EN
©2001-2026 Atumi & Sakai
2026.9.24
1. Introduction
On 13 August 2026, the Vietnamese Government promulgated Decree 320/2026/ND-CP (Decree 320) amending several provisions of Decree 69/2014/ND-CP (Decree 69) guiding the electronic authentication and identification regime. Coming into effect on 28 September 2026, Decree 320 materially amends the access, usage and application procedure for foreign nationals’ VNeID accounts. VNeID is a mobile application developed by the National Population Database Center of the Ministry of Public Security of Vietnam. The primary purpose of VNeIDs is to authenticate personal identity, replace traditional documents, and facilitate secure public services and electronic transactions. VNeID accounts are used to access features, services and applications of an electronic identification and authentication system and an information system connected and shared according to regulations of law.
This legal update highlights the key amendments under Decree 320 and analyzes their implications for foreign nationals and foreign-invested enterprises operating in Vietnam.
2. Key changes
2.1. Broaden VNeID access for foreign nationals
Under Decree 320, any foreign national who has entered Vietnam legally or is legally residing in Vietnam is eligible to apply for a VNeID account. Previously, Decree 69 required foreign nationals to hold either a permanent residence card or a temporary residence card as a prerequisite to application for a VNeID account. Because these cards are not mandatory for all legal foreign residents, many foreigners living in Vietnam were excluded from obtaining a VNeID account.
2.2. Consolidated account application process for foreign nationals
For foreign nationals, a Level 1 account only provides basic electronic identity verification, cannot replace the presentation of original documents, and is strictly used for simple online transactions such as bill payments and certain public services; a Level 2 account, having been biometrically verified in person at the immigration authority, can be used for online transactions with higher and more complex authentication requirements, serving as a substitute for physical documents.
Decree 320 has removed the option allowing eligible foreign nationals to apply for a level one VNeID account digitally through their personal digital devices. Now, applications for both level one and level two VNeID accounts must be submitted in person at the immigration department of the provincial-level public security department. Applicants must submit a completed application form, present a valid passport or equivalent international travel document and undergo biometric verification, including facial image and fingerprint collection. Foreign nationals under 14 years of age, as well as those under guardianship or legal representation, must complete the registration process in person accompanied by their guardian or legal representative.
The foreign nationals will receive the application result either through the VNeID application, their registered mobile phone number or email address.
2.3.Expanded functionality of foreign nationals’ VNeID accounts
In addition to expanding the eligibility and consolidating application procedures for VNeID accounts, Decree 320 also expands the functionality of foreign nationals’ VNeID accounts to access more services. Previously, only level two accounts of foreign nationals were eligible to access specialized databases and all VNeID features; the features available to level one accounts were more limited. Decree 320 has changed this, allowing VNeIDs of foreign nationals to access full VNeID features, notwithstanding whether their VNeID account is level one or level two.
Additionally, Decree 320 now enables foreign nationals who have acquired VNeID accounts to utilize the automated border control gates at airports when entering and exiting Vietnam.
2.4. Shortened VNeID account processing time for organization applications
For organizations applying to open new VNeID accounts under Decree 320, the Government reduced the maximum processing time to 10 working days, applicable when verifiable data regarding the organization is missing from national or specialized databases. If the data is already available within national or specialized databases, the maximum processing time remains capped at 3 working days as previously established by Decree 69.
3. Implications of the changes for foreign nationals and businesses
Since June 1, 2026, the Vietnamese Government discontinued e-signature and token-based login methods for businesses wanting to access the National Public Service Portal and the Ministry of Public Security Public Service Portal. Businesses are now obliged to access these through their business VNeID account instead. Additionally, starting July 1, 2026, businesses executing electronic employment agreements must also verify this platform through a business VNeID account. These changes highlight the increasingly important role of VNeID accounts for both individuals and businesses operating in Vietnam.
Under the previous rules, however, opening a business VNeID account required the organization's legal representative to hold a Level 2 VNeID account, pursuant to Article 12.1 of Decree 69. Previously, this rule created difficulties for companies whose sole legal representatives were foreign nationals without a permanent or temporary residence card when registering a business VNeID account, forcing businesses to rely on workarounds including appointing an additional Vietnamese national with a VNeID account as a legal representative. Decree 320 addresses this issue by expanding foreign nationals’ eligibility for personal VNeID accounts, allowing these foreign nationals to obtain their own personal VNeID accounts and subsequently register VNeID accounts for their businesses.
The amendments brought about by Decree 320 are potentially beneficial. In particular, allowing foreign nationals with a VNeID account to use automated border control gates significantly streamlines immigration procedures for these foreign nationals. Additionally, shortening the processing time for both individual and business VNeID accounts can help prevent businesses from experiencing operational disruptions due to their inability to access public services that require a VNeID account.
Considering these regulatory shifts, foreign nationals who are legal representatives of companies in Vietnam and who do not yet possess a personal VNeID account are advised to register for a VNeID account after Decree 320 becomes effective on September 28, 2026. Once the representative’s personal VNeID account has been issued and activated, the organisation should subsequently register a Business VNeID account if one has not already been created to avoid any disruptions to employment-related procedures and other online administrative processes.