A telecom service license does not last indefinitely. Under Article 33.2 of the Telecom Law 24/2023/QH15 (effective 1 July 2024; Article 33 unamended), the maximum validity depends on whether the enterprise has network infrastructure: up to 15 years for licenses with network infrastructure, up to 10 years for licenses without.
Short answer
- License with network infrastructure: maximum 15 years (Article 33.2, Telecom Law 24/2023/QH15).
- License without network infrastructure: maximum 10 years.
- Renewal: the combined period (initial grant + renewals) must not exceed the maximum above (Article 39.2.b).
- This article covers validity periods only; licensing conditions are a separate topic.
License validity table
| License type | Maximum validity | Basis |
|---|---|---|
| Telecom service license with network infrastructure | 15 years | Art. 33.2, Telecom Law 2023 |
| Telecom service license without network infrastructure | 10 years | Art. 33.2, Telecom Law 2023 |
“With network infrastructure” means the enterprise builds and owns transmission infrastructure (cables, BTS stations, core networks) to provide services; “without network infrastructure” means it leases infrastructure from others (the MVNO — mobile virtual network operator — model is the classic example). The 15-year / 10-year ceilings reflect the different infrastructure investment levels of the two models.
Note: these are maximum periods — the licensing authority may grant a shorter term depending on the dossier and business plan.
Renewal: the “aggregate cap” rule
Article 39.2.b of the Telecom Law 2023 provides the renewal principle: the aggregate license period (initial term plus all renewals) must not exceed the maximum set in Article 33.2.
Example: a with-infrastructure license initially granted for 10 years may be renewed for at most 5 more years (15 total) — not for another full 10-year cycle. Once the aggregate cap is reached, the enterprise must apply for a new license to continue providing services.
What if the license expires without renewal or a new grant?
- The enterprise may not continue providing telecom services once the license has expired without renewal or a new grant — operating without a license is a violation subject to administrative penalties.
- File the renewal dossier well before expiry, giving the authority enough time to appraise it and avoiding a legal “gap”.
- While awaiting the renewal decision, plan service continuity for existing customers in compliance with regulations (e.g., notifications, migration support) — do not simply carry on as if licensed.
What businesses should note
- Track expiry: put the license expiry date into the compliance alert system and start renewal preparation several months ahead.
- Calculate the aggregate cap: for long-term investment planning (especially infrastructure projects), count the remaining headroom within the 15-year/10-year ceiling to plan for a new grant.
- Keep compliance records: retain licensing, renewal, and periodic reporting dossiers — the basis for renewal/new-grant procedures.
FAQ
Can a 10-year (no-infrastructure) license be converted to the 15-year (with-infrastructure) type? Conversion follows a real change in infrastructure investment, not a simple “term upgrade”. An enterprise investing in network infrastructure applies for licensing matching the new model.
Has Article 33 of the Telecom Law 2023 been amended? As of writing (14 October 2026), Article 33 is unamended — the 15-year/10-year ceilings apply as written.
Do foreign investors face different validity caps? The 15-year/10-year maximums apply generally. Foreign investors’ market-access conditions (ownership ratios, investment forms) are a separate topic outside this article’s scope.
Sources
- Telecom Law 24/2023/QH15 (effective 1 July 2024): Article 33.2 (15-year / 10-year maximums), Article 39.2.b (renewal principle); in force, Article 33 unamended.
Need telecom licensing advice? FLAT Law Firm advises on new grants and renewals of telecom licenses, validity tracking, and reporting compliance. Contact us at https://flaw.vn/en/contact/.
This article is for general reference under current law as of 14 October 2026 and does not constitute legal advice for any specific matter. Consult a lawyer before acting.
Transparency note: This article was produced by FLAT Law Firm’s AI content production system and is going through internal review before publication. It has not been reviewed by a human lawyer.