Resolution No. 66.18/2026/NQ-CP: Higher Economic Concentration Notification Thresholds – But Not Lower Competition Risks
- 2 days ago
- 1 min read
Vietnam just made it easier to skip a merger filing — and riskier to get merger compliance wrong.
From 1 July 2026, Resolution No. 66.18/2026/NQ doubles three of the four economic concentration notification thresholds:
* Total assets / turnover: VND 3,000bn → 6,000bn
* Transaction value: VND 1,000bn → 2,000bn
* Combined market share: 20% (unchanged)
Many mid-sized M&A deals will now fall outside mandatory notification. Good news for deal timelines and costs.
But three things are easy to miss:
1. The 20% market share trigger hasn't moved. A deal under every financial threshold can still require a filing.
2. These thresholds are temporary — in force only until 28 February 2027, pending broader Competition Law reform.
3. Enforcement got tougher, not lighter. Decree 102 (effective 20 May 2026) brings fixed fines up to VND 2bn, structural remedies including forced divestiture, and new VCC power to revoke approvals obtained on false information.
The takeaway: fewer filings doesn't mean lower risk. Competition analysis belongs at the structuring stage — not the week before closing.
Full breakdown below.
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