Dermatology, obstetrics and pediatrics are among the most popular specialties for private clinics in Vietnam. But opening a “dermatology clinic” does not entitle you to offer every skin-related service, and not every multi-specialty combination can operate under a single license. This guide explains the permitted scope of practice under the Law on Medical Examination and Treatment 2023 and Decree 96/2023/ND-CP.
1. Three legal models for combining specialties
- (a) Separate specialty clinics: each clinic covers at least 1 specialty (Article 43, Decree 96/2023);
- (b) General clinic: at least 3 specialties including 2 of the 4 core specialties (internal medicine, surgery, obstetrics, pediatrics), plus a paraclinical department (Article 42) — the right model for a combined “dermatology + obstetrics + pediatrics” facility;
- (c) Multi-specialty clinic: at least 2 specialties outside the 4 core specialties (Article 44).
Choosing the wrong model means redoing the licensing dossier.
2. Scope of practice = the approved list of techniques
A common misunderstanding: the permitted scope is not “anything within the specialty” — it is the list of techniques approved by the licensing authority together with the operating license (Article 61, Decree 96/2023).
Performing techniques outside the approved list — e.g., a dermatology clinic doing unapproved invasive cosmetic procedures — constitutes practicing beyond the licensed scope, punishable under Decree 90/2026/ND-CP (fines, suspension of the right to use the license, facility suspension).
3. Conditions for specialty clinics
Under Article 43, Decree 96/2023, a specialty clinic needs: a reception area; examination rooms of at least 10 m²; procedure rooms of at least 10 m² (if applicable); a sterilization area; and an anaphylaxis emergency kit. The person in charge must hold a practice license in the relevant scope with at least 36 months of practice (point b, Clause 4, Article 40 of Decree 96/2023/ND-CP).
4. Dermatology vs. cosmetic surgery: the most common trap
A dermatology specialty clinic may diagnose and treat skin diseases within its approved list. Invasive cosmetic procedures (cosmetic surgery, deep bodily interventions to alter appearance) fall outside an ordinary dermatology clinic’s scope — they may only be performed at hospitals with a cosmetic specialty or equivalently licensed facilities. Health inspectors have penalized many dermatology/cosmetic facilities for unapproved invasive techniques, unlicensed personnel, and out-of-scope advertising.
5. Notes for obstetrics and pediatrics clinics
Obstetrics and pediatrics specialty clinics mainly provide outpatient examination, consultation and treatment within their approved scope. Obstetric interventions (deliveries, surgery) belong to hospitals or facilities with a correspondingly approved technique list — a specialty clinic is not automatically entitled to perform them.
Q: Can one clinic cover dermatology, obstetrics and pediatrics?
A: Yes — but it must be licensed as a general clinic (meeting Article 42) or split into separate specialty clinics. A dermatology specialty license cannot simply “cover” obstetrics and pediatrics.
Q: Can a dermatology clinic offer filler or botox injections?
A: Only if these techniques are on the facility’s approved list and performed by properly licensed practitioners. Injectables are invasive procedures — doing them off-list is a violation.
Planning a specialty clinic and need help choosing the right model and technique list? Contact us for advice.
This article was prepared by the FLAW AI Legal Council. It is pending QA review before owner approval; information is for reference only and does not replace legal advice for your specific case.