invoices and valuable papers.
|
No |
| 13 | Karaoke and discotheque services | Karaoke: singing along to audio and video recording discs or other audio and video recording technologies. Discotheque: dancing at dance business establishments.
|
Applicable only to discotheque business |
| 14 | Accommodation services | Accommodation establishments under the Law on Tourism and other forms of accommodation rental (hourly or overnight), whether on land or on tourist accommodation vessels. | Applicable only to establishments that are enterprises |
| 15 | Military uniforms and equipment, military weapons, specialized equipment, means for the Military and the Police, and components and manufacturing technologies thereof | Military uniforms, military insignia, police insignia, badges, rank insignia and service numbers; handguns, shoulder-fired guns and ammunition; speed measuring devices with image recording, alcohol concentration measuring devices, drug testing devices, and devices for signal analysis and mobile information code scanning; specialized components and manufacturing technologies. | Applicable only to guns and ammunition |
2. Security and order assurance plan required for only 10 business lines
Decree 392 has narrowed the list of business lines required to have a security and order assurance plan from 13 to 10 business lines (see the table above).
As regards the basic contents of the plan, business establishments shall continue to comply with the provisions of Decree 96.
3. Three-tier decentralization of authority to issue Security and Order Certificates
Under Decree 392, the authority to issue Security and Order Certificates under Decree 96 is replaced in its entirety. Specifically, the new competent authorities comprise the following three (03) levels:
- The Police Department for Administrative Management of Social Order, Ministry of Public Security;
- The Police Division for Administrative Management of Social Order of the provincial-level Police;
- The Commune-level Police.
4. Procedures for issuance of Security and Order Certificates
Under Decree 392, the procedures for issuance of Security and Order Certificates are adjusted as follows:
a. Dossier submission: Each business establishment shall submit one (01) set of dossiers to the competent Police authority.
b.Processing time: No more than 04 working days (for new issuance) or 03 working days (for re-issuance) from the date of receipt of a complete and valid dossier.
5. Effectiveness and transitional provisions
Decree 392 takes effect from 15 November 2026. Accordingly:
a. Dossiers for new issuance or re-issuance of Security and Order Certificates that have been received and are under review before 15 November 2026: Shall continue to be processed in accordance with Decree 96 prior to its amendment.
b. Dossiers submitted on or after 15 November 2026: The new competent authorities, dossier components and forms shall apply.
Decree 392 does not require the re-issuance of Security and Order Certificates issued prior to its effective date.
6. Assessment and recommendations
Overall, Decree 392 represents a significant step forward in simplifying administrative procedures and easing regulatory requirements for businesses by narrowing the regulatory scope of conditional business lines in terms of security and order. In addition to decentralizing authority to three (3) levels to streamline the administrative apparatus, the Decree also substantially shortens dossier processing times.
Furthermore, Decree 392 continues to recognize the legal validity of existing Security and Order Certificates issued under Decree 96, while allowing dossiers under processing to proceed under the current procedures, thereby ensuring that business operations are not disrupted or interrupted in any way.
Accordingly, enterprises/establishments currently doing business in the field of security and order should prioritize:
- Cross-checking the actual operations of each establishment against the 15 groups of business lines and the exclusions to determine which establishments are required to obtain a Security and Order Certificate;
- Reviewing and updating the security and order assurance plan in line with the scope of operations, and keeping it readily available for inspection upon request by competent state authorities.
