Quick answer: Vietnam’s Decree No. 320/2026/ND-CP, dated 13 August 2026, introduces important changes to electronic identification and VNeID. From 28 September 2026, a foreign national who has lawfully entered Vietnam or is lawfully residing in Vietnam may be issued an electronic identification account when needed. The amended procedure for foreigners requires a passport or valid international travel document, but it does not list a Temporary Residence Card (TRC) as a mandatory document.
Foreign legal representative without a TRC?
VINADAY GOREISE can review the company, passport, visa/entry status and current Business VNeID situation before you proceed with registration or immigration-related procedures.
What is Decree 320/2026/ND-CP?
Decree No. 320/2026/ND-CP amends and supplements a number of provisions of Decree No. 69/2024/ND-CP on electronic identification and authentication. The Decree was issued on 13 August 2026 and takes effect on 28 September 2026.
For foreign-owned companies, one of the most significant changes concerns the eligibility and procedure for issuing electronic identification accounts to foreign nationals. This is particularly relevant when the company’s legal representative is a foreigner and needs an individual VNeID account before managing the organization’s electronic identification account.
Can a foreign legal representative get VNeID without a TRC?
Under the wording of Decree 320/2026, a TRC is not listed as a mandatory document for the new foreigner VNeID procedure.
The amended Article 7 states that a foreigner who has lawfully entered Vietnam or is lawfully residing in Vietnam may be issued an electronic identification account when needed.
This wording is important because it distinguishes between:
- a foreigner who has legally entered Vietnam, and
- a foreigner who is legally residing in Vietnam.
Therefore, the regulation is not written only for foreigners who already hold a temporary residence card or permanent residence card.
The amended Article 11 also states that the foreigner goes to the competent immigration authority, presents a passport or another valid international travel document, completes the required application information, and provides biometric data. A TRC is not specifically included in that list.
What documents are required for a foreigner under the new rule?
Based on the amended Article 11, the foreign applicant should prepare the following:
- Valid passport or another valid international travel document
- Information required on Form TK01
- A mobile phone number registered in the applicant’s own name
- Email address, if available
- Lawful Vietnam entry or residence information that can be verified in the immigration database
- Biometric enrollment, including facial image and fingerprints
The application is handled through the immigration authority. The officer receives the information, captures biometrics and verifies the applicant against the National Immigration Database.
How long does foreigner VNeID registration take?
Decree 320/2026 provides two main processing timelines for foreign applicants:
- Up to 2 working days where facial image and fingerprint information is already available in the National Immigration Database.
- Up to 5 working days where that biometric information is not yet available in the database.
Actual preparation time may be longer if the passport, immigration record, phone registration or other data does not match the relevant government databases.
What does Decree 320 change for Business VNeID?
The Decree also amends the classification of electronic identification accounts. It states that an agency or organization established or registered to operate in Vietnam may be issued an electronic identification account, without classification by level, when needed.
For a company, this means the organization itself remains an electronic identity subject. The company account is separate from the foreign legal representative’s personal account.
In practical terms, foreign-owned companies should think of the process as two connected identities:
- Individual VNeID: the foreign legal representative or authorized person needs an eligible individual electronic identification account.
- Business VNeID: the company then obtains and uses its organization electronic identification account for relevant digital public services and transactions.
For a broader explanation of company registration issues, see our Business VNeID Registration Guide for Foreign-Owned Companies.
Does this mean a foreign director never needs a TRC?
No. Decree 320/2026 should not be interpreted as eliminating the TRC from Vietnam’s immigration system.
The important point is narrower: the amended VNeID eligibility and registration provisions do not list a TRC as a prerequisite for a foreigner who has lawfully entered Vietnam.
A foreign director may still need a TRC for other immigration, employment, investment, residence, banking or administrative purposes depending on the person’s status and the procedure being performed.
If your company is preparing immigration documents at the same time, review our Vietnam Immigration Guide and Vietnam Visa Extension Guide.
Can a foreigner on a visa or eVisa apply after 28 September 2026?
The new regulation uses the phrase “lawfully entered Vietnam or lawfully residing in Vietnam.” On its face, this is broader than requiring a TRC.
Accordingly, a foreign legal representative who is in Vietnam with a valid passport and lawful entry status may fall within the new eligibility wording even if a TRC has not yet been issued.
However, eligibility still depends on the authorities being able to verify the person’s information in the immigration database. Companies should therefore check the foreign representative’s passport number, name, nationality, date of birth, visa or eVisa information and most recent entry record before submitting the request.
For visitors currently using an eVisa, see the Vietnam eVisa 2026 Complete Guide.
Where does a foreigner apply for VNeID?
Under the amended Article 11, the foreign national applies through the competent immigration authority and presents the passport or valid international travel document.
The process includes:
- Submitting the required personal information.
- Providing the applicant’s own registered mobile number and email where applicable.
- Facial image capture.
- Fingerprint capture.
- Verification against the National Immigration Database.
- Electronic identification account issuance by the electronic identification and authentication system authority.
- Notification of the result through VNeID, the registered mobile number or email.
What other VNeID changes affect businesses?
Decree 320/2026 also strengthens the use of information and documents integrated into the national identification application. When an administrative agency, public service provider or other relevant body handles procedures and the required document has already been integrated into VNeID, the regulation states that the individual or organization should not be required to submit or present the original or a copy of that integrated document.
The Appendix to the Decree includes a list of documents that may be integrated for organizations. This includes important company records such as the Enterprise Registration Certificate, business location registration documents, branch/representative office registration documents and tax registration certificates.
This is part of the broader move toward using verified digital identity and synchronized government data instead of repeatedly requesting the same paper documents.
Example: foreign legal representative without a TRC
Consider a newly established foreign-owned company in Ho Chi Minh City:
- The legal representative is a foreign national.
- The person has entered Vietnam legally.
- The passport is valid.
- The person currently has a valid visa or eVisa.
- The company is registered in Vietnam.
- The TRC has not yet been issued.
From 28 September 2026, Decree 320/2026 provides a clearer legal basis for the foreign representative to request an electronic identification account based on lawful entry, without the amended procedure expressly requiring a TRC.
Once the individual identification issue is resolved, the company can proceed with the relevant organization VNeID process, subject to the applicable implementation procedure and data verification.
Need to prepare Business VNeID before an immigration deadline?
We can review whether the foreign legal representative’s passport, current entry status, company registration details and VNeID records are ready for the next step.
Frequently Asked Questions
When does Decree 320/2026 take effect?
The Decree takes effect on 28 September 2026.
Is a TRC mandatory for a foreigner to apply for VNeID under Decree 320?
The amended Article 11 does not list a TRC as a mandatory document. It requires the foreign applicant to present a passport or valid international travel document and complete identity and biometric verification.
Can a foreigner who only has a valid visa or eVisa qualify?
The amended eligibility rule covers foreigners who have lawfully entered Vietnam or are lawfully residing in Vietnam. Therefore, lawful entry is expressly recognized. Verification of the person’s immigration data is still required.
Can a 100% foreign-owned company obtain Business VNeID?
Yes. An organization established or registered to operate in Vietnam may be issued an electronic identification account when needed, subject to the applicable registration and verification procedure.
Does Business VNeID replace the Enterprise Registration Certificate?
No. VNeID does not abolish the underlying company registration document. However, the Decree provides for organization documents, including the Enterprise Registration Certificate, to be integrated and used electronically within the national identification system.
Need help with Business VNeID in Vietnam?
If your company has a foreign legal representative, no Vietnamese administrative staff, an urgent immigration deadline, or difficulty registering Business VNeID, VINADAY GOREISE can review the case before submission.
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Legal and administrative procedures may be clarified by implementing guidance or agency practice. This article summarizes Decree 320/2026/ND-CP and should not be treated as a substitute for case-specific legal advice.