On 7 August 2025, the Government of Vietnam issued Decree No. 219/2025 (“Decree 219”) governing foreign workers working in Vietnam, amending Decree No. 152/2020, as amended (“Decree 152”). Modernizing and Liberalizing its talent mobility with its growth strategy.

Ambit

Decree 219 applies to foreign nationals working in Vietnam under one of 13 enumerated categories, including:

• Employees under labor contracts;
• Intra-company transferees and other transfers;
• Service providers, contractors, and volunteers;
• Representatives establishing a commercial presence;
• Family members of foreign diplomatic staff authorized under treaties;
• Investors, members of board of directors (including, chairperson) of a joint stock company, owners of LLCs for the capital threshold noted below (“Exempted”).
• Employees of NGOs, diplomatic missions, or international organizations.

Notable Change

• Decree 152/2020: Exempted with capital contribution ≥ VND 3 billion were exempt from work permits.
• Decree 219/2025: Exempted with capital contribution < VND 3 billion are expressly included as requiring work permits.

Job Position Requirements

Decree 219 retains the four categories of Manager, CEO, Expert, and Technical Worker, but redefines qualification thresholds:

Position	Decree 152	Decree 219
Manager	Aligned with Enterprise Law.	No substantive change.
CEO (executive)	Head of branch, rep office, or enterprise.	Same, but must have ≥ 3 years’ experience in relevant field.
Expert	Bachelor’s degree + ≥ 3 years’ experience.	(a) Bachelor’s + ≥ 2 years’ experience, OR (b) Bachelor’s + ≥ 1 year in finance, technology, digital transformation, innovation, or socio-economic priority sectors certified by ministries/authorities.
Technical Worker	≥ 1 year of training + ≥ 3 years’ experience.	(a) ≥ 1 year training + ≥ 2 years’ experience, OR (b) ≥ 3 years’ relevant experience without formal training.

Key: Term CEO is officially stated.

Authority

• Provincial People’s Committees (PPCs) remain the primary licensing authority, with delegation powers.
• Foreign workers across multiple provinces: the PPC of the employer’s head office has competence.

Digitalization

• All applications (issuance, reissuance, renewal, exemptions) must be filed via the National Public Service Portal.
• Criminal record certificates for work permit applications can be processed concurrently.

Key Work Permit Exemptions

Decree 219 expands and refines the exemption categories. Highlights include:

1. Capital Contributors ≥ VND 3 billion.
2. ODA consultants/experts engaged under international treaties.
3. Foreign journalists accredited by Ministry of Foreign Affairs.
4. Foreign students/interns under agreements.
5. Short-term workers in one of the above stated positions (<90 days’ / calendar year).
6. Intra-company transferees in WTO-committed service sectors, employed ≥ 12 months.
7. Digital transformation, science, and innovation experts certified by ministries or PPCs.

Procedural Distinction

Certain categories (e.g., short-term assignments, major investors) require only notification to authorities, not formal exemption confirmation.

Principal Requirement – Permits, Renewals, and Validity

Application Requirements

• Medical examination certificate (≤12 months).
• Passport and criminal record certificate (≤6 months).
• Photos (4×6 cm).
• Employer’s demand justification and documents proving position/working form.

Primary Processing Time

• Exemption confirmation: 5 working days.
• Work permit issuance: 10 working days.
• Reissuance: 3 working days.
• Renewal: 5–10 working days.

Validity Period

• Work permits and exemptions valid for up to 2 years
• Multiple renewals reinstated (Decree 152 allowed only 1 renewal)
• Validity linked to underlying contract or official document

Basic Revocation Scenarios

Grounds

• Expiration
• Employer/worker non-compliance
• Termination of employment or employer’s operations
• Worker’s violation of Vietnamese law leading to prosecution

Procedures

• Employers must return expired permits within 15 days to the issuing authority
• Competent authorities may revoke permits directly and notify the Immigration Department

Transitional Provisions

1. Permits/exemptions issued under Decree 152/2020 (amended by Decree 70/2023) remain valid until expiry.
2. Pending applications filed prior to 7 August 2025 continue under old rules (Decree 152/2020 or Decree 128/2025).
3. Exemptions for managers/CEOs/experts/technical workers under Decree 152 remain valid but must transition to categories under Decree 219 for renewal.
4. Provisions in Decree 128/2025 concerning delegation of powers (Art. 8 & Appendix II, Section 2) are repealed.

Strategic Implications for Businesses

• Compliance Burden Shift: Employers must adapt to a digital-only regime and update internal HR/legal processes.
• Investor Threshold Clarity: Only capital contributors ≥ VND 3 billion are exempt; others must obtain work permits.
• Sector-Specific Advantage: Relaxed requirements for experts in technology, innovation, and digital transformation facilitate talent attraction in strategic sectors.
• Extended Expatriate Planning: With multiple renewals allowed, companies can plan for long-term expatriate assignments.
• Stricter Reporting Duties: Employers must track expiry, report revocations, and notify authorities of multi-province assignments. Non-compliance risks administrative penalties and potential revocation.
• Transitional Flexibility: Current permits remain valid; however, future renewals will be governed by Decree 219 standards. Employers should proactively review existing expatriate portfolios.