Introduction
On 25 June 2024, the Government of Vietnam issued Decree No. 69/2024/ND-CP on electronic identification and authentication (“Decree 69“), which repealed Decree No. 59/2022/ND-CP. A key transitional provision under Article 40.4 of Decree 69 stipulates that from 1 July 2025, accounts created via the National Public Service Portal or ministerial/provincial administrative platforms for enterprises will no longer be valid.
As of 1 July 2025, only electronic identification (“eID“) accounts issued in accordance with Decree 69 are accepted for accessing online public services, including tax filings and electronic payments.
Key Obligations for Enterprises
All enterprises established or operating in Vietnam, including foreign direct investment (“FDI“) enterprises, are required to hold their own valid eID accounts in order to access administrative services. The key requirements are as follows:
- eID registration must have been completed by 1 July 2025.
- Registration could be carried out online via the VNeID application, using a Level-2 eID account held by the legal representative or a duly authorised person.
- Applications must include accurate and up-to-date information on the enterprise and its legal representative (e.g. full name, Vietnamese citizen ID number, or eID number for foreign nationals).
- In the event of any mismatch between the legal representative’s eID and the enterprise registration records (e.g. if the company was registered using a passport), enterprises are advised to update their business registration information with the Department of Planning and Investment.
- All FDI enterprises are subject to Decree 69 and are required to register for eID accounts. However, in cases where the legal representative of an FDI enterprise is a foreign national, Level-2 eID accounts remain operationally unavailable pending full implementation by the Ministry of Public Security of Level-2 eID issuance procedures for foreign nationals. In such cases, a transitional solution remains in effect, under which FDI enterprises may temporarily continue using their existing accounts (e.g. electronic tax credentials) until further notice.
Additional Details
Decree 69 provides additional details as follows:
- Administering authority: The eID system is administered by the Police Department for Administrative Management of Social Order (C06 – Ministry of Public Security).
- Processing time: Processing time is up to three working days for standard eID issuance (or up to 15 working days if verification from external data sources is required).
- Authentication levels: Enterprise eID accounts are not classified by levels, unlike individual accounts, but may still require two-factor authentication for access to certain sensitive services.
- Legal effect: An eID account has the same legal validity as a hard-copy document when an entity is submitting information for administrative or transactional purposes.
Current Gaps and Recommendations
- At present, there is no unified mechanism similar to the eID system for organisations that are not registered with the Department of Planning and Investment (e.g. representative offices or foreign non-governmental organisations (NGOs)), due to a lack of verified data within the national business registry.
- Enterprises are strongly advised to ensure that their eID accounts are active and compliant to avoid disruptions in public service access or fulfilling tax obligations.
- Until Level-2 eID functionality is fully available for foreign legal representatives, affected enterprises should continue to monitor guidance that relevant authorities may issue in relation to this.
This Update was authored by Dr. Le Hong Phuc.
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