Clarify this first to avoid the most common mistake: an “employment service center” is a public service unit established by the State (a public employment service organization) — a private enterprise cannot “establish an employment service center.” Private enterprises may only establish an employment service enterprise. Any dossier or document using the wrong concept risks rejection or legal misunderstanding.
1. Current regime from 01/7/2026: notification replaces licensing
Under Resolution 66.18/2026/NQ-CP (effective 01/7/2026–28/02/2027), procedures for issuance, re-issuance and renewal of Employment Service Operating Licenses (Articles 13, 14, 15, 17, 18 of Decree 352/2025/ND-CP) are suspended. Instead, employment service enterprises must:
- Notify the Department of Home Affairs via the National Employment Exchange (vieclam.gov.vn);
- Publicly disclose information, post working hours and service fee schedules;
- Submit semi-annual reports (before 20/6) and annual reports (before 20/12);
- Submit to state post-activity inspection.
This regime is temporary, ending 28/02/2027. After that date, businesses must await new regulations — the current mechanism must not be assumed permanent.
2. Legal framework and validity (as of 14/10/2026)
- Employment Law of 2025 (effective 01/01/2026) — replacing Employment Law 38/2013.
- Decree 352/2025/ND-CP (effective 01/01/2026) on employment services — replacing Decree 23/2021/ND-CP.
- Resolution 66.18/2026/NQ-CP (01/7/2026–28/02/2027) — suspending issuance/re-issuance/renewal of employment service licenses.
- Investment Law 143/2025/QH15 (Article 7, Appendix IV, from 01/7/2026) — “employment service business” removed from the list of conditional business lines.
- Decree 283/2026/ND-CP (10/9/2026) — labor administrative sanctions, replacing Decree 12/2022/ND-CP.
3. Capability conditions under Decree 352/2025 (reference framework)
Although licensing procedures are suspended, the capability conditions in Decree 352/2025/ND-CP (Article 15) remain the reference for minimum enterprise capability:
- Premises: a head office location owned or leased with at least 24 months of remaining lease term;
- Escrow: VND 300,000,000 at a commercial bank;
- Legal representative: full civil act capacity, holding a university degree or at least 02 years of experience in employment services or labor supply.
4. Licenses issued before 01/7/2026
Employment service operating licenses issued before 01/7/2026 remain valid — enterprises may continue operating until the expiry date stated on the license, unless revoked as prescribed.
5. Ongoing operational obligations
- Publicly post working hours and service fee schedules charged to workers and employers.
- Submit semi-annual reports (before 20/6) and annual reports (before 20/12).
- Protect workers’ rights; do not charge unlawful fees; keep full service records for post-activity inspection.
6. Violations and sanctions
Violations of employment service regulations are sanctioned under Decree 283/2026/ND-CP. Businesses should consult the original text to identify the applicable conduct and sanction framework.
7. Practical recommendations
- Use correct terminology: “employment service enterprise” — never write “establishing an employment service center.”
- Notify operations via the National Employment Exchange; do not wait to “apply for a license.”
- Maintain the VND 300 million escrow and compliant premises throughout operations.
- Watch the 28/02/2027 milestone to update to the new regime promptly.
- Do not cite Employment Law 2013, Decree 23/2021 or Decree 12/2022 — all have been replaced.
8. FAQs
Can a private enterprise establish an employment service center?
No. Employment service centers are public service units established by the State. Private enterprises may only establish employment service enterprises.
Do I need an employment service license in 2026?
No. From 01/7/2026 to 28/02/2027, issuance/re-issuance/renewal procedures are suspended; enterprises notify via the National Employment Exchange and report periodically.
What is the escrow amount for employment services?
VND 300,000,000 under Decree 352/2025/ND-CP.
When are periodic reports due?
Semi-annually (before 20/6) and annually (before 20/12).
Are old employment service licenses still valid?
Licenses issued before 01/7/2026 remain valid until expiry, unless revoked.
9. Legal sources
- Employment Law of 2025 (effective 01/01/2026; replacing Law 38/2013)
- Decree 352/2025/ND-CP (replacing Decree 23/2021/ND-CP)
- Resolution 66.18/2026/NQ-CP (01/7/2026–28/02/2027)
- Investment Law 143/2025/QH15 (Article 7, Appendix IV)
- Decree 283/2026/ND-CP (replacing Decree 12/2022/ND-CP)
Contact FLAT Law Firm: For advice on notification, reporting and escrow obligations for employment service enterprises, or labor law compliance in Vietnam, please contact FLAT Law Firm.
Disclaimer: This article provides general legal information only and does not constitute legal advice for any specific case. Laws and regulations may change; please consult a lawyer before applying.
Transparency notice: This article was prepared by our editorial team with quality review (QA) support from the AI Legal Council; it has not been reviewed or approved by a human lawyer.