Internal labor regulations (ILR) are a company’s “internal code” — without valid regulations, an employer can hardly discipline employees lawfully. The law issues no mandatory ILR template; each company builds its own under the 10 principal items of Article 118, Clause 2 of the 2019 Labor Code and must register them with the state authority when required.
1. Who must issue, who must register?
Issuance (Article 118, Clause 1): employers must issue internal labor regulations; where employing 10 or more employees, the regulations must be in writing.
Registration (Article 119): employers using 10 or more employees must register the regulations with the specialized labor agency of the provincial People’s Committee where the employer registers its business.
Key point: the 10-employee threshold is counted across the employer’s total workforce, not per branch. Where fewer than 10 employees are used: written issuance is not mandatory and registration is not required — but disciplinary and material-liability matters must be agreed in the labor contracts.
2. Checklist of the 10 principal items (Article 118, Clause 2)
Article 118, Clause 2 lists 10 items (a–k); the content must not contravene the law (detailed in Article 69 of Decree 145/2020/ND-CP):
- (a) Working hours and rest time;
- (b) Order in the workplace;
- (c) Occupational safety and hygiene;
- (d) Prevention of sexual harassment in the workplace;
- (dd) Procedures for handling sexual harassment in the workplace;
- (e) Protection of the employer’s property, business secrets, technological secrets and intellectual property;
- (g) Cases of temporarily assigning employees to work different from the labor contract;
- (h) Labor-discipline violations and handling forms;
- (i) Material liability;
- (k) Persons competent to handle labor discipline.
Note that (d) and (dd) are two separate items: preventing sexual harassment, and the procedures for handling it — do not merge them and miss one.
3. Mandatory: consult the grassroots employee representative organization
Before issuing, amending or supplementing the regulations, the employer must consult the grassroots employee representative organization (where one exists) (Article 118, Clause 3; Article 69, Clause 3 of Decree 145/2020). This is mandatory: the organization’s written comments are one of the 4 dossier items — without them, the registration dossier is incomplete.
4. Registration dossier — Article 120 of the Labor Code (not Article 70 of Decree 145/2020)
A serious citation trap: the ILR registration dossier comes from Article 120 of the 2019 Labor Code, comprising 4 items:
- The written request for ILR registration;
- The internal labor regulations;
- Written comments of the grassroots employee representative organization (where one exists);
- The employer’s documents on labor discipline and material liability (if any).
Article 70 of Decree 145/2020 governs the procedures for handling labor discipline — never cite it for the registration dossier.
5. Filing place, deadlines and effectiveness
- Filing place: the specialized labor agency of the provincial People’s Committee — in practice after the 2025 merger, the Department of Home Affairs (the statute still carries the old name “Department of Labor, Invalids and Social Affairs”). Do not mechanically use the old agency name in dossiers and guides. Filing is available via the National Public Service Portal (procedure “Registration of enterprise internal labor regulations”, code 2.001955); some localities have decentralized to commune level (e.g. Ho Chi Minh City — Official Letter 1351/SNV-LDTLBHXH/2025), so check local guidance.
- Filing deadline: within 10 days from the date of issuance of the regulations (Article 119, Clause 2) — counted from issuance, not from the date the request letter is signed.
- Processing: within 07 working days of receiving a complete dossier, if the content contravenes the law the authority notifies and guides the employer to amend, supplement and re-register (Article 119, Clause 3).
- Effectiveness: the regulations take effect 15 days after the competent authority receives the complete registration dossier (Article 121). Where fewer than 10 employees and the regulations are issued in writing: effectiveness is decided by the employer in the regulations.
Registration ≠ approval: the state authority only notifies where the content contravenes the law; there is no “ILR registration certificate”. And unregistered regulations (where registration is required) cannot serve as a basis for discipline.
6. After issuance: notification, posting — and sanctions
After issuance, the employer must: send the regulations to each grassroots employee representative organization (if any), notify all employees, and post the main contents where necessary in the workplace (Article 69, Clause 4 of Decree 145/2020).
Sanctions (Article 25 of Decree 283/2026/ND-CP):
- VND 1–3 million: failing to publicly notify or post the main contents of the regulations;
- VND 5–10 million: having no written regulations where 10+ employees are used; failing to register; failing to consult the employee representative organization; using regulations not yet effective or expired;
- VND 20–40 million (individuals): imposing fines or wage deductions instead of labor discipline. Organisations are fined double (Article 7).
Transitional provisions (Article 67 of Decree 283/2026/ND-CP): violations that occurred and ended before 10/9/2026 are sanctioned under Decree 12/2022/ND-CP; violations that began before but continue after 10/9/2026 are sanctioned under Decree 283/2026/ND-CP; and sanctioning decisions issued before 10/9/2026 that remain under complaint are governed by the law in force at the time of issuance.
FAQs
Does a company with 8 employees have to register ILR?
No. Under 10 employees, written issuance is not mandatory and registration is not required — but disciplinary and material-liability matters must be agreed in the labor contracts.
What does the registration dossier include?
4 items under Article 120 of the Labor Code: the written request; the regulations; the employee representative organization’s comments (where one exists); documents on discipline and material liability (if any).
Where is the dossier filed?
The provincial specialized labor agency — now the Department of Home Affairs (after the 2025 merger); filing via the National Public Service Portal is available.
When do the regulations take effect?
15 days after the competent authority receives the complete registration dossier (Article 121).
Is registration an “approval” process?
No. The authority only notifies where content contravenes the law and guides amendment and re-registration; no registration certificate is issued.
Cited legal bases
- Labor Code 45/2019/QH14: Article 118 (issuance duty, 10 items), Article 119 (registration), Article 120 (registration dossier), Article 121 (effectiveness).
- Decree 145/2020/ND-CP: Article 69 (content details, consultation, notification, posting); Article 70 (discipline-handling procedures — not for the registration dossier).
- Decree 283/2026/ND-CP: Article 25 (sanctions); Article 7 (organisations fined double); Article 67 (transitional provisions).
- National Public Service Portal: procedure “Registration of enterprise internal labor regulations” (code 2.001955).
Need internal labor regulations with all 10 mandatory items, registered correctly with the Department of Home Affairs? Contact FLAT Law Firm via the Contact page.
The information above is for reference only and does not constitute legal advice.
Transparency note: This article was drafted by FLAT Law Firm’s AI content production system and is awaiting review by the QA Council. It has not been reviewed by a human lawyer.