In brief

The Prime Minister of Vietnam has recently issued two new Decisions prescribing lists of strategic technologies and high technologies, effective 1 July 2026:

  • Decision No. 21/2026/QD-TTg introduces 10 strategic technologies and 30 strategic technology products, replacing Decision No. 1131/QD-TTg (“Decision 21”).
  • Decision No. 23/2026/QD-TTg introduces 70 high technologies prioritized for investment and development and 100 high-tech products encouraged for development, replacing Decision No. 38/2020/QD-TTg (“Decision 23”).

Businesses operating in technology, manufacturing, research and development (R&D), digital infrastructure, energy, semiconductors, and related sectors should review their investment projects to identify potential incentive opportunities and assess any implications arising from Decision 21 and Decision 23.

Recommended actions

  • Prepare a mapping matrix of current technologies, products, projects, and R&D pipelines against the lists under Decision 21 and Decision 23.
  • Review existing high-tech certificates and written recognition documents, including their validity periods and the legal basis of the applicable lists.
  • For new projects or applications, consider aligning technical descriptions, business plans, and incentive dossiers with the wording of the relevant list items.
  • For areas previously covered under Decision No. 1131/QD-TTg or Decision No. 38/2020/QD-TTg but no longer expressly included under Decision No. 21 or Decision No. 23, assess whether they may fall within a broader category or whether an alternative basis for incentives should be considered.
  • Monitor implementing guidance and any future updates to the lists issued by the Government and competent authorities.
      

In more detail

1. Background and key changes

The two new Decisions establish a two-tier structure for Vietnam’s technology policy framework, effective from 1 July 2026:

  • Decision 21 focuses on strategic technologies and strategic technology products. This is the more selective list, targeting technologies of foundational or long-term importance, as well as those linked to national technological self-reliance.
  • Decision 23 focuses on high technologies prioritized for investment and development and high-tech products encouraged for development. This is the broader list and is expected to serve as a key reference for high-tech certification, project classification, and incentive planning.

Legally, Decision 21 replaces Decision No. 1131/QD-TTg, while Decision 23 replaces Decision No. 38/2020/QD-TTg. Accordingly, new projects or applications from 1 July 2026 should be assessed against the new lists rather than relying solely on the previous framework.

The new framework may affect businesses, investors, R&D organizations, and manufacturers operating in Vietnam’s priority technology sectors, particularly those engaged in digital technologies, semiconductors, clean energy, life sciences, advanced manufacturing, strategic minerals, and strategic infrastructure.

2. Decision 21: strategic list and policy direction

Decision 21 introduces 10 strategic technology groups and 30 strategic technology products. Its objective is to identify areas Vietnam seeks to prioritize at a strategic level, particularly for R&D, domestic capability building, core technology supply chains, and national priority programs.

The notable product groups can be viewed in six clusters:

  • Digital & AI: LLMs, virtual assistants, digital twins, and cloud platforms
  • Connectivity & cybersecurity: blockchain, 5G/5G-Advanced, and critical infrastructure security
  • Advanced manufacturing & robotics: autonomous robots and smart manufacturing platforms
  • Life sciences & agriculture: vaccines, cell therapies, biosensors, and advanced breeding
  • Energy & climate technology: advanced materials, batteries, hydrogen, and carbon management
  • Strategic infrastructure & frontier technology: semiconductors, quantum, UAVs, satellites, and high-speed rail

3. Decision 23: broader applicable list for high technologies

Decision 23 approves 70 high technologies prioritized for investment and development and 100 high-tech products encouraged for development. Compared with Decision 21, this list is broader and more directly relevant to determining whether a technology, product, or project may qualify as a high technology or high-tech product.

Key technology and product groups include:

  • AI, data & digital infrastructure: AI, big data, cloud/edge/HPC, IoT, and blockchain
  • Semiconductors & advanced networks: chips, materials, 5G-A/6G, and cybersecurity platforms
  • Energy transition: renewable energy, storage, hydrogen, and carbon solutions
  • Advanced manufacturing & transport: robotics, autonomous systems, additive manufacturing, UAVs, and new-energy vehicles
  • Strategic minerals & advanced materials: rare earth processing and green/high-performance materials
  • Life sciences & smart agriculture: gene therapies, biologicals, organoids, and precision agriculture

4. Key differences compared with the previous lists

Businesses that have already mapped their projects or products against the previous lists should pay attention to the following representative changes:

A. Decision 21 compared with Decision No. 1131/QD-TTg: strategic technologies and strategic technology products

  • The classification of strategic technology products is no longer based on groups of strategic technologies. Instead, it is based on criteria such as fundamental importance, long-term value, and the need for national technological independence.
  • Newly introduced or more clearly emphasized items include high-speed and urban railway technologies; small modular reactors; green hydrogen, biofuels, battery energy storage systems, and carbon capture, utilization and storage; edge AI cameras; smart manufacturing platforms; personalized 3D medical manufacturing systems; and smart biosensors.
  • Items no longer expressly listed as standalone categories include the metaverse; digital assets, currencies, and cryptocurrencies; large-scale data centers; separate references to 6G/ORAN, core networks, and high-speed IP transmission; satellite ground stations and control systems; and standalone firewall/intrusion detection terminology.

B. Decision 23 compared with Decision No. 38/2020/QD-TTg: high technologies and encouraged high-tech products

  • The list of high technologies prioritized for investment and development has been significantly restructured and shortened, from approximately 99 items under Decision No. 38/2020/QD-TTg to 70 items under Decision 23, with many technologies merged, renamed, or narrowed.
  • Newly introduced or more clearly emphasized items include 5G-A and non-terrestrial networks; AI R&D platforms and virtual laboratories; national decentralized electronic identification (e-ID); semiconductor packaging, testing, and materials; high-speed railway systems; new-energy vehicles, battery energy storage systems (BESS), hydrogen, and next-generation battery technologies; strategic minerals and rare earth refining; organoids, brain–computer interfaces and neurotechnologies; and geospatial smart agriculture solutions.

Items no longer expressly listed as standalone categories include smart cards and readers; electronic BPO/KPO/ITO services; e-signature certification; automated digital content creation; cognitive radio; next-generation television technologies; ropeless elevator systems; large and complex vessels; wireless charging stations; standalone tidal, wave, and geothermal power generation; and certain specific materials, such as specialized paints, synthetic rubber, non-metallic reinforced concrete, and 500 kA aluminum electrolysis.

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Manh Hung Tran, Managing Partner, Ngoc Trung Tran, Senior Regulatory Advisor, and Trung Kien Nguyen, Tax Practitioner, have co-authored this legal update.

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