From August 7, 2025, onward, Decree No. 219/2025/ND-CP (“Decree 219“) of the government officially takes effect, replacing and amending several important provisions of Decree No. 152/2020/ND-CP (“Decree 152“) regarding the management of foreign employees working in Vietnam.

The new decree is considered one of the most significant reforms in the field of foreign labor management, as it simultaneously simplifies administrative procedures, adjusts eligibility requirements for certain categories of highly skilled workers, and introduces greater flexibility for employers in recruiting and employing foreign workers.

In this article, we review the most important changes under Decree 219/2025/ND-CP and analyze the practical implications that businesses should consider when implementing procedures related to foreign employees in the coming period.

 

Changes Under Decree 219

New Provisions Introduced By Decree 219

Additional form of employment

Foreign employees may work in Vietnam under the form of:

“Being assigned from a foreign agency, organization, or enterprise to work in Vietnam, except for intra-company transferees.”

 

Additional category of foreigners exempt from Work Permits

Decree 152: Article 7 provided 14 categories of foreign employees exempt from work permits.
Decree 219: Article 7 provides 15 categories of foreigners exempt from work permits in Vietnam.

A new exemption has been added for foreign employees who are “Certified by ministries, ministerial-level agencies, or provincial People’s Committees to work in Vietnam in the fields of finance, science, technology, innovation, national digital transformation, and sectors prioritized for socio-economic development”

Re-issuance of Work Permits and certificates of Work Permit Exemption

Decree 152: No separate procedure for re-issuance.

Decree 219: Section 2 of the Decree stipulates the cases for reissuance of certificate of work permit exemption, which are:

“1. The certificate of work permit exemption is still valid but is lost or damaged and unusable.

2. Changes to any of the following: full name, nationality, passport number, workplace, change of employer’s name without changing the employer’s identification number.”

Interconnected procedure for issuing criminal record certificates

Decree 152: No provisions allowing simultaneous processing of applications for work permits and judicial record certificates. The two procedures were carried out separately before different authorities (Department of Labor, Invalids & Social Affairs and Public Security agencies)

Decree 219: Introduces an interconnected online procedure through the National Public Service Portal that allows simultaneous processing of applications for work permit and judicial record certificate.

The interconnected process is coordinated by the National Public Service Portal, the work permit authority under the provincial People’s Committee, and the police authority responsible for issuing judicial record certificates. Electronic work permits and judicial record certificates are issued simultaneously.

One Work Permit allows work in multiple localities

Decree 152: No specific provision. In practice, some local authorities would require the reissuance of work permits when the employees work in another locality.

Decree 219: According to Clause 5, Article 22, it is permitted that:

“In cases where a foreign worker who has been granted a work permit wishes to work for that employer in multiple provinces or municipalities, at least 3 days before the expected start date, the employer must notify the competent authority where the foreign worker is expected to work of the following information: full name, age, nationality, passport number, work permit number, name of the foreign employer, start date and end date of work, not exceeding the validity period of the issued work permit.”

Other Additional Changes Under Decree 219

• Replacing job titles with fields of work.
• Adjusting health examination requirements.
• No longer requiring labor contracts to be submitted to the licensing authority.

Decree 219/2025/ND-CP on Foreign Employees Working in Vietnam introduces significant changes to Vietnam’s foreign labor management framework, aiming to simplify procedures, increase flexibility for enterprises, and better support the attraction of highly qualified talent. Enterprises should proactively review their recruitment and employment processes to ensure compliance and effectively benefit from the advantages offered by the new decree.

What support could CNC provide?

• Outbound Investment: Company Establishment, Investment Registration and Post-registration Services in relation to tax, accounting, labor, insurance, salary, and outsourced legal department;
• Operation Licenses: We could provide support in the application for operation licenses for business activities in fields such as manufacturing, commerce, services, e-commerce, healthcare, education, or food & beverage (restaurants);
• M&A Services: Conduct legal due diligence, structure transactions, draft and negotiate transaction documents, provide advice on competition law compliance (including merger control filings and related approvals), obtain necessary regulatory approvals and licenses, and provide post-closing support;
• Personal Data Protection: Provide support in compliance with the data protection regulations, including the drafting and reviewing of Data Protection Impact Assessment (DPIAs), Data Processing/Transfer Agreement, Privacy Policies, and other necessary documents under the Personal Data Protection Decree (PDPD);
• Dispute Resolution: Litigation and Commercial Arbitration (VIAC SIAC ICC); and
• Legal Retainer Services per the clients’ requests.

Please contact Mr. Chris Luong – Partner through the email address of chris.luong@cnccounsel.com or Ms. Ngan Nguyen – Partner through the email address of ngan.nguyen@cnccousel.com for prompt and timely support.

Managed by

Nguyen Thi Kim Ngan I Partner Phone: (84) 919 639 093 Email: ngan.nguyen@cnccounsel.com

Luong Van Chuong I Partner Phone: (84) 938 04 7969 Email: chris.luong@cnccounsel.com

Tran Thi Thanh | Associate Phone: (84) 981 317 539 Email: thanh.tran@cnccounsel.com

Contact Us

For further information, please contact:

CNC Vietnam Law Firm

Address: The Rise Building, 2A1 Nguyen Thi Minh Khai, Sai Gon Ward, Ho Chi Minh City, Vietnam

Phone: (84) 28-6276 9900

Hotline: (84) 916-545-618

Email: contact@cnccounsel.com

Website: cnccounsel

We would be delighted to welcome you at CNC’s office, where you’ll have the opportunity to consult with the lawyer best suited to your circumstances. Of course, if you are unable to meet in person, simply email us via contact@cnccounsel.com or call us via (+84-28) 6276 9900.

Copyright © CNC Counsel. All Rights Reserved.

Ownership: This document and the content contained herein (the “Document”) are proprietary materials exclusively owned by CNC Counsel. Use of this Document does not, by itself, create any contractual relationship or attorney-client relationship between CNC Counsel and any party.

Disclaimer: All materials contained in this Document are provided for informational purposes only and may not reflect the most current legal developments. Summaries of laws, regulations, and practices are subject to change. This Document does not constitute legal, professional, or other advice with respect to any specific matter.

It is not intended to replace reference to (and compliance with) the detailed provisions of any applicable laws, rules, regulations, or official forms. Readers are strongly encouraged to seek legal advice before taking, or refraining from taking, any action based on the information contained in this Document.

CNC Counsel, its editors, and authors make no representations or warranties as to the accuracy or completeness of the information contained herein and disclaim any liability to any person or entity with respect to any actions taken or omitted based on all or any part of this Document. This Document may contain links to external websites, and external websites may contain links to this Document.

CNC Counsel is not responsible for the content, accuracy, availability, or operation of any such external websites and disclaims all liability arising from or related to the content or operation of any external websites.

Notice: Prior results do not guarantee a similar outcome. Every matter is unique and must be assessed based on its own specific facts and circumstances

—————————————–