LEVEL-2 ELECTRONIC IDENTIFICATION

LEVEL-2 ELECTRONIC IDENTIFICATION (eID) REGISTRATION FOR FOREIGNERS IN VIETNAM

I. INTRODUCTION

As of July 1, 2025, Vietnam officially launched the implementation of Level-2 electronic identification (eID) registration for foreigners through local Immigration Departments in selected provinces such as Hanoi, Ho Chi Minh City, and Dong Nai. This is a significant milestone in the Government of Vietnam’s roadmap toward nationwide digital transformation and centralized identity verification across administrative, legal, and financial domains.

Level-2 eID is a critical component for enabling foreigners, particularly those serving as legal representatives of companies in Vietnam, to access and use e-government services—including tax registration, e-invoice issuance, digital banking, labor reporting, and business licensing.

II. ELIGIBILITY AND REQUIRED DOCUMENTS

According to Decree 69/2024/ND-CP and internal guidelines from the Ministry of Public Security, foreign nationals must meet specific conditions to register for a Level-2 eID:

1. Who is eligible?

• Foreigners legally residing in Vietnam;

• Holding a valid temporary residence card issued by Vietnamese authorities;

• Acting as legal representatives or key personnel in enterprises operating in Vietnam.

2. Required documents:

• Passport (valid and consistent with visa/residence documents);

• Temporary residence card still valid at the time of application;

• Form TK01 (official application form as per Decree 69/2024/ND-CP);

• Vietnamese mobile phone number registered under the applicant’s personal name;

• Personal email address for contact and digital verification purposes.

All documents must be presented in person at the Immigration Department of the province/city where the applicant is registered to reside.

III. REGISTRATION PROCESS

1. Personal presence required: Unlike some domestic citizen services that allow for online pre-registration, foreigners must appear in person to submit their documents and undergo biometric verification (photo and fingerprint capture).

2. Verification and approval: After submission, immigration officers will verify the documents and information against national databases. If valid, an eID Level-2 profile will be created and issued.

3. Linkage to electronic platforms: Once registered, the foreigner’s eID will be linked to national digital systems (e.g., tax, banking, business licensing, social insurance), enabling secure access and electronic signatures for official transactions.

IV. CURRENT LIMITATIONS AND CHALLENGES

Although this initiative is a progressive step, several limitations hinder its broad application:

• Foreigners who do not currently reside in Vietnam or who do not hold a valid temporary residence card are not eligible for registration. This particularly affects foreign legal representatives who are based overseas and only occasionally travel to Vietnam.

• The requirement for a Vietnamese mobile phone number in the applicant's own name poses a challenge for foreigners who use corporate phones or foreign-registered SIM cards.

• No remote or digital alternative is currently available, meaning all eligible individuals must physically visit an Immigration Office—a time-consuming process that may impact operations in large organizations with multiple foreign representatives.

• Lack of official guidance for cases where the legal representative is replaced by another foreigner or for parent companies registering eID for multiple foreign nationals under one business group.

V. STRATEGIC RECOMMENDATIONS FOR BUSINESSES

1. Audit and prepare legal representative profiles: Companies should proactively review the residency status, residence card validity, and mobile/email registration status of their foreign representatives in Vietnam.

2. Coordinate with local immigration authorities: Businesses may reach out to provincial Immigration Departments for clarification on acceptable documentation or appointment scheduling.

3. Update internal compliance policies: Incorporate eID registration into HR, legal, and licensing workflows to avoid delays in tax and business administration processes.

4. Anticipate future regulations: Stay updated with additional guidance from the Ministry of Public Security, particularly regarding:

   • Group or proxy registration for foreign entities;

   • Digital onboarding or remote authentication mechanisms;

   • Integration of eID with e-signature providers and tax platforms.

5. Communicate with investors or headquarters: FDI companies should brief parent companies and key foreign personnel on Vietnam’s evolving digital identity regulations, especially where board members or executives are based abroad.

VI. CONCLUSION

The implementation of Level-2 eID for foreigners represents a forward-thinking effort by the Vietnamese government to harmonize administrative processes, improve national security, and support the digital transformation of both public and private sectors. While the legal framework is gradually taking shape, practical hurdles—such as in-person registration, phone number ownership, and limited eligibility—require businesses to take a proactive approach. Early preparation and close coordination with authorities will ensure compliance and unlock the full benefits of eID systems for foreign investors and professionals operating in Vietnam.