You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

April 23, 2025

Wider Skies: Vietnam Expands Aviation Market to More Aircraft Types

Subscribe to Updates

On April 13, 2025, the government of Vietnam issued Decree No. 89/2025/ND-CP to amend and supplement Decree No. 92/2016/ND-CP dated July 1, 2016, concerning conditional business lines within the civil aviation sector (“Decree 89”). This update was implemented through an expedited procedure with immediate effect and has drawn public attention as it broadens the types of aircraft eligible for import into Vietnam, thereby promising to inject greater diversity into the country’s aviation market.

What has changed?

Decree 89 expands the recognition of aircraft type certificates—documents ensuring that the design of the aircraft, aircraft engine, or propeller meet airworthiness standards—from two to seven foreign aviation authorities. While Vietnam previously only accepted type certificates from the U.S. Federal Aviation Administration (FAA) and the European Union Aviation Safety Agency (EASA), the country now further accepts type certificates issued by five additional foreign aviation authorities:

  • National Civil Aviation Agency of Brazil (ANAC)
  • Transport Canada Civil Aviation (TCCA)
  • Federal Agency for Air Transport of the Russian Federation (Rosaviatsiya)
  • U.K. Civil Aviation Authority (UK CAA)
  • Civil Aviation Administration of China (CAAC)

Additionally, on April 14, 2025, Vietnam’s Ministry of Construction issued Circular No. 03/2025/TT-BXD (“Circular 03”) with immediate effect, amending and supplementing several articles under Circular No. 01/2011/TT-BGTVT previously issued by the Ministry of Transport (which was merged into the Ministry of Construction on March 1, 2025) in 2011 on the promulgation of the Civil Aviation Safety Regulations for aircraft and aircraft operations. Echoing Decree 89, Circular 03 allows the Civil Aviation Authority of Vietnam (CAAV) to issue or recognize Certificates of Airworthiness to aircraft that hold type certificates issued by the aviation authorities of Brazil, Canada, Russia, the United Kingdom, or China, in addition to those issued by the FAA or EASA.

Following the entry into force of Decree 89 and Circular 03, the first aircraft imported and approved for commercial flights under these expanded rules was a Chinese-made aircraft from the Commercial Aircraft Corporation of China, Ltd. (COMAC), holding a type certificate issued by the CAAC.

Why the change?

Decree 89 is expected to boost competition across the region and lower costs for Vietnamese airlines. This significant expansion appears to be driven by two main factors.

  • Vietnam has ambitious plans to expand its aviation infrastructure to accommodate rising passenger numbers. Under Vietnam’s near-term master plan for the development of national airports through 2030 and its long-term vision to 2050, the country aims to expand its airport network to 30 airports by 2030 (14 international and 16 domestic), up from the current total of 22. The long-term vision for 2050 includes further upgrades and development to increase annual passenger capacity by more than 80%. By recognizing more aircraft types from additional countries, Vietnam is providing local airlines with greater flexibility and more options when purchasing or leasing aircraft that are safe, cost-effective, and suited to their needs.
  • Over the past three years, Vietnam has strengthened relationships with countries such as Brazil, Canada, Russia, the U.K., and China through high-level diplomatic and regulatory cooperation. Vietnam has hosted state-level visits or held meetings with leaders and envoys of these nations, fostering closer ties and paving the way for mutual recognition in civil aviation matters.

What’s next?

Looking ahead, the government of Vietnam is taking further steps to support this growth in air travel. It is in the process of updating Decree No. 68/2015/ND-CP on registration of nationality and rights to aircraft to streamline aircraft registration and align with international standards under the Cape Town Convention and Protocol.

Related Professionals

Industries

Aviation

Location

RELATED INSIGHTS​ 

July 23, 2026
Tilleke & Gibbins’ Bangkok-based aviation specialists have authored the Thailand chapter of Aviation Finance & Leasing 2026 from Chambers and Partners. This annual guide examines the key legal issues impacting aircraft lessors, lessees, and financiers in nearly 40 jurisdictions worldwide. In addition to the Thailand chapter, Tilleke & Gibbins also contributed the Vietnam chapter to this year’s edition. The Thailand chapter offers a comprehensive overview of the country’s legal framework governing all aspects of aircraft sale and purchase, aircraft and engine leasing, and aircraft debt finance. Some topics covered include: sale and lease agreement terms taxation lease registration and enforcement lease assignment/novation insurance and reinsurance debt structuring securities liens The guide also examines other matters with practical implications for the aviation industry’s day-to-day operations. Chambers and Partners’ Global Practice Guides provide in-house counsel with authoritative commentary on practical legal issues affecting business, enabling readers to compare legislation and procedures across multiple jurisdictions. The Thailand chapter of Aviation Finance & Leasing 2026 is available on the Chambers and Partners website.
Read More
July 23, 2026
Aviation law experts from Tilleke & Gibbins’ Vietnam offices have prepared the Vietnam chapter of Aviation Finance & Leasing 2026 from Chambers and Partners. Covering nearly 40 jurisdictions worldwide, the guide addresses key legal considerations for aircraft lessors, lessees, and financiers. Alongside the Vietnam chapter, Tilleke & Gibbins also provided the Thailand chapter for this year’s edition. The Vietnam chapter delivers detailed insights into the legal environment affecting aircraft sale and purchase, aircraft and engine leasing, and aircraft debt finance. Some of the topics it examines include: sale and lease agreement terms taxation lease registration and enforcement lease assignment/novation insurance and reinsurance debt structuring securities liens The guide also covers other issues influencing the day-to-day activities of aviation industry participants in Vietnam. Chambers and Partners’ Global Practice Guides provide in-house counsel with authoritative analysis of practical legal matters impacting business, enabling readers to compare legislation and relevant procedures across leading jurisdictions. The Vietnam chapter of Aviation Finance & Leasing 2026 is available on the Chambers and Partners website.
Read More
February 20, 2026
Thailand’s Supreme Administrative Court has issued a decisive ruling annulling the Ministry of Labor’s notification that had granted an exemption for foreign pilots to fly domestic routes under wet‑lease arrangements. A wet lease is a leasing arrangement in which the aircraft is provided together with its foreign flight crew, including pilots, and related operational support, rather than the airline supplying its own pilots. The judgment, delivered on November 17, 2025, and published in the Government Gazette on January 30, 2026, follows a legal challenge brought by the Thai Pilots Association, which argued that the exemption unlawfully enabled foreign workers to assume a role traditionally reserved for Thai nationals. The notification in question, dated December 13, 2024, authorized foreign pilots who came as part of wet‑leased aircraft to fly domestic routes. The Thai Pilots Association disputed the legality of this rationale, asserting that the exemption was triggered by a private airline’s request rather than by any statutory necessity. The Ministry of Labor justified this measure by relying on aircraft‑specific approvals issued by the Ministry of Transport and by enabling the Department of Employment to issue corresponding work permits. Arguments Presented in the Case The Thai Pilots Association argued that the exemption undermined the interests of domestic pilots and conflicted with the policy intent of Thailand’s foreign‑worker regulatory framework. The lawsuit emphasized that the notification arose directly from a private airline company’s request to operate two A320 aircraft under a wet lease and that the measure had the practical effect of displacing Thai pilots who remained unemployed. Meanwhile, the Ministry of Labor defended the exemption as a temporary and necessary response to industry shortages and part of national efforts to support tourism and restore aviation capacity. Legal Framework Thai law establishes a general prohibition against foreign nationals piloting domestic aircraft. Section
Read More
December 4, 2025
Thailand has expanded the circumstances under which state agencies may bypass competitive bidding procedures to address urgent security challenges. On November 28, 2025, Thailand’s Ministry of Finance published the Ministerial Regulation Determining Cases of Procurement by Specific Method (No. 6) B.E. 2568 in the Royal Gazette, introducing a new pathway for procuring supplies and services needed to address cyber and military threats that may affect the stability of government agencies or the nation. For technology vendors, cybersecurity firms, and defense contractors, this regulatory change creates immediate opportunities to engage directly with government buyers facing urgent security challenges. New Fast-Track Category for Security Threats The regulation amends Thailand’s Public Procurement and Supplies Management Act B.E. 2560 (2017) to add a new category of procurement that qualifies for the “specific method”—a noncompetitive, direct selection process. Previously, agencies could use this expedited method only in limited circumstances, such as emergencies, cases with proprietary technology requirements, or national security operations. The new provision explicitly covers procurement of supplies related to preventing or resolving cyber or military threats that could impact the stability of a state agency or the country. This addition recognizes the urgent nature of modern security challenges, where competitive bidding timelines may leave agencies vulnerable during critical threat windows. State agencies dealing with active cyberattacks, preparing defensive measures against anticipated threats, or responding to military security concerns can now move directly to negotiate with qualified vendors rather than conducting lengthy public tender processes. Vendor Considerations Vendors offering cybersecurity solutions now have a regulatory avenue to work directly with government clients when stability concerns are present. These solutions include threat detection systems, anti-ransomware tools, incident response services, firewalls, and security consulting. Similarly, defense contractors providing military equipment or specialized security supplies can pursue direct engagement channels where traditional procurement methods would create
Read More