Tiếng Việt
Dear Valued Clients,
On 13 August 2026, the Government officially promulgated Decree No. 320/2026/ND-CP (“Decree 320”), amending and supplementing a number of articles of Decree No. 69/2024/ND-CP dated 25 June 2024 on electronic identification and authentication (“Decree 69”). Decree 320 takes effect from 28 September 2026. Decree 320 introduces significant improvements aimed at addressing existing difficulties, simplifying administrative procedures, and facilitating foreign nationals (“FN”) in registering for and using electronic identification accounts, as well as conducting transactions in the digital environment in Vietnam.
To assist enterprises (particularly foreign-invested enterprises and enterprises employing foreign workers) and individual FNs in proactively reviewing and updating their compliance procedures, this article provides an analysis of five notable changes introduced by Decree 320.
- Expansion of the categories of foreign nationals eligible for electronic identification accounts
Pursuant to Article 3 of Decree 320, FNs who have lawfully entered Vietnam or are lawfully residing in Vietnam are eligible to be considered for the issuance of electronic identification accounts upon request. This provision officially removes the legal barrier under the previous Decree 69, which only permitted FNs holding permanent residence cards or temporary residence cards to register for such accounts. This change enables investors, experts, and workers entering Vietnam for short-term assignments, as well as newly arrived personnel who have not yet obtained temporary residence cards, to access the national electronic identification system immediately.
- Abolition of the classification of electronic identification accounts by level for foreign nationals
Instead of classifying accounts into Level 1 and Level 2, as provided under the previous regulations, Articles 3 and 5 of Decree 320 establish a unified management mechanism under which electronic identification accounts for foreign individuals are no longer differentiated by level. This simplification optimizes the registration process and eliminates complicated tiered authentication procedures, thereby enabling FNs to access public services and digital utilities in Vietnam more easily.
- Standardization of a streamlined and clear procedure for applying for electronic identification accounts
Article 6 of Decree 320 replaces Article 11 of Decree 69 in its entirety. The new procedure consists of the following six steps:
Step 1: The FN visits the immigration authority of the provincial-level police, presents a valid passport or other valid international travel document, and completes the account issuance procedures.
Step 2: The FN completes the application form using Form TK01, specifying their mobile telephone number registered in their own name, email address (if any), and other information requested for integration into VNeID.
Step 3: The receiving officer enters the information into the system, collects facial images and fingerprints for verification against the National Immigration Database, and instructs the FN to download, install, and complete the required declarations on VNeID.
Step 4: The immigration authority submits a request for account issuance to the authority responsible for managing and operating the electronic identification and authentication system.
Step 5: The result is notified through VNeID, the mobile telephone number registered in the FN’s own name, or the email address.
For FNs under 14 years of age, persons under guardianship, and persons represented by legal representatives, the relevant individual must attend the procedure together with their representative or guardian. The representative or guardian uses a mobile telephone number registered in their own name to complete the declaration and registration.
The following table compares the procedures under Decree 69 and Decree 320:
| Criteria | Decree No. 69/2024/ND-CP | Decree No. 320/2026/ND-CP |
| Method of application | Level 1: Self-registration through VNeID by entering passport details and taking a facial photograph using a digital device. Level 2: In-person application at an immigration authority. | Unified procedure: Applicants must visit an immigration authority; the separate online self-registration procedure is no longer available. |
| Receiving authority | Immigration authorities under the Ministry of Public Security or provincial-level police. | Immigration authority of the provincial-level police. |
| Biometric data | Level 1: Facial image. Level 2: Facial image and fingerprints. | Facial image and fingerprints, verified against the National Immigration Database. |
| Assistance with VNeID installation | No specific provision requiring assistance at the Level 2 reception stage. | The receiving officer instructs the applicant to download, install, and complete the required declarations on VNeID. |
| FNs under 14 years of age, persons under guardianship, and persons represented by legal representatives | Level 1: The representative registers through VNeID. Level 2: The applicant attends the procedure together with the representative. | The applicant attends the procedure together with the representative or guardian; the representative or guardian uses a mobile telephone number registered in their own name. |
- Significant reduction in the processing time for electronic identification account applications
Article 7 of Decree 320, which amends Clause 3 and Point b, Clause 4 of Article 13 of Decree 69, provides for a reduction in administrative processing times based on the availability of biometric data in the relevant system. Where the FN’s facial image and fingerprints are already available in the National Immigration Database, the account issuance period is reduced to no more than two working days. Where such biometric data are not yet available, the maximum processing time is also reduced to no more than five working days.
| Case | Decree No. 69/2024/ND-CP | Decree No. 320/2026/ND-CP |
| FN applying for a Level 1 account | No more than one working day. | No longer applicable because the classification by level has been abolished. |
| FN whose facial image and fingerprints are already available in the National Immigration Database | No more than three working days. | No more than two working days. |
| FN whose facial image and fingerprints are not yet available in the National Immigration Database | No more than seven working days. | No more than five working days. |
| Organizations whose information is already available in national or specialized databases | No more than three working days. | Unchanged. |
| Organizations whose information requires verification because it is not available in the relevant databases | No more than 15 days. | No more than 10 working days. |
Promotion of the integration and legal use of immigration-related documents
Decree 320 introduces an Appendix specifying the standardized lists of documents eligible for integration and updating on VNeID, comprising List 1 (66 types of documents issued to individuals) and List 2 (140 types of documents issued to agencies and organizations). Documents in the immigration sector and those directly relevant to FNs include:
| List | Documents | |
| List 1 (Items 5–9) | Ordinary passports (generally issued to Vietnamese citizens); visas; visa exemption certificates; permanent residence cards for FNs; temporary residence cards for FNs. | |
| List 2 (Items 51–56) | Electronic visas; ABTC cards; Vietnam–Cambodia border passes; permits for entry into restricted areas and border areas; Vietnam–Laos border passes; temporary residence cards. | |
| List 2 (Item 90) | Work permits for foreign workers (issued by the Ministry of Home Affairs). | |
Once the above documents have been successfully integrated into VNeID, agencies and organizations processing administrative procedures may not require FNs to submit or present paper copies, except where the system is unable to retrieve or authenticate the relevant information or where otherwise provided by law. In addition, FNs who have completed electronic identification account registration or whose required data have been fully collected in the National Immigration Database are also permitted to use automated border control gates (“Autogates”) when completing immigration procedures.
As always, we hope that you find this article useful and look forward to accompanying and supporting you in the time ahead.
Yours sincerely,
ENT LAW LLC
