• Policy shift promotes greater centralization, faster decision-making
• Incomplete project proposals face early regulatory scrutiny and delays

In April 2026, UK-based stock market index provider FTSE Russell confirmed Vietnam’s upgrade from Frontier Market to Secondary Emerging Market.[1] Effective from September 2026, the upgrade validates Vietnam’s progress in reforming its market infrastructure and is expected by FTSE Russell to boost foreign inflows by up to USD 6bn.[2]

The reclassification comes against a backdrop of steady economic growth, with Vietnam’s economy expanding by over 7% per year in 2024 and 2025, compared with around 5% in Indonesia and below 3% in Thailand, according to the International Monetary Fund (IMF).[3]

Capital flowing into Vietnam has increasingly been directed toward sectors tied to long‑term national priorities, such as manufacturing, supply‑chain infrastructure, energy transition, and higher‑value industrial capacity. For instance, Vietnam is seeing strong investment in AI data centres, with capacity set to almost double from 525 MW in 2025 to 1,000 MW by 2030.[4]

In December 2024, NVIDIA signed an agreement with the Vietnamese government to jointly set up an AI research and development centre and expand an AI centre owned by the Vietnamese military-owned Viettel Group.[5] In April 2025, The LEGO Group celebrated the opening of a 44-hectare, USD 1 billion manufacturing facility in Binh Duong province, Vietnam, which is the group’s most eco-friendly factory to date.[6]

Meanwhile, the 14^th National Congress of the Communist Party of Vietnam, which concluded in January 2026 and reaffirmed Tô Lâm’s leadership through his re‑election as General Secretary, advocated for a greater focus on project delivery, a greater centralization of power and faster decision-making across ministries and regulators.[7]

Together with the capital flows described above, this environment could contribute to stronger deal flow. It is also expected to bring a more consistent approach to governance and enforcement across agencies and investment projects.

Previously, years of heightened anti‑corruption enforcement had made officials more cautious about taking decisions, with a tendency in some cases to delay or avoid decisions altogether for fear of personal accountability associated with project approvals.

Now greater weight is placed on whether decisions are taken in a timely manner and can be clearly attributed to responsible officials. Post-Congress guidance has reportedly stressed that officials must “dare to act and dare to take responsibility.”[8]

According to an IMF report from October 2025, “the ongoing institutional restructuring is expected to streamline decision-making and improve efficiency.”[9]

As a result, scrutiny is increasingly likely to be front-loaded in the project lifecycle. Where projects previously relied on post‑approval adjustments or informal accommodation to address weaknesses, there is now less tolerance for unresolved issues at the approval stage.

Project proposals – especially those involving infrastructure, energy, manufacturing, or other capital‑intensive sectors – with unclear ownership structures, incomplete technical preparation, or unrealistic timelines could attract hesitation or requests for clarification at an early stage, rather than being allowed to proceed and corrected later.

Case Study: Informal Access Versus Execution Capability

In a recent due diligence assignment for a foreign energy corporation considering participation in a project in Vietnam, Blackpeak assessed a local partner positioned as the project sponsor.

The partner’s perceived strength lay in its claimed institutional access and familiarity with the approval environment, including purported connections to the Ministry of Public Security, one of the most powerful ministries in Vietnam. While our inquiries found no indication that these connections were used in any illicit manner, Blackpeak sources indicated that the partner had a limited track record in delivering complex energy infrastructure projects and appeared to rely more on informal political access than demonstrable project capability for project approval.

Previously, such gaps might have been expected to be resolved over time through relationship‑driven flexibility. In today’s environment, where approvals are expected to move faster and scrutiny is increasingly front‑loaded, these issues are more likely to delay projects at an early stage of development.

As institutional decision‑making becomes more formal and regulatory scrutiny intensifies, investors should incorporate the following angles into a more integrated due‑diligence framework:

• Partner Due Diligence:

As reliance on informal arrangements declines, partner due diligence is less about validating who a local counterparty knows and more about what they have demonstrably delivered. The focus is shifting from political access or personal relationships to verifiable execution, including delivery track records, internal governance, financial resilience, and experience managing complex projects within regulatory and time constraints.

• Decision-Pathway Analysis:

Beyond having a general understanding of the regulatory environment and different laws governing an industry, investors need to understand how decisions that directly affect their project would actually flow through ministries, regulators, and government committees. As Vietnam moves toward faster decision‑making across agencies, decision‑pathway analysis helps investors identify where approval processes have been streamlined or compressed, where officials’ discretion has narrowed, and where bottlenecks may persist.

• Approval‑Readiness Test for Project Proposals:

Greater emphasis should be placed on addressing key assumptions in project proposals upfront to facilitate approvals. Key areas that investors need to pay attention to include realistic timelines, land ownership and use rights, technical feasibility, financing structures, and required licensing. In the past, those areas might have been treated as manageable uncertainties that can be revisited once an application enters the approval process, or after approval is granted. In the current environment, unclear assumptions are more likely to slow or stall approvals.

As Vietnam’s investment environment becomes more open, it will also become more exacting.

The system now places greater emphasis on clarity, readiness, and execution discipline, with diminishing tolerance for informal, post-approval fixes. Investors who focus on partner capability, approval pathway, and project readiness are more likely to mitigate execution risk and maintain project momentum.

[1]     https://www.vietnam-briefing.com/news/vietnam-secures-ftse-emerging-market-status-upgrade.html/

[2]     https://www.reuters.com/world/asia-pacific/vietnam-says-ftse-russells-emerging-market-status-confirmation-is-significant-2026-04-08/

[3]     https://www.imf.org/-/media/files/publications/cr/2025/english/1vnmea2025001-source-pdf.pdf

https://www.imf.org/en/news/articles/2026/01/21/pr-26010-indnonesia-imf-executive-board-concludes-2025-article-iv-consultation

https://www.bot.or.th/en/news-and-media/news/news-20260214.html

[4]     https://en.vietnamplus.vn/vietnam-emerges-as-new-hotspot-for-ai-data-centre-investment-post332260.vnp

https://en.vneconomy.vn/vietnams-data-center-capacity-set-to-near-1000mw-by-2030.htm

[5]     https://thediplomat.com/2024/12/vietnam-signs-agreement-with-nvidia-to-establish-ai-research-and-data-centers/

[6]     https://www.lego.com/en-us/aboutus/news/2025/april/the-lego-group-opens-new-state-of-the-art-factory-in-Vietnam?locale=en-us

[7]     https://thediplomat.com/2026/01/vietnams-14th-national-congress-power-reform-and-the-next-political-generation/

[8]    https://thuvienphapluat.vn/chinh-sach-phap-luat-moi/vn/ho-tro-phap-luat/chinh-sach-moi/111418/tang-cuong-trien-khai-khuyen-khich-can-bo-dam-nghi-dam-lam-vi-loi-ich-chung-trong-viec-thuc-hien-nghi-quyet-dai-hoi-xiv-cua-dang

[9]     https://www.imf.org/-/media/files/publications/cr/2025/english/1vnmea2025001-source-pdf.pdf