Vietnam raises general merger notification thresholds

Vietnam has temporarily raised several general economic concentration notification thresholds under Resolution No. 66.18 of the Government dated 18 May 2026 (Resolution 66/2026), a practical change for M&A transactions as fewer deals should be caught solely by Vietnamese assets, Vietnamese turnover or transaction value.

1.         What has changed?

Under Article 13.1 of Decree 35/2020, enterprises participating in an economic concentration generally had to notify the National Competition Commission before implementation if one of four general filing thresholds was met. Resolution 66 increases the first three, while leaving the combined market share threshold unchanged

Threshold	Decree 35/2020	Resolution 66/2026
Assets in Vietnam	VND 3,000 billion	VND 6,000 billion
Sales revenue or purchase turnover in Vietnam	VND 3,000 billion	VND 6,000 billion
Transaction value	VND 1,000 billion	VND 2,000 billion
Combined market share in the relevant market	20%	20%

2.         Notification thresholds applicable to regulated sectors: no apparent change

Resolution 66/2026 does not revise the separate notification thresholds for credit institutions, insurance enterprises and securities companies, which are generally much higher than the general thresholds.

3.         Timing and temporary effect

The revised thresholds take effect from 1 July 2026 under Article 7.1 of Resolution 66/2026 and to apply only until 28 February 2027, unless superseded earlier under Article 7.4. Resolution 66 also identifies Article 13 of Decree 35/2026 for amendment, suggesting that a further legal instrument will be needed if the higher thresholds are to continue after Resolution 66/2026 expires.

This temporary effect matters. Businesses planning transactions in late 2026 or early 2027 should confirm the applicable thresholds at signing and again before closing, especially where competition clearance is a condition precedent.

This post is written by Ha Thanh Phuc.