The question of what goes into as-built records has a different answer this year, and that is where most material online is now wrong. Since 1 July 2026, Decree 06/2021 has ceased to have effect. It has been replaced by Decree 207/2026/ND-CP. The document list, the way an as-built drawing is produced, and the stamp forms all sit in the new decree.
This article sets out the list exactly as it appears in Appendix VII of Decree 207/2026, explains how to produce and stamp an as-built drawing under Appendix IIb, says who prepares and who signs each part, and separates three things that are constantly confused: as-built records, acceptance, and payment.
"As-built records" and "completion records" are the same thing
On site everyone says as-built records. In the legislation that phrase does not appear — the official term is completion records for the works. Clause 4, Article 3 of Decree 207/2026 defines it as "a compilation of the records and documents relating to the construction investment process that must be retained when the works are put into operation and use."
Two words in that definition matter: "process" and "retained". As-built records are not a folder put together in the last week before handover. They are what the project generated along the way, kept so that someone can consult them later during maintenance, alteration or an incident investigation. Once you read it that way, it becomes clear why records cannot be "produced" after the works are finished.
Note too that the as-built drawing is one component of the set, not the whole of it. Clause 3, Article 3 defines it as "a drawing of the completed construction works showing the position, dimensions, materials and equipment actually used."
The legal basis: Decree 207/2026 replaces Decree 06/2021
This is the point to update, because most guidance in circulation still cites the old decree.
Decree 207/2026/ND-CP was issued on 15 June 2026 and took effect on 1 July 2026. It details several articles of the Construction Law on quality management, construction and maintenance of works. Article 52 states plainly that Decree 06/2021 — as amended by Decrees 35/2023, 175/2024, 14/2026 and 67/2026 — ceases to have effect from the date the new decree takes effect.
Three places to remember in the new decree:
| Subject | Where it sits |
|---|---|
| List of completion records | Appendix VII |
| How to produce an as-built drawing, and the stamp forms | Appendix IIb |
| Responsibility for compiling, language, archiving | Article 28 |
If your file still uses the forms and list from Decree 06/2021, most of the content still works, but the legal basis printed on the cover and in every record has to be updated. The authority checking acceptance will look at that detail.
The as-built list under Appendix VII
Appendix VII splits the records into three groups, following the order a project actually passes through.
Group I — pre-investment records and contracts. The investment policy decision and pre-feasibility report if any; the project approval decision with the feasibility study or the economic-technical report; the design brief and appraisal documents; the compensation, site clearance and resettlement plan if any; written agreements from state bodies on planning, connections to infrastructure outside the site boundary, environmental impact, traffic safety and the safety of adjacent works; the land allocation decision or land lease contract; the construction permit unless exempt; the contractor selection decision and construction contracts; documents evidencing contractor capability.
Group II — survey and design records. The survey brief, the technical survey plan and the survey report; the decision approving the survey report; design verification and appraisal results, and the design approval decision with the approved design documents, including the list of drawings and the technical specifications; the written notice accepting the design.
Group III — construction management records, sixteen items. This is the heaviest group, and the one where people compiling a file discover what they are missing. The last session of the construction payment and final accounts course is spent checking exactly this list against a real file. The ones most often missing at submission:
- The list of design changes made during construction, with the appraisal and approval documents from the competent authority.
- As-built drawings, with the list of drawings attached. Missing that list gets the file returned even when every drawing is present.
- Certificates of origin, labelling, declarations of applied standards, conformity certificates and the acknowledgement of conformity declarations required under the Law on Product and Goods Quality.
- Monitoring, survey and testing results produced during construction.
- Acceptance records for work items, and for parts or stages of the works.
- Quality management records for equipment installed in the works.
- The operating procedure if any, and the maintenance procedure for the works.
- Written approvals on fire safety, environment, occupational safety, infrastructure connections and compliance with the construction permit.
- Incident resolution records if any, and the schedule of outstanding items to be remedied after the works are put into use.
- The record of acceptance of the completed work item and of the completed works.
Producing an as-built drawing correctly
Appendix IIb is very specific here, and this is where newcomers most often go wrong.
Built as designed. If the actual dimensions and parameters do not exceed the permitted tolerance against the design, nothing has to be redrawn: the construction drawing is photocopied, and the parties concerned stamp and sign it to make it the as-built drawing.
Built differently. If actual dimensions or parameters have changed against the approved construction drawing, the contractor writes the actual figure in brackets, beside or below the old figure, on that same sheet. That keeps both the design value and the actual value on one sheet, so a later reader sees immediately where something changed.
Where necessary the contractor may redraw a fresh as-built drawing, with a title block similar to the stamp forms in the appendix.
Two further rules get overlooked. First, concealed parts of the works must have an as-built drawing prepared, or their actual dimensions and parameters measured and recorded, before the next activity proceeds — meaning it has to happen at that moment, not after the concrete has been poured. Second, for a joint venture, each member prepares and signs its own scope; delegating that to another member is not permitted.
Reading an as-built drawing requires being able to read the construction drawing first. How to read structural drawings describes the package the as-built version is built on.
The as-built stamp and who signs it
The decree gives two stamp forms.
Form 1 covers the ordinary case: the contractor's name, the words AS-BUILT DRAWING, the date, and three signatures — the preparer with full name and position, the site manager or project director, and the lead site supervisor.
Form 2 applies where there are subcontractors, or under an EPC or turnkey contract. It adds the signature of the site manager or project director on the subcontractor's side, alongside the main contractor's.
Stamp size follows the lettering used on the drawing; the decree does not fix it.
Who compiles it, in what language, kept where
Article 28 answers all four questions briefly.
Who compiles it. The client organises the compilation of the completion records after acceptance of the completed work item or works, and is responsible for their accuracy and truthfulness. Each contractor is responsible for the part it prepared. In other words, the completion file is the client's job; the contractors supply the raw material.
Language. The whole file must be in Vietnamese. Only where there is a foreign element may the parties agree to add English or another language — add, not replace.
One set or several. Where the work items are put into use at the same time, one set is compiled for the whole project. Where they are put into use at different times, separate sets may be compiled for each work item.
Archiving. The client keeps one set; each participant keeps its own scope. Records must be kept as originals and as electronic copies; where no original exists, a principal copy or a lawful copy takes its place. The electronic-copy requirement is the part many organisations have yet to get used to.
As-built records, acceptance and payment
These three happen close together, so they get merged in people's minds, but their purposes are quite different.
Acceptance confirms quality: whether a work item, part, stage or the whole works meets the design requirements. Decree 207/2026 sets this out in Article 22 for work items, Article 23 for stages and parts, and Article 24 for completed work items and works. The output is a set of acceptance records.
The completion file captures the actual condition: how the works were really built, and where they differ from the design. The output is the as-built drawings and the completion records. It follows acceptance of the completed works.
Payment and final accounts determine money: how much the executed quantities are paid. The output is the interim payment files and the final account file. What goes into a construction payment and final account file? describes that set.
The link between the three is very practical: the as-built drawing is what establishes the actual quantity, and the actual quantity is what payment rests on. An error in the as-built drawing becomes an error in the money. That is why quantity surveyors and estimators, not only site engineers, have to be able to read one.
Five reasons a file gets sent back
It still cites Decree 06/2021. That instrument lost effect on 1 July 2026. The cover and every record must cite Decree 207/2026.
As-built drawings with no list attached. Appendix VII says explicitly "with the list of drawings attached". It is a formality, and it is enough to get the file returned.
Concealed work with no as-built drawing. Foundations, reinforcement inside concrete and buried services must be recorded or measured before they are covered. After that there is no way back.
No maintenance procedure. Plenty of files are complete on the construction side and omit this item, even though it is on the list and it is what the eventual operator needs most.
Joint venture members signing for each other. The decree prohibits delegation between members when signing off as-built drawings.
Frequently asked questions
Does the client or the contractor compile the file?
The client organises the compilation and is responsible for the accuracy of the whole set. Each contractor prepares and is responsible for its own part, including its as-built drawings.
If it was built exactly as designed, does the as-built drawing have to be redrawn?
No. Where deviations fall within the permitted tolerance, the construction drawing is photocopied, then stamped and signed to become the as-built drawing.
How is a deviation recorded on an as-built drawing?
The actual figure is written in brackets, beside or below the design figure, on that same sheet. The design figure is not erased.
How many sets have to be kept?
The client keeps one complete set; each participant keeps its own scope. Both originals and electronic copies are required.
Are as-built records a precondition for payment?
Not directly, but the as-built drawing establishes the actual quantity, and the actual quantity is what payment and final accounts rest on. In practice, final accounts stall while the completion file is unfinished.