1. Mandatory Obligation under the New Regulation

As of July 1, 2025, Decree No. 69/2024/ND-CP officially takes legal effect and sets forth a mandatory requirement for enterprises to apply for and use electronic identification accounts. Accordingly, all enterprises operating in Vietnam, including foreign-invested enterprises (FDI enterprises), must carry out the procedure for obtaining an electronic identification account in order to:
(a) Log in and verify information on the National Electronic Identification Application (VNeID).

(b) Perform administrative procedures and access public services via electronic platforms.

(c) Engage in other lawful business-related activities as required.

In cases where the legal representative of an FDI enterprise is a foreign national, the electronic identification process involves specific and distinct requirements. This is a compulsory legal condition for transparent and effective enterprise operations in Vietnam’s digitized administrative system.

2. 4-Step Electronic Identification Process for FDI Enterprises

The procedure for granting an electronic identification account to an FDI enterprise with a foreign legal representative includes the following steps:

(a) Step 1: Issuance of Level 1 Electronic Identification Account for the Legal Representative

(i) Condition: The individual must hold a valid temporary or permanent residence card in Vietnam.

(ii) Procedure:

– Download and install the VNeID application on a digital device (smartphone, tablet, etc.);

– On the app, enter passport or international travel document number and registered email address or phone number (if any); fill in required information per instructions; capture a facial photo via the device and submit the request for account issuance to the electronic identification authority via VNeID;

– The police authority will notify the result of account registration via VNeID, phone number, or email.

(iii) Processing time: No more than 01 working day.

(b) Step 2: Issuance of Level 2 Electronic Identification Account for the Legal Representative

(i) Condition: The procedure must be conducted in person at the Immigration Department of the Ministry of Public Security or provincial-level Police Departments.

(ii) Procedure:

– Present a passport (or valid international travel document) and complete Form TK01 (issued with Decree No. 69/2024/ND-CP);

– The officer inputs personal information; captures facial photo and fingerprints for cross-verification with the National Immigration Database;

– The immigration authority sends a request for account issuance to the electronic identification management authority;

– The latter notifies the account registration result via VNeID, phone number, or email;

– The legal representative must activate the account on VNeID within 07 days from the date of receiving approval.

(iii) Processing time:

– Within 03 working days if facial and fingerprint data already exist in the national database;

– Within 07 working days if such data are not available.

(c) Step 3: Issuance of Electronic Identification Account for the FDI Enterprise

(i) Condition: Completion of Step 2.

(ii) Procedure:

– The legal representative (or their authorized person) uses their Level 2 electronic ID account to log into VNeID, input required information, and submit a request for the enterprise’s electronic identification account;

– Alternatively, the legal representative (or their authorized person) may complete Form TK02 (issued with Decree No. 69/2024/ND-CP) and submit it directly to the Electronic Identification and Authentication Authority or a convenient local ID management agency;

– The authority will verify the enterprise’s information in the National Business Registration Database, other national databases, and sector-specific databases;

– If the information is not available in such databases, the authority will conduct a verification process;

– The result will be notified via VNeID, phone number, or email;

– If the enterprise is not eligible for account issuance, the authority shall notify in writing, by message, or via the electronic ID account of the applicant.

(iii) Processing time:

– No more than 03 working days if enterprise data is already available;

– No more than 15 working days if verification is required due to lack of data.

(d) Step 4: Activation and Use of the Enterprise’s Electronic Identification Account

(i) Condition: After receiving approval of account issuance.

(ii) Procedure:

– The enterprise must activate its electronic identification account on VNeID within 07 days from the date of receiving the result;

– If the account is not activated within 07 days, the enterprise must contact the electronic ID authority via the official hotline to proceed with account activation.

(iii) Processing time: Within 07 days of receiving the account approval.

3. Recommendations

With the new provisions of Decree No. 69/2024/ND-CP, the issuance and activation of an electronic identification account for FDI enterprises is a compulsory and essential requirement for effective administrative procedures, digital transactions, and business operations in Vietnam. Accordingly, FDI enterprises are advised to:

(a) Proactively complete the identification procedure early to avoid disruption when submitting administrative applications or engaging in electronic transactions.

(b) Ensure that the foreign legal representative holds a valid temporary or permanent residence card, and that biometric data (facial photo and fingerprints) are prepared in advance.

(c) Authorize properly in writing if the legal representative does not directly perform the enterprise account application steps.

In the context of Vietnam’s strong push for digital transformation and administrative modernization, obtaining and using an electronic identification account is a mandatory legal requirement for all enterprises, including those with foreign legal representatives. Understanding and properly implementing the procedure not only ensures compliance but also helps enterprises save time, reduce legal risks, and optimize digital operations in Vietnam.