A method for manufacturing a non-volatile memory with SONOS memory cells, which includes steps of: providing a substrate; forming a first gate oxide layer and a first gate conductive layer onto the substrate; forming a MOS transistor gate by executing a photolithography process on the first gate conductive layer, and then forming an ONO structure on the substrate; and forming a second gate conductive layer on the ONO substrate, and then forming a NVM transistor gate by executing a photolithography process on the second gate conductive layer.