Conditions for an Employment Services License from 2026

Quick answer: From 01/01/2026, the conditions for granting an employment services business license follow Decree No. 352/2025/ND-CP (replacing Decree No. 23/2021/ND-CP). Enterprises must simultaneously satisfy 3 conditions: (1) a stable location for the head office/branch, owned or leased with at least 24 months remaining on the lease; (2) a VND 300,000,000 deposit; (3) the legal representative must not be restricted in or deprived of civil capacity and must hold a bachelor’s degree or higher, or at least 24 months of experience in employment services or labor supply.

Conditions for granting an employment services license from 01/01/2026

Under Decree No. 352/2025/ND-CP detailing certain articles of the Law on Employment on job creation support policies and employment services (effective 01/01/2026, replacing Decree No. 23/2021/ND-CP), an enterprise applying for an employment services license must satisfy:

• Location: having a head office or branch location for employment services activities, owned by the enterprise or stably leased with at least 24 months remaining;
• Deposit: having made a deposit of VND 300,000,000 at a commercial bank;
• Legal representative: not subject to restriction or deprivation of civil capacity; holding a bachelor’s degree or higher, or at least 24 months of work experience in employment services or labor supply.

Do the old rules (Decree 23/2021) still apply?

No. Decree No. 23/2021/ND-CP ceased to be effective from 01/01/2026 when Decree No. 352/2025/ND-CP took effect. The previous more detailed and stricter conditions have been replaced by the new set of conditions above.

What about enterprises already licensed under Decree 23/2021?

Licenses granted under Decree No. 23/2021/ND-CP continue to be considered under the transitional provisions of Decree No. 352/2025/ND-CP. Enterprises need to review their compliance with the new conditions when renewing or reissuing licenses.

Applicable legal basis

• Decree No. 352/2025/ND-CP (effective 01/01/2026, replacing Decree No. 23/2021/ND-CP): conditions for granting employment services licenses.
• Law on Employment 2013.

Note on Applying Current Legal Regulations

This article is part of the Business & M&A Knowledge series and is presented for reference purposes, helping readers understand the legal issue at a general level before preparing documents or entering into transactions.

Legal regulations may change depending on timing, locality, document type, and specific circumstances. If you need to determine the exact legal basis applicable to your file, please contact ANT Legal’s lawyers at 0966.475.966 for verification and advice before proceeding.

Common Risks to Note

• Applying an outdated, amended, or replaced legal instrument.
• Preparing incomplete dossiers, documents, or evidence.
• Misunderstanding the conditions, procedures, time limits, or competent authorities.
• Signing, filing, or entering into transactions without fully assessing legal risks.

How Can ANT Legal Help?

ANT Legal supports reviewing specific situations, checking dossiers, identifying the applicable legal basis, advising on handling options, and representing clients in dealings with individuals, organizations, or competent authorities when necessary.

For prompt advice, please contact our lawyers at 0966.475.966.

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