IMPACT – HIGH

What is the change?
The Vietnamese government has implemented multiple new travel measures to halt the spread of COVID-19.

What does the change mean? Travelers arriving from Italy or Iran who left those countries less than 14 days ago will be denied entry or will be placed in a government quarantine area. The Immigration Departments in Hanoi and Ho Chi Minh City have temporarily stopped issuing visas of all categories to Korean, Italian and Iranian nationals. Visa exemptions for citizens of South Korea and Italy have also been temporarily suspended until further notice.

  • Implementation time frame: Ongoing from March 2.
  • Visas/permits affected: Any visa used for inbound travel from the target countries and locations. Initial/new work permit and re-issues for Korean and Chinese nationals will also be impacted.
  • Who is affected: All travelers from Iran, Italy, South Korea and COVID-19-impacted areas. Korean and Chinese nationals working in Vietnam or wishing to do so may be affected as well.
  • Business impact: The new travel measures will affect all forms of travel from the targeted countries and COVID-19 areas, including travel for business.
  • Next steps: The new travel measures are in force until further notice. Employers should expect that any employees who are in the target countries or areas will be denied entry, placed in a government quarantine or be required to complete a medical declaration questionnaire upon arrival.

Additional information: The Ho Chi Minh City Labor Department has temporarily stopped accepting applications for initial/new work permits and renewals for Korean and Chinese nationals. Business and work visa renewal procedures for foreign nationals coming from countries strongly affected by the epidemic are subject to additional travel declaration requirements which the host company must sign. Travelers from areas impacted by COVID-19 may be requested to complete a medical declaration questionnaire after arriving in Vietnam, which a Health Quarantine officer will review.

Analysis & Comments: The new measures for travelers from Iran, Italy, South Korea and COVID-19-impacted areas represent Vietnam’s latest efforts to halt the spread of COVID-19. Those planning travel to Vietnam from the target countries and areas may wish to reconsider their plans. The response to the COVID-19 outbreak continues to develop, and Deloitte will provide additional updates as information becomes available.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – HIGH

What is the change? The Vietnamese Embassy in China has stopped issuing tourist, business and work visas to Chinese nationals and all other foreign nationals applying for visas in China.

What does the change mean? Chinese nationals and foreign nationals currently in China cannot apply for or obtain visas for travel to Vietnam. Foreign nationals applying for a visa-on-arrival pre-approval letter must prove they are not coming from mainland China, Hong Kong or Macau.

  • Implementation time frame: Ongoing.
  • Visas/permits affected: All visas.
  • Who is affected: Chinese nationals, all foreign nationals in China, and their employers.
  • Business impact: Employers of Chinese workers and foreign nationals currently in China may experience delays affecting employee mobility.
  • Next steps: Employers should anticipate further developments in the government’s policies regarding Chinese nationals and travel from China owing to the developing coronavirus situation.

Background: Many countries in the region have stepped up efforts over the last week to contain the spread of the coronavirus. Vietnam recently stopped issuing tourist, business and work visas to Chinese nationals and issued other directives aimed at discouraging visitors from China, anticipating further restrictions.

Analysis & Comments: The latest visa policy indicates that the government is implementing increasingly stricter measures in response to the coronavirus outbreak. The visa policy is still developing, and Deloitte will continue to monitor the situation and will provide updates as they become available.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2020. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

What is the change? The National Assembly has adopted amendments to its immigration law and a new labor law.

What does the change mean? Under changes to the immigration law, taking effect in 2020, foreign nationals will be allowed to convert status in-country under some circumstances, and visa-waived nationals will no longer be subject to a 30-day cooling-off period. Under the new Labor Code that takes effect in 2021, work permit exemptions will be expanded to certain owners and directors and to spouses of Vietnamese citizens, and work permits will be limited in duration to two years, extendable for an additional two years.

  • Implementation time frame: The amendments to the Law on the Entry, Exit, Transit and Residence of Foreigners take effect July 1, 2020. The new Labor Code takes effect Jan. 1, 2021.
  • Visas/permits affected: Work permits, visa conversion, visa waivers.
  • Business impact: The changes are intended to ease rules for expatriate workers and attract foreign investment.
  • Next steps: The government is expect to issue guidance in 2020 that will provide implementation details and additional clarifications.

The main changes are listed below.

2020 immigration law changes:

  • Change of visa category. Foreign nationals may change status in-country under certain circumstances and with proper documentation, eliminating the need to leave the country to apply for a new visa category. This will apply to business visa holders only, not to those holding tourist visas.
  • Visa-exempt nationals. Visa-waived nationals will be able to enter with only a passport as long as it will remain valid for at least six months, and will no longer be subject to a 30-day cooling-off period upon exit. This change benefits nationals of Denmark, Finland, France, Germany, Italy, Japan, Korea, Norway, Russia, Spain, Sweden, and the U.K.
  • Investor visas. Foreign investors will be issued visas and temporary residence cards with a duration of one to 10 years depending on the investment amount. Dependents will have a maximum duration of three years, renewable.
  • DN visas. DN visas will continue to be issued to foreign nationals coming to Vietnam for general business purposes or working less than 30 days per visit. The category covers foreigners working with entities whose legal status is regulated by Vietnamese law and foreigners conducting activities under international agreements to which Vietnam is a party.
  • Working (LD) visas. LD visas will continue to be issued for work permit holders and for those holding a work-permit exemption certificate, and the duration of the visa or temporary residence card will depend on the duration of the work permit.

2021 labor law changes:

  • Work permit exemptions. The following categories will be exempt from work permits: owners or capital-contributing members of limited liability companies that meet minimum contribution amounts designated by the government; chairs or members of the board of directors of a joint stock company that meet government capital contribution requirements; spouses of Vietnamese citizens.
  • Labor contracts. Labor contracts for foreign nationals must not exceed the validity period of the work permit. Employers may enter into multiple definite-term labor contracts with foreign employees provided that the work permit is granted.
  • Work permit duration. Work permits will be issued for a maximum two years and may only be extended once for a maximum period of two years.

Analysis & Comments: The two laws contain several welcome changes that should ease rules and conditions for foreign nationals, saving time and money for companies and expatriate employees. In particular, allowing foreign nationals to change visa categories in-country and removing the cooling-off period for visa-waived nationals will eliminate or reduce the need for additional travel. Additionally, the expansion of work permit exemptions and investor visas should help attract foreign direct investment and encourage economic development; however, foreigners will only be able to renew work permits once for up to two years.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2019. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

What is the change? Vietnam has extended its e-visa program to foreign nationals of 34 countries.

What does the change mean? Foreign nationals from 34 countries, including Austria, Belgium, Brazil, China, Mexico and Switzerland, are now eligible for 30-day, single-entry e-visas to Vietnam. While tourist and business travel is allowed under the e-visa program, work activities are not.

  • Implementation time frame: Feb. 1.
  • Visas/permits affected: E-visa program
  • Who is affected: Nationals of 34 countries traveling to Vietnam for up to 30 days.
  • Business impact: Employers are reminded that stays of more than 30 days are not covered under the e-visa program; therefore, employees conducting business for more than 30 days must obtain the appropriate visa or permit before arriving in Vietnam.

Background: The e-visa program has been extended to nationals of 34 countries, along with Hong Kong and Macau passport holders, under Decree 17/2019. Nationals of the following countries are now eligible for the e-visa program, effective Feb. 1.

Newly Eligible Nationals – e-Visa program
Andorra Austria Belgium
Bosnia and Herzegovina Brazil Croatia
Cyprus Estonia Fiji
Georgia Iceland Latvia
Liechtenstein Lithuania Macedonia
Malta Marshall Islands Mexico
Micronesia Moldova Monaco
Montenegro Nauru Palau
Papua New Guinea Portugal Qatar
San Marino Serbia Slovenia
Solomon Islands Switzerland Vanuatu
Western Samoa Hong Kong* Macau*

* China was previously included in the e-visa program, but not Hong Kong and Macau specifically.

Analysis & Comments: The e-visa program will ease travel procedures for nationals of 34 countries traveling to Vietnam for short-term stays. Travelers should note, however, that while the e-visa is typically appropriate for short-stay tourism and business activities, employees staying in Vietnam beyond 30 days or conducting work activities must apply for the applicable visa prior to entry.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.

IMPACT – MEDIUM

What is the change? The Ministry of Labour, Invalids and Social Affairs has partially implemented a decree that amends work permit termination procedures.

What does the change mean? Employers must again notify the Department of Labour, Invalids and Social Affairs of early terminations.

  • Implementation date: Officially Dec. 18, 2018, but not all provinces have fully implemented the regulation.
  • Visas/permits affected: Work permits.
  • Who is affected: Employers and work permit applicants.
  • Business impact: Employers must alert the authorities of early terminations. The notification requirements may vary by province.

Background: Circular No. 18/2018/TT has reinstated a previous rule that requires the sponsoring entity to notify the authorities of early work permit terminations. While the requirement has been formally reinstated, each province may enforce the requirement differently. For example, in Ho Chi Minh City the sponsoring entity is required to inform the authorities in writing of an early termination and the original work permit should be collected from the employee and kept by the host entity. Alternatively, in some provinces, the original work permit must be returned to the Department of Labour, Invalids and Social Affairs.

Analysis & Comments: Employers should ensure that the authorities are notified of all early work permit terminations as required by the new decree.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.

IMPACT – MEDIUM

What is the change? Vietnam’s Ministry of Labour issued a decree last month, introducing a number of changes.

What does the change mean? The decree introduces changes that affect work permit applications, including the removal of the work permit cancellation process and a decrease to processing times.

  • Implementation time frame: Oct. 8.
  • Visas/permits affected: Work permit applications and cancellations.
  • Who is affected: Foreign nationals applying for work permits; Employers cancelling work permits.
  • Impact on processing: Processing times have been reduced from seven working days to five working days. It remains to be seen if the change is reflected in practice.

Additional information: The new decree introduces changes and additions to Decree 11/2016/NĐ-CP. Key changes include:

  • Work permit application requirements. Only a normal copy of a passport is required. Previously, a notarized or certified copy was required for work permit applications. However, the Ho Chi Minh City labor department is still requiring a notarized copy at this time.
  • Work permit cancellation process removed. The annulment of Article 17 of Decree No. 11 effectively removed the need to complete the work permit cancellation process and the HCMC and Hanoi labor departments have stopped accepting work permit cancellations. The change, however, may be temporary and work permit cancellations may again be required and accepted.
  • Processing times decrease. From application submission to work permit issuance, processing has been reduced from seven working days to five.
  • Clarifications. The decree clarified that the person who is responsible for establishing the commercial presence of an entity in Vietnam is exempt from the work permit requirement.

Analysis & Comments: Some of the changes made by the decree alleviate work permit requirements for applicants and processes for employers. It remains to be seen, however, how the announced changes affect processing in practice as different provinces may transition in the changes at different times and in different phases.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.

IMPACT – HIGH

What is the change? Immigration authorities in a number of Vietnamese provinces, including Hanoi and Dong Nai, have begun requiring foreign nationals who are at the end of an assignment to cancel and turn in their temporary residence card before leaving Vietnam.

What does the change mean? Foreign nationals affected by the change, as well as their dependents, must apply for a separate exit visa before departing Vietnam.

  • Implementation time frame: Ongoing.
  • Visas/permits affected: Temporary residence cards.
  • Who is affected: Foreign nationals and their dependents in provinces where authorities are requiring them to hand in their temporary residence cards before leaving Vietnam.
  • Impact on processing times: The change may add to the time it takes to leave Vietnam. Foreign nationals affected by the change should submit applications for exit visas two to four weeks before their expected date of departure.

Background: Up until now, foreign nationals at the end of an assignment could leave Vietnam for their home country with their temporary residence card and then mail it back to a third party in Vietnam for delivery to the Immigration Department for cancellation. This has changed in Hanoi and Dong Nai, however, and authorities are requiring foreign nationals to turn in their temporary residence cards before leaving. While Hanoi and Dong Nai have adopted new rules, other provinces, including Ho Chi Minh, continue to operate under the old procedures, which allow foreign nationals to use their temporary residence card to leave Vietnam at the end of an assignment.

BAL Analysis: Those affected by the change should submit applications for exit visas within the time frame described above. They should note that they may need to leave their passport at the Immigration Department for seven days or longer while their exit visas are processed. BAL will continue to follow developments in Vietnam, including the possibility that more provinces adopt the new rules.

This alert has been provided by the BAL Global Practice group and our network provider in Vietnam. For additional information, please contact your BAL attorney.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? Labor authorities in Ho Chi Minh City have imposed a stricter rule requiring that work permit validity cannot exceed the expiration date on the sponsoring company’s business license.

What does the change mean? Foreign nationals applying to work in Ho Chi Minh City will be issued work permits that are valid for a maximum of two years, or the time remaining on a sponsor’s business license if it is less than two years.

  • Implementation time frame: Immediate and ongoing.
  • Visas/permits affected: All work permits, including renewals.
  • Who is affected: Employers and foreign nationals planning to work in Ho Chi Minh City.
  • Impact on processing times: Processing times themselves will not change, but foreign workers may, in some cases, be forced to renew their work permits sooner than they otherwise would have had to.

Background: The rule described above previously applied at the immigration authorities to temporary residence cards and visas, but up until now, labor authorities were more flexible when it came to work permits. They would normally issue a work permit with a two-year validity period, even when a sponsor’s business license was set to expire in that time period. That practice changed this month, however, and authorities in Ho Chi Minh City have grown increasingly strict about tying work permit validity to the business license expiration date.

BAL Analysis: The change may have a limited impact on companies with operations in Vietnam that are usually given business licenses that do not expire for several years. Others, such as representative offices and project offices, however, are normally issued business licenses that are valid for a much shorter time period and may be more affected by the change. Sponsoring companies may wish to renew their business license to ensure that foreign workers are given as much time on their work permit as possible. The business license renewal process usually takes two months, but sometimes longer.

This alert has been provided by the BAL Global Practice group and our network provider located in Vietnam. For additional information, please contact your BAL attorney.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – LOW

What is the change? Authorities in Ho Chi Minh City have said that parents and adult children will only be able to obtain a six-month extension of their dependent visas before they will be required to leave Vietnam.

What does the change mean? Affected foreign nationals who are seeking an extension beyond the initial six-month extension will be required to leave Vietnam and obtain a new visa at a Vietnamese embassy or consulate in another country.

  • Implementation time frame: Immediate and ongoing.  
  • Visas/permits affected: Temporary residence cards.
  • Who is affected: Dependent parents or adult children seeking to extend their temporary residence in Vietnam.
  • Impact on processing times: The change will add to the time it takes for affected foreign nationals to obtain a visa to remain in Vietnam after an initial six-month extension.

Background: Officials recently adopted the change without formal notice. For the time being, the new rule only applies in in Ho Chi Minh City.

BAL Analysis: Visa eligibility requirements have not changed, but the new procedures will require some adult dependents to leave Vietnam in order to extend their temporary residence beyond an initial six-month extension. The change will not affect spouses or minor children.

This alert has been provided by the BAL Global Practice group and our network provider located in Vietnam. For additional information, please contact your BAL attorney.

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – LOW

What is the change? Immigration authorities in Ho Chi Minh City have adopted a new process for obtaining multiple-entry business visas (MEBVs). In some cases, the new procedure may extend the time it takes to get MEBVs by about two days.

What does the change mean? Effective immediately, MEBV applicants in Ho Chi Minh City must complete an initial copy of a Form NA-2, to be submitted along with required supporting documentation. Authorities then provide a printed-out copy of the form that is returned to the sponsoring company for signing and stamping.

  • Implementation time frame: Immediate and ongoing.
  • Visas/permits affected: MEBVs.
  • Who is affected: Sponsoring companies and foreign nationals applying for MEBVs.
  • Impact on processing times: The change may delay MEBV processing in Ho Chi Minh City by about two days. BAL and its network partner in Vietnam recommend that applicants submit their information no less than two weeks before their proposed entry date.

BAL Analysis: Thus far, Ho Chi Minh City is the only locale to institute the two-step process, which requires applicants to submit supporting documentation and a completed form that is then returned for signing and stamping. While substantive requirements remain the same, the new process may add about two days to processing times. Companies and business visitors should take note and adjust their schedules accordingly.

This alert has been provided by the BAL Global Practice group and our network provider located in Vietnam. For additional information, please contact your BAL attorney.

Copyright © 2017 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.