A foreign trader’s representative office is permitted to use multiple seals if needed, under the principle that an organization decides by itself on its seals. The registration, management and use of seals are carried out under Decree 99/2016/ND-CP on the management and use of seals. Note: regulations on district-level police organizations in old documents should be understood in accordance with the new organizational model from 01/7/2025 (two-level local government, district level abolished).
1. May a representative office use multiple seals?
Yes. Current law permits agencies and organizations, including representative offices of foreign traders, to decide by themselves on the number, form and contents of seals suitable for their needs, provided that the management and use of seals comply with Decree 99/2016/ND-CP. When needing additional seals (a second, third seal…), the representative office carries out the supplementary seal specimen registration procedure as prescribed. Note: under Resolution 22/2026/NQ-CP dated 29/4/2026 of the Government and Decision 2709/QD-BCA dated 15/5/2026 of the Ministry of Public Security, the separate administrative procedure of “registration of additional seals” (Article 16 of Decree 99/2016/ND-CP) has been abolished; the registration of seal specimens — including supplementary seals — is carried out under the general seal specimen registration procedure.
2. What does the dossier for supplementary seal registration include?
Since the separate administrative procedure of “registration of additional seals” has been abolished (see section 1), the representative office shall submit the seal specimen registration dossier under the general procedure for supplementary seals. Regarding dossier components, cross-referencing Article 16 of Decree 99/2016/ND-CP (as amended by Clause 10, Article 2 of Decree 58/2026/ND-CP, effective from 15/3/2026): for economic organizations, the dossier consists only of the written request for seal specimen registration (Form No. 03 in Appendix II issued with Decree 58/2026/ND-CP). The copy of the Establishment License, documents of the head, or physical seal specimens previously required are no longer required. The dossier is filed at the Police Division for Administrative Management of Social Order of the provincial-level Public Security — the authority competent to register seal specimens for foreign organizations without diplomatic functions under Article 12 of Decree 99/2016/ND-CP (as amended by Decree 58/2026/ND-CP, effective from 15/3/2026); it may be filed directly, by post, or via the VNeID application.
3. Receiving authority and processing time limit
The competent police authority receives the dossier, checks its validity and issues a Seal Specimen Registration Certificate for the new seal specimen within the prescribed time limit. The representative office may only put the new seal into use after being granted the certificate. All seals in use must be strictly managed; when changing or canceling a seal specimen, the prescribed procedures must be followed and the old seal surrendered (if any).
Notes on applying current legal regulations
The content of this article is presented for reference purposes, helping readers understand the legal issue at an overview level. Seal registration procedures are tied to the current police organizational structure in each locality. Where you need to carry out additional seal registration procedures for a representative office, you should contact an ANT Legal lawyer via 0966.475.966 for review and advice before proceeding.
Common risks to note
– Using seals whose specimens have not been registered with the competent authority.
– Filing the dossier with a district-level police authority (which no longer exists).
– Citing old documents without cross-checking with the current organizational structure.
– Lax management leading to seal abuse.
How can ANT Legal help?
ANT Legal assists in advising on and representing clients in seal specimen registration procedures (including supplementary seals) for representative offices and branches of foreign traders. For prompt advice, please contact our lawyers via 0966.475.966.
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