From 1 July 2026, under Resolution 66.18/2026/NQ-CP, the Police Fire Service will no longer conduct acceptance inspection procedures for fire safety. This is a significant administrative reform — but it is also widely misunderstood. What is removed is the Police Fire Service's own inspection layer, not all state oversight. For high-grade structures, the construction authority's acceptance inspection layer remains intact. Below we explain precisely what is removed, what remains, and where responsibility now sits.
1. What is "acceptance inspection" — and what exactly does Resolution 66.18 remove?
To understand the change correctly, three concepts that are often conflated must be separated:
- Fire safety design assessment (thẩm định thiết kế) — the Police Fire Service checks the drawings against technical regulations before construction begins. This is a paper-based control. Since Law 55/2024 and Decree 105/2025 came into effect, this procedure is called design assessment, replacing the former term design approval (thẩm duyệt).
- Acceptance testing / commissioning — the project owner, together with the contractor and supervision consultant, organises functional testing of systems after installation. This remains mandatory and is not abolished.
- Acceptance inspection (kiểm tra công tác nghiệm thu) — an independent check by the state authority, comparing the completed structure (as-built) with the approved design (as-designed), with functional testing of fire pumps, alarms, stairwell pressurisation, smoke control, and interlocks.
Resolution 66.18/2026/NQ-CP (Annex I.1, fire safety section under the Ministry of Public Security) removes 3 procedures and simplifies the pre-approval dossier for the remaining procedure:
| Measure | Legal basis |
|---|---|
| Remove Acceptance Inspection of fire safety | Art. 18(5)(c) Law 55/2024; Art. 10 Decree 105/2025 |
| Remove Fire Safety Acceptance (projects with design approval certificate but not yet issued acceptance approval) | Art. 46(3) Decree 105/2025 |
| Remove Reinstatement of Operations procedure (premises, vehicles, households) | Art. 46(5)(b) Decree 105/2025 |
| Simplify the design assessment dossier (reduced to 3 document types: Form PC11; land/investment approval documents; detailed design or construction drawings) | Art. 9(4)(a) Decree 105/2025 |
The Department of Police Fire Service (C07) stopped accepting these procedures from midnight on 20 June 2026; dossiers received before that date will be processed and returned before midnight on 1 July 2026.
Why does the acceptance inspection layer have distinct technical value?
Design assessment only examines drawings. It cannot detect construction deviations: pipes resized in the field, missing sprinkler heads, valves in the wrong position, pressurisation systems not reaching required differential pressure, smoke control and alarm interlock failures. The acceptance inspection layer is the check between approved design and actual construction, with real functional testing before the building enters operation.
In international practice, this control layer exists widely but takes different forms. In the United States, acceptance testing and commissioning under NFPA 3 and NFPA 4 are witnessed by the Authority Having Jurisdiction (AHJ) as a condition of the Certificate of Occupancy. In the United Kingdom, responsibility passes to a competent person regime with mandatory fire safety handover documentation under the Building Regulations, backed by serious criminal penalties. In both countries, the technical control layer does not disappear — it shifts: to independent third-party certification, backed by post-occupancy enforcement with meaningful deterrent penalties.
2. Two parallel regulatory systems
This is the most commonly misunderstood point. A construction project is subject to two independent regulatory systems, operated by two different authorities:
- Fire safety system — Ministry of Public Security: fire safety design assessment, and (previously) acceptance inspection. Resolution 66.18 has removed the acceptance inspection layer from this system.
- Construction quality system — construction authority: design assessment for construction works (within which fire safety is one component), and acceptance inspection under Article 24 of Decree 06/2021/ND-CP (as most recently amended by Decree 67/2026/ND-CP). Resolution 66.18 does not touch this layer.
The construction authority's acceptance inspection does not apply to all projects. Under Article 24 of Decree 06/2021, it applies to national-importance projects; large-scale or technically complex structures (special grade, grade I); public-investment projects; projects with significant impact on community safety — conducted by the relevant construction authority or a State Inspection Council. The scope includes compliance with quality management requirements, construction safety, and acceptance completion conditions, of which fire safety is one component.
| Criterion | Fire safety system (MPS) | Construction quality system (construction authority) |
|---|---|---|
| Pre-construction check | Fire safety design assessment — remains (simplified dossier) | Construction design assessment, including fire safety component — remains |
| Acceptance inspection | Removed (from 1 July 2026) | Remains — for special grade and grade I structures, national-importance projects, public investment, and projects with significant community impact |
| Legal basis | Law 55/2024; Decree 105/2025; Resolution 66.18 | Art. 24 Decree 06/2021 (as amended, most recently Decree 67/2026) |
| Fire safety examined where | Only at the design assessment stage (drawings) | As part of acceptance completion condition check |
3. Liability allocation: before and after 1 July 2026
Previously, a project subject to fire safety controls had to pass through two sequential Police Fire Service procedures — design assessment, then acceptance inspection — before being put into service. The Police Fire Service acted as a control gate: when they inspected, they identified deficiencies and required rectification before approving operations.
From 1 July 2026, only one pre-construction procedure remains under the fire safety system: design assessment. After organising construction and commissioning independently, the project owner may put the building into use and bears full legal responsibility for construction execution, supervision, and acceptance against applicable technical standards and regulations.
One distinction must be drawn clearly: abolishing an administrative procedure does not abolish the substantive compliance obligation. The full body of QCVN 06:2025, the TCVN standards, and Law 55/2024 remains in force. The state is shifting from pre-inspection to post-inspection: the competent authority will still conduct inspections and audits during the operational phase, and will enforce penalties.
| Criterion | Before 1 July 2026 | From 1 July 2026 |
|---|---|---|
| Independent Police Fire Service inspection | Yes — acceptance inspection | No (project owner self-accepts) |
| When fire safety defects are detected | Before operations begin | At post-inspection or when a fire occurs |
| Opportunity to rectify | Yes — fix before being allowed to operate | Yes, but accompanied by legal liability |
| Condition for putting into use (fire safety system) | After written approval | Project owner decides; project owner bears responsibility |
| Obligation to comply with QCVN / TCVN | Mandatory | Mandatory (unchanged) |
| Party | Before 1 July 2026 | From 1 July 2026 |
|---|---|---|
| Project owner | Prepares dossier; awaits Police Fire Service acceptance approval | Self-organises acceptance; decides when to begin operations; bears full legal responsibility |
| Design consultant | Design passes assessment; defends dossier when required | Bears professional liability for design compliance; role unchanged but legal exposure now more visible |
| Supervision consultant | Supervises construction to design; signs acceptance records | Becomes the most critical on-site quality control link; supervision records are legal evidence |
| Contractor | Constructs per drawings; rectifies as directed by inspection team | Bears independent liability for own construction scope; no "inspection team" to identify defects first |
| Independent inspector / third-party verifier | Optional | Becomes the prudent choice to fill the "independent third party" role left by the Police Fire Service |
4. Two case studies with final court rulings
When the Police Fire Service inspection barrier is removed, a technical defect does not thereby become less serious. The two incidents below — both with concluded investigations and court judgments — illustrate where the risk lies.
According to the first-instance judgment of the Hanoi People's Court, the owner had been granted a permit for a 6-storey single-family dwelling but unilaterally changed the design to 9 storeys plus a rooftop structure — 3 floors above the permitted height — without preparing any fire safety design, assessment, acceptance, or management documentation as required. The court found violations of construction and fire safety regulations and sentenced the owner to 12 years' imprisonment (reduced to 9 years and 6 months on appeal), together with civil compensation exceeding VND 23 billion.
According to the indictment and investigation conclusion, at the time of the fire the building's automatic fire alarm and suppression systems were non-functional; acceptance records for fire safety equipment had documented known deficiencies that were never rectified; one fire pump had been removed and lent to another project; and fire exit doors had been propped open, allowing toxic smoke to spread to upper floors. The developer's director and building management head were prosecuted and tried for violation of fire safety regulations; the developer paid compensation exceeding VND 119 billion.
5. Operations, maintenance and post-inspection
A common mistake is to treat acceptance as the finish line. In fact, from the moment a building is put into service, the legal liability of the project owner and facility operator continues throughout the operational life. A fire safety system that meets the standard at handover does not remain compliant after several years without maintenance.
- Operations, maintenance and periodic inspection, testing and maintenance (ITM). Pumps, alarms, pressurisation, smoke control, valves, and sprinkler heads must be tested and maintained on schedule; fire safety equipment and systems must be installed and maintained per QCVN 10:2025/BCA. Carina is the costly example: systems "passed on paper" but did not function in practice.
- Self-inspection and record-keeping. Facilities must self-organise periodic fire safety inspections and maintain records (self-inspection checklists per Decree 105/2025 templates), as evidence of compliance when a post-inspection team arrives.
- Post-inspection by the competent authority. The state is shifting emphasis to inspection and audit of fire safety during the operational phase, combined with enforcement penalties. Documentation proving compliance at the time of acceptance and throughout operation is the project owner's legal asset when an audit team visits.
6. Building technical control when the Police Fire Service gate is removed
When the Police Fire Service inspection layer is lifted, the prudent project owner will proactively build their own technical control layer. Six steps to take:
- Internal acceptance must produce evidential records. Don't stop at generic sign-off documents — produce system-by-system checklists, test results with measured data (flow rates, pressures, differential pressures, response times), and photographs of as-installed conditions, especially for components that will be concealed after finishing works.
- Engage an independent consultant or inspection body to witness and certify acceptance. This directly fills the "independent third party" role left vacant by the Police Fire Service. A self-acceptance record carries fundamentally different legal weight when countersigned by a qualified, independent specialist.
- Compile and retain a complete fire safety as-built dossier for post-inspection purposes. The competent authority has shifted its focus to post-occupancy inspection combined with operational safety audits. Documentation proving compliance at acceptance is the project owner's legal asset when an audit team arrives.
- Establish an operations, maintenance and ITM programme. Safety does not end at handover; legal liability continues throughout the operational life — Carina is the costly proof.
- Clearly allocate responsibility in contracts between project owner, design consultant, contractor, and supervision consultant. When a defect occurs, civil liability boundaries are determined by contract clauses and professional records — not by verbal accounts.
- Maintain transparent safety records for residents and tenants. Transparency reduces legal risk and is a commercial advantage.
Commentary from industry practitioners aligns with this direction: moving to self-acceptance means that if an incident occurs, the project owner and contractor will bear full legal liability; and a self-acceptance record that deviates from technical regulations can, if an incident occurs, become evidence against the very person who signed it.
7. The role of an experienced consultant
This reform produces a somewhat counterintuitive result: fewer administrative procedures, but greater need for independent specialist expertise. Fire safety is a deep technical field; most project owners are strong in capital and business but lack the specialist knowledge to independently assess all requirements of a fire safety system. As one developer observed in published commentary: project owners cannot alone carry all fire safety liability — they need a framework under which consultants, designers, contractors, and inspection bodies bear clear professional responsibility for their respective scope of work.
When selecting a partner, project owners should apply the following criteria:
- Independent assessment and inspection capability, separate from the design or construction team, to ensure objectivity in acceptance certification.
- Proven experience with complex projects — high-rise and super-high-rise buildings, underground / metro structures, industrial facilities, storage depots, battery energy storage systems (BESS) — where technical risk is highest.
- Fluency in both Vietnamese technical regulations (QCVN 06:2025, TCVN) and international standards (NFPA, BS 7974 / PD 7974), with performance-based design (PBD, ASET/RSET) capability for projects that require safety justification beyond the regulatory framework.
- Ability to provide standardised acceptance checklists and templates that help project owners build a self-acceptance dossier that is legally sound.
Removing the procedure is the right direction and consistent with modern governance practice — but it comes with self-responsibility. Project owners who genuinely benefit from Resolution 66.18 are those who proactively build their own technical control layer, not those who mistake the removal of a procedure for permission to relax safety standards.
8. Frequently asked questions
The procedure has been removed — does acceptance testing still need to happen?
Yes, it does. What has been abolished is the acceptance inspection procedure of the Police Fire Service — not the act of acceptance testing itself. Project owners must still organise commissioning and acceptance of systems and bear legal responsibility for fire safety compliance before putting the building into service.
Does the removal mean no state authority will check acceptance anymore?
Not quite. Resolution 66.18 only removes the Police Fire Service's procedure. For special-grade and grade-I structures, national-importance projects, or projects with significant community safety impact, the construction authority (or State Inspection Council) still conducts acceptance inspection under Article 24 of Decree 06/2021 (as amended, most recently by Decree 67/2026), within which fire safety is a component of overall construction quality.
If the project owner self-accepts and a fire occurs, who bears liability?
The project owner and all parties involved (design consultant, supervision consultant, contractor, inspection body) each bear liability for their respective scope of work. Liability may be administrative or criminal if serious consequences result, together with civil compensation obligations — as illustrated by the two case studies above.
What is the difference between "design approval" (thẩm duyệt) and "design assessment" (thẩm định)?
Since Law 55/2024 and Decree 105/2025 came into effect, the pre-construction fire safety dossier check by the Police Fire Service is called fire safety design assessment, replacing the former term design approval. Design approval certificates already issued retain their original title and legal validity until they expire.
Is this removal of procedures permanent or time-limited?
Resolution 66.18/2026/NQ-CP is effective from 1 July 2026 to 28 February 2027. This is a transitional mechanism: during this period, ministries must submit amendments to the underlying laws and decrees to make the cuts permanent before 1 March 2027. The removal is substantive and takes effect immediately — it is not a temporary suspension that will be reversed.
Need to review your project's self-acceptance process?
VIETSAFE E&C partners with project owners to build self-acceptance processes that are technically sound and legally defensible: independent verification, as-built dossiers, and standardised checklists for complex structures.
Contact usThis article draws on authoritative sources (Resolution 66.18/2026/NQ-CP; C07 announcements; Fire Safety Law 55/2024; Decree 105/2025; Article 24 Decree 06/2021 and subsequent amendments including Decree 67/2026; publicly released court judgments and investigation conclusions from the fires cited) and is provided for reference purposes only. For application to specific projects, please consult the primary legal texts directly or contact a specialist adviser. VIETSAFE E&C is not a legal authority and this content does not constitute formal legal advice.