In its comments to the Prime Minister's Advisory Council for Administrative Procedure Reform on the draft report on improving business regulations to support productivity growth in Vietnam, the VCCI has stated that the draft report has provided a fairly comprehensive assessment of Government Resolution No. 68/NQ-CP of May 12, 2020, which promulgates the Program to reduce and simplify regulations related to business activities for the period 2020-2025 (Resolution 68).

Specifically, the VCCI accurately identified the remaining issues in Resolution 68 itself and the implementation of this Resolution. According to the VCCI, the policy recommendations are quite reasonable and will be very useful for policymakers in developing long-term policies to improve the investment and business environment.

However, to further improve the report, the VCCI suggests that some policies should be considered, revised, and supplemented to be more suitable.

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Regarding the structure of simplified business regulations, the draft report assesses the types of regulations that have been simplified or eliminated, focusing mainly on administrative procedures, followed by technical standards and norms, and specialized reporting and inspection requirements.

However, according to the VCCI, this assessment only provides figures on the types of regulations that have been simplified or abolished, and has not yet identified in greater depth which regulations have been abolished, from which it is possible to assess the impact of simplifying or eliminating business regulations.

According to the VCCI, in the options to reduce and simplify administrative procedures, the main proposals are focused on reducing the number of dossiers, reducing the number of days to complete procedures, and adding electronic methods of conducting procedures...

The VCCI believed that, in principle, these proposals will facilitate procedures for subjects, but they are not truly innovative or reforming. Businesses not only expect cuts and simplifications in investment and business conditions, but also need more radical reforms in the regulations on administrative procedures.

Along with the above issue, regarding the recommendation to "reform licensing supported by inspection reform," according to the VCCI, this content is still unclear. For business activities, the State currently manages through mechanisms: prohibiting investment and business; imposing business conditions; and conducting business without being bound by conditions or licenses other than business registration.

Therefore, the VCCI suggests that, depending on the level of risk and impact on the public interest, the State will determine appropriate management measures. For licensing or non-licensing mechanisms, the State still conducts inspections and audits to ensure that businesses comply with the law.

Regarding the recommendation to "clarify the list of conditional business activities in the Investment Law," according to the VCCI, some points in this content need to be reconsidered. For example, the consideration of business conditions for conditional business lines is currently quite clear and the Law on Investment has required public disclosure. The specific business conditions are stipulated in specialized laws, not in the Investment Law...

Regarding the recommendation to "build a horizontal legal framework for granting business licenses," the VCCI believes that this recommendation needs to be reconsidered in terms of feasibility because in the current business legal system, administrative procedures related to granting business licenses are separately regulated in specialized legal documents and comply with the principles of administrative procedures regulations.