Vietnam’s healthcare sector is rapidly developing, leading to increasing demand for hospital investment. This is a key factor in the national healthcare infrastructure. The Law on Medical Examination and Treatment 2023 and its guiding documents up to 2025 have undergone significant changes. Investors, especially foreign ones, must thoroughly understand the legal framework, technical standards, and current incentives to ensure effective implementation.

See more: Forming a Medical Equipment Joint Venture in Vietnam: Strategic Guide for Foreign Partners

1. Legal Framework Overview

Update on Investment Law 2025

The Investment Law on hospital construction in 2025 has introduced important amendments to facilitate investment while ensuring the quality of medical services. Additional relevant legal documents include:

• Investment Law No. 61/2020/QH14, amended by Law No. 72/2022/QH15.
• Construction Law No. 50/2014/QH13, amended by Law No. 62/2020/QH14.
• Law on Medical Examination and Treatment No. 15/2023/QH15 (effective from 01/01/2024).
• Decree 96/2023/ND-CP: Detailing the implementation of certain provisions of the Law on Medical Examination and Treatment.
• Circular 23/2021/TT-BYT: Specifying the list of minimum medical equipment.
• QCVN 01:2021/BYT: National technical regulation on healthcare facilities.
• Circular 147/2020/TT-BCA: Fire prevention and fighting regulations for medical facilities.
• Circular 36/2012/TT-BYT: Ensuring accessibility for people with disabilities at medical facilities.

2. Basic Investment Requirements

2.1 Minimum Investment Capital

According to Article 41 of Decree 96/2023/ND-CP:

• General hospitals (minimum 30 beds)
• Large-scale general hospitals (over 500 beds):
  • Minimum investment capital: VND 300 billion.
  • Expenditures: basic construction costs, high-tech medical equipment, auxiliary infrastructure systems, training, staff salaries, and operation for the initial 6–12 months.
  • Suitable for investors with large financial capacity aiming to operate regional or central-level hospitals.
• Medium-scale general hospitals (200–500 beds):
  • Minimum investment capital: VND 200 billion.
  • This capital level usually applies to provincial hospitals with basic clinical departments and subclinical departments such as laboratories and diagnostic imaging.
  • Suitable for domestic private investors or public–private partnership (PPP) models.
• Specialized hospitals:
  • Minimum investment capital: VND 100 billion, depending on specialties such as obstetrics, oncology, cardiology, orthopedics, psychiatry…
  • Although the number of beds may be lower, specialized equipment requirements (e.g., radiotherapy machines, interventional endoscopy, 4D echocardiography…) and highly qualified doctors necessitate relatively large capital.
  • This model suits specialized hospitals collaborating with top experts or international medical chains.

2.2 Technical Standards

• Construction area: hospitals must ensure a minimum construction area of 50 m²/bed (point b clause 2 Article 41 of Decree 96/2023/ND-CP).
• Medical equipment: must meet conditions under clauses 3 and 5 Article 40 of Decree 96/2020, as well as Circular 08/2019/TT-BYT guiding standards and norms for using specialized medical machinery and equipment.
  • Medical facilities must be fully equipped with medical devices appropriate to the registered scope of professional activities.
  • Equipment must have:
    • Clear technical documentation;
    • Regular maintenance, servicing, and inspection;
    • Clear origin and quality standards.
• Medical waste treatment system: hospitals must construct treatment systems that comply with environmental standards such as:
  • QCVN 28:2010/BTNMT – National technical regulation on medical wastewater.
  • QCVN 07:2009/BTNMT – Threshold for hazardous waste.
  • Accessible architecture: hospital designs must ensure that people with disabilities can independently, safely, and conveniently access and use functional areas according to QCVN 10:2024/BXD – National technical regulation on accessible construction for people with disabilities.
  • Fire prevention and fighting: comply with TCVN 3890:2021 – fire prevention and fighting equipment and arrangements for buildings and constructions.

3. Licensing Procedure

Implementation Steps

1. Submit the investment project proposal dossier (Article 33 of the Law on Investment)
2. Appraise the project in terms of technical and financial aspects (Decree No. 175/2024/ND-CP)
3. Apply for a construction permit (Clause 30 Article 1 of the amended Law on Construction 2020)
4. Complete infrastructure and equipment (Articles 40 and 41 of Decree No. 96/2023/ND-CP)
5. Inspection and issuance of an operation license (Articles 60 and 61 of Decree No. 96/2023/ND-CP)

Refer to the website of the Department of Construction for detailed licensing procedures.

4. Construction Standards

Construction standards to comply with:

• Design must follow clear zoning regulations (examination, emergency, laboratory, inpatient areas…), open hallways, natural lighting systems, and comply with QCVN 10:2014/BXD on accessibility for people with disabilities.
• Fire safety system: in accordance with TCVN 3890:2021, fully equipped with automatic fire alarms, water and gas fire extinguishing systems, emergency stairs, backup lighting, and unobstructed emergency exits.
• Functional departments must be continuously arranged to ensure non-overlapping flows of patients, staff, and sterile materials.
• Clear separation of clean and contaminated zones, separate pathways for emergency transport, corpse transport, and medical waste.
• National technical regulation QCVN 01:2021/BXD on Construction Planning.
• Hospital design standards include:
  • TCVN 4470:2012 – General hospital – Design standards.
  • TCVN 9212:2012 – Regional general hospital – Design standards.
  • TCXDVN 365:2007 – General hospital – Design guidelines.

5. Conclusion and Recommendations

• Study the local market and healthcare demand.
  • Survey and analyze demographic indicators, disease models, and current status of medical facilities in the intended investment area.
  • Investing in line with actual demand not only ensures financial efficiency but also gains support from local authorities.
• Consult experts in healthcare and construction.
  • Each hospital project requires a team of professional consultants, including healthcare architects, hospital systems engineers, medical legal experts, and hospital managers.
  • Partnering with experienced consulting firms helps meet international standards and shorten licensing and operational timelines.
• Prepare sufficient capital and long-term financial planning.
• Build a professional management and operational team.
  • Modern hospitals require professional administrators.
  • Efficient operations directly affect service quality and hospital branding.

For detailed investment consultation in hospital construction, please contact the legal experts at Harley Miller Law Firm.

Opportunity for foreign investors: Vietnam’s Medical Equipment Market: A Comprehensive Guide for Foreign Investors and Understanding Clinical Trial Regulations for Foreign Pharmaceutical Companies in Vietnam.

Harley Miller Law Firm

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