Employment Services No Longer a Conditional Business Line from July 1, 2026

The promulgation of the Law on Investment 2025 marks a significant turning point in the legal framework for investment management, notably removing the employment service business from the list of conditional business lines. Although this provision helps enterprises optimize capital and reduce administrative procedures, investors must pay special attention to its effective date.  

Therefore, clarifying the legal bases and applicable regulations during the transition period will serve as an essential foundation to help enterprises proactively plan an appropriate legal compliance roadmap. 

1. Legal basis for abolishing conditions for employment service business: 

Regarding the legal basis, previous laws established a strict control mechanism over labor supply activities through mandatory requirements for operating licenses and escrow deposits. However, driven by the orientation of administrative procedure reform, these barriers have been removed to create a transparent and open business environment and reduce the financial burden on investors.  

This systemic change is specifically recorded in the Law on Investment 2025. Pursuant to Article 51.2, and Appendix IV of the Law on Investment No. 143/2025/QH15, the employment service business is no longer included in the List of conditional business lines. This provision reflects a shift in the State management approach from a “pre-inspection” to a “post-inspection” mechanism, respecting the freedom of enterprise of economic organizations. 

2. Effective date of the new provision: 

Although the Law on Investment 2025 took effect on March 01st, 2026, the provision on abolishing the conditions for the employment service business does not take effect immediately. Enterprises arbitrarily applying the incorrect timeline may face severe legal risks, including administrative sanctions for conducting business operations without fully meeting statutory conditions. 

The time of application is clearly specified in Article 51.2 of the Law on Investment 2025: “Article 7 and the List of conditional business lines stipulated in Appendix IV promulgated together with this Law shall take effect from July 01st, 2026”. 

Accordingly, from now until the end of June 30th, 2026, from a legal perspective, the employment service business remains subject to the current regulations governing conditional business lines. 

3. Applicable legal framework during the transition period: 

The existence of a transition period from the promulgation of the Law on Investment 2025 until Appendix IV takes effect necessitates maintaining stability in the State management of labor. Pending the issuance of detailed guiding documents on the transition mechanism by competent State agencies, economic organizations must strictly fulfill current statutory obligations to safeguard the legitimate rights and interests of employees. The legal basis governing these activities in the current period is Decree No. 352/2025/ND-CP. 

“Pending guiding documents from competent authorities, the issuance, re-issuance, extension, and revocation of the License for employment service operations, and the withdrawal of escrow deposits by enterprises operating employment services shall continue to be implemented in accordance with Decree No. 352/2025/ND-CP dated December 30th, 2025 of the Government detailing a number of articles of the Law on Employment regarding employment services.” 

Therefore, for procedures arising at present, such as applying for a new operating license, terminating operations, or requesting the release of escrow deposits, enterprises are strictly required to fully satisfy the standards, dossiers, and procedures prescribed by the law on employment until a replacing mechanism is introduced. 

4. Conclusion:

The Law on Investment 2025 represents a crucial step forward in perfecting the legal corridor for investment, particularly through the abolition of barriers to the employment service business. Nevertheless, the principle of legal application requires investors and economic organizations to strictly adhere to the effective date of the new list, which is July 01st, 2026. During the current transition period, maintaining business conditions, including operating licenses and escrow deposit obligations, remains a mandatory statutory requirement to ensure security and transparency in enterprise operations. 

Submission date: June 20th 2026

Related posts

  1. Changes to the business conditions for employment services from mid-2026
  2. Regulatory notes for enterprises operating in Employment services (Part 3)
  3. Conditions for foreign investors to operate in employment services in Vietnam

Disclaimers:

This article is for general information purposes only and is not intended to provide any legal advice for any particular case. The legal provisions referenced in the content are in effect at the time of publication but may have expired at the time you read the content. We therefore advise that you always consult a professional consultant before applying any content.

For issues related to the content or intellectual property rights of the article, please email cs@apolatlegal.vn.

Apolat Legal is a law firm in Vietnam with experience and capacity to provide consulting services related to Business and Investment and contact our team of lawyers in Vietnam via email info@apolatlegal.com.



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