Effective Date: September 28, 2026
Summary
Vietnam has issued Decree No. 320/2026/ND-CP, dated August 13, 2026, which amends Decree No. 69/2024/ND-CP on electronic identification and authentication. Under the new rules, eligibility for a personal VNeID account is no longer restricted to holders of a Permanent Residence Card (PRC) or Temporary Residence Card (TRC).
From September 28, 2026, foreign nationals who have legally entered or are legally residing in Vietnam may apply for an account. The Immigration authorities in Hanoi and Ho Chi Minh City have both published guidance confirming the change.
For employers, this provides a practical solution. It addresses the bottleneck that has prevented certain entities from completing filings since Business VNeID became the mandatory access method for government portals on June 1, 2026.
Key Information to Note
Expanded Eligibility
Previously, applicants generally needed to hold a PRC or TRC, excluding many foreign nationals who were lawfully present in Vietnam on visas or other permitted grounds. Decree 320 removes the requirement to hold a residence card as a prerequisite for obtaining a personal VNeID account.
Account Levels and Application Process
Eligible individuals may apply for either a Level 1 or Level 2 account. For applicants aged six or above, obtaining a Level 2 account requires an in-person appointment with the competent authority to verify the applicant’s information and collect biometric data, including a facial image and fingerprints. Applications are submitted through the relevant immigration authorities.
Level 2 is particularly important for corporate purposes because a legal representative must hold a personal Level 2 VNeID account before an organisational Business VNeID account can be registered.
Why it Matters for Employers
Since June 1, 2026, organizations registered in Vietnam have been required to access the National Public Service Portal and the Ministry of Public Security’s portal through a Business VNeID, following the withdrawal of the previous e-signature and token-based login methods.
Where an organization’s sole or principal legal representative was a foreign national without a PRC or TRC, that individual could not obtain the required personal VNeID account. As a result, the organization could not register its Business VNeID and was consequently unable to submit immigration applications through the relevant portals. Decree 320 addresses the underlying cause of this impasse by expanding eligibility for personal VNeID accounts.
Newland Chase Insights
Foreign nationals who were previously ineligible for VNeID due to not holding a Temporary Residence Card or Permanent Residence Card should reassess their eligibility once the new rules take effect.
In addition, the new rules may eliminate the need for employers to use structural workarounds, such as changing the legal representative to a Vietnamese national to access government portals. Employers should confirm their Business VNeID status, check the legal representative’s registration details, and arrange biometric registration for the required Level 2 account.
Given potential differences in initial implementation, employers should allow additional lead time for Vietnam filings through Q4 2026 and monitor guidance from the Hanoi and Ho Chi Minh City immigration authorities.
This news alert is for informational purposes only and does not constitute legal advice. For case-specific guidance or further information, please contact Newland Chase directly.
