Vietnam’s 2024 digital transformation[1] has begun to promote advances in science, technology, and innovation for a high-income, digital economy. To streamline administration and reduce bureaucracy, the new electronic identification (“e-ID”) account is available to all citizens and residents currently living in Vietnam and to all companies operating in Vietnam. We discuss the regulatory framework governing electronic identification and authentication. We also discuss the essence and necessity of e-ID accounts for foreign residents and for foreign-owned companies in Vietnam.
- GOVERNING REGULATIONS
Vietnam’s first regulation on electronic identification and authentication for individuals and organizations was introduced in 2022. On June 25, 2024, the government promulgated Decree No. 69/2024/ND-CP on Regulations for Electronic Identification and Authentication (“Decree 69”). It took effect on July 1, 2024. Decree 69 governs electronic identification and authentication. This decree modifies regulations on registration of electronic identification for foreign residents in Vietnam and for Vietnamese companies. The new arrangements that relate to foreigners track existing rules that apply to Vietnamese.
- THE ESSENCE OF E-ID ACCOUNTS
An e-ID account is a collection of information in a digital identification and authentication system that uniquely identifies individuals or organizations. For individuals, e-ID accounts are classified into Level 1 and Level 2 accounts. For companies, e-ID accounts are issued as Corporate e-ID accounts.
An e-ID for individuals contains an ID number[2], full name, D.O.B, gender, nationality, date and place of issuance of passport/travel document, portrait photo and fingerprints[3]. A Corporate e-ID contains the company’s ID number, name (in Vietnamese, and as abbreviated or in a foreign language), date of establishment, headquarters’ address, tax ID number, enterprise code, e-ID code, and the Legal representatives’ full names and personal ID numbers. An e-ID account is used to log into and access features and services on VNeID[4]. As stipulated in Decree 69, an e-ID account, together with any integrated data[5] has the same legal validity as the corresponding physical documents, which can be used for administrative procedures, public services, and other transactions and activities.[6]
Electronic identification, through e-ID accounts, refers to the process of linking a real-world identity with a digital identity. Electronic authentication involves verifying and confirming that the user of an e-ID account is indeed the legitimate holder of that digital identity. This verification is performed for each transaction or procedure and may involve various methods, including passwords, secret keys, barcodes, one-time passwords (OTP code), identity cards, passports, facial images, fingerprints, voice recognition, iris scans, or other electronic methods.[7] Hence, electronic identification and electronic authentication establish a reliable digital trust framework, ensuring that electronic transactions are transparent and traceable.
- PRACTICE OF E-ID ACCOUNTS
- 1. NECESSITY
Prior to 1 July 2025, companies had separate corporate accounts on different public service portals (eg, tax, customs, business registration, and other provincial-level portals), typically using their enterprise code or tax code. Decree 69 provides a one-year transitional period for companies to obtain corporate e-ID accounts, after which, from 1 July 2025, public service systems will be integrated with the VNeID system. Consequently, existing corporate accounts on digital public service portals will no longer be accepted, and companies are required to use a unified e-ID account to access and perform those procedures on one single national public portal.[8] On that basis, tax administration offices, including the General Department of Taxation under the Ministry of Finance and local tax departments, have issued notifications and reminders urging companies to complete their e-ID registration to ensure no disruptions or rejection of tax filings, administrative procedures, and other transactions. This means Vietnamese entities, including foreign-owned Vietnamese enterprises, must create e-ID accounts.
For foreign nationals residing in Vietnam, registration for either a Level 1 or Level 2 e-ID remains voluntary and demand-driven, with no requirement imposed by the government. However, the registration of e-ID accounts for companies necessitates the involvement of the legal representative’s Level 2 e-ID account. Although the legal representative may authorize another individual to carry out the registration using that individual’s Level 2 e-ID account, the legal representative must ultimately use their own Level 2 e-ID account to confirm the application. Accordingly, while foreign individuals are not generally required to obtain an e-ID account, foreign nationals acting as legal representatives of foreign-owned Vietnamese companies are required to possess a Level 2 e-ID account.
- 2. REGISTRATION
Established or registered agencies/organizations in Vietnam, including foreign-owned companies, are eligible to apply for e-ID accounts. Registration for a Corporate e-ID account also needs the consent of all legal representatives of the company. Registering a Corporate e-ID account must be carried out by the legal representative (“LR”) of the company or by a duly authorized person (authorization will be confirmed by the LR on VneID).
The prerequisite for a foreigner to obtain an e-ID account is her Vietnamese permanent or temporary residence card[9] (“PRC/TRC”). A foreign individual aged six (06) years or older with a PRC/TRC is eligible to receive a Level 1 e-ID account, and a Level 2 e-ID account in case they elect to apply for one. A foreign individual under six (06) years of age with a PRC/TRC may be granted a level 1 e-ID account. A guardian must apply for individuals under 14 years of age.
The issuance of a Level 1 e-ID account and corporate e-ID account can be accomplished via VNeID on a digital device. For the issuance of a Level 2 e-ID account, foreigners must apply in person at the immigration department or the provincial police authority. The application dossier includes a written application form (which requires their Vietnamese registered mobile number, email address), as well as biometric data such as a facial image and fingerprints.
- 3. PROS & CONS
Foreign residents with a Level 2 e-ID account can authenticate their identity for transactions such as banking and leasing, access public services easier, eg, digital services to make a tax or residency declaration, and to store electronic residence cards and other official documents. The Level 2 e-ID is the digital equivalent of a passport in most administrative processes, ultimately reducing the need to carry physical passports or other documents. For enterprises, e-ID codes facilitate electronic signing of documents or contracts, online tax declarations, and public services such as business licenses or construction permits. Without e-ID accounts, companies would be required to follow traditional administrative procedures, which are paper-based, time-consuming, and resource-intensive, often involving in-person submissions and complex documentation. Accordingly, electronic identification and authentication streamline public service processes, making them more efficient and convenient for companies to comply with regulatory requirements.
However, a significant drawback of this regulation is that foreign individuals who do not reside in Vietnam or do not hold a valid PRC/TRC are not eligible to register for a Level 2 e-ID account and must await further guidance from the authorities. In such circumstances, foreign companies operating in Vietnam, particularly those without formal establishment and only subject to tax administration, and without a legal representative residing in Vietnam, may face substantial operational constraints, as they can expect difficulties accessing public service portals after 1 July 2025.
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In conclusion, by streamlining procedures and centralizing data on citizens, residents, and entities, electronic identification and authentication serve as a key tool for digital governance. While the benefits are clear, the mandatory implications create concrete compliance obligations for businesses. Accordingly, obtaining an e-ID account is now necessary for individuals and enterprises operating in Vietnam.
[1] Politburo Resolution 57-NQ/TW dated December 22, 2024 on breakthroughs in the development of science, technology, innovation, and national digital transformation.
[2] This number refers to a unique numerical string generated by the system to manage an e-ID of a foreign individual.
[3] Level 2 e-ID accounts additionally include fingerprints, whereas Level 1 accounts are limited to basic information and portrait photos.
[4] VNeID is a digital platform developed and operated by the National Population Data Center under the management of the Ministry of Public Security.
[5] For Vietnamese citizens, this could include their driver’s license, residency information, passport, and health insurance information. For foreigners, this includes their passport, visa, and residency information.
[6] Article 9 of Decree 69.
[7] Articles 3.6 to 3.8 of Decree 69.
[8] Article 40.4 of Decree 69.
[9] A temporary/permanent residence card is a document issued by a Vietnamese authority to a foreigner who is permitted to reside in Vietnam for a certain period of time or indefinitely, and this card, instead of a visa, is valid for a foreigner.
By Ho Huynh Bao Tran
