Is VNeID Registration Mandatory for FDI Companies with Foreign Legal Representatives?

By KMC Consulting Company Limited

On June 25, 2024, the Vietnamese Government issued Decree No. 69/2024/NĐ-CP, providing regulations on electronic identification and authentication. This decree establishes the legal framework for the registration and use of electronic identification accounts (VNeID) for both domestic and foreign individuals and organizations residing or operating in Vietnam.

A key concern arising from this decree, especially for foreign-invested enterprises (FDI), is:
“Is VNeID registration mandatory if the company’s legal representative is a foreign national?”

In this article, KMC analyzes the legal requirements and provides guidance to help your business comply effectively.

KMC Companies with a foreign legal representative

Is VNeID registration mandatory for FDI companies with foreign legal representatives?

The answer is: Yes.

According to Article 2 of Decree 69/2024/NĐ-CP, the scope of application includes:

“Vietnamese organizations and individuals, and foreign organizations and individuals residing or operating within Vietnamese territory who participate in or are related to electronic identification, authentication, or e-ID activities.”

Therefore, FDI companies with foreign legal representatives fall within the scope and are required to register and use VNeID in accordance with the law.

What is VNeID for Foreigners?

  • Electronic identification (VNeID) for foreigners refers to the process of registering, verifying, creating, and linking an electronic identity to a foreign individual.

1. Information Included in the VNeID Profile of Foreigners: 

  • Personal identification number: A unique natural number assigned by the VNeID system;
  • Full name (last name, middle name, and first name);
  • Date of birth;
  • Gender;
  • Nationality;
  • Passport or internationally valid travel document number, symbol, date of issue, and place of issue;
  • Facial image;
  • Fingerprints.

(Article 5.1 of Decree No. 69/2024/NĐ-CP)

2. Eligible Individuals for VNeID Account Issuance:

(Article 7.2 of Decree No. 69/2024/NĐ-CP)

  • Foreigners aged 6 or older holding permanent or temporary residence cards in Vietnam: Eligible for a Level 1 VNeID account and, upon request, a Level 2 account.
  • Foreigners under 6 years of age holding permanent or temporary residence cards in Vietnam: Eligible for a Level 1 VNeID account upon request.

3. Use Value of VNeID Accounts for Foreigners:

(Article 9 of Decree No. 69/2024/NĐ-CP)

  • Level 1 VNeID Account:

+ Access and use basic electronic identity information, functions, utilities, and features provided by the VNeID system;

+ Perform electronic authentication through legally connected and shared information systems.

  • Level 2 VNeID Account:

+ Access and use full electronic identity information and additional data integrated from national and specialized databases, including all system utilities and applications;

+ Perform electronic authentication through legally connected and shared information systems.

Conditions for registering VNeID for FDI companies

As per Article 12 of the Decree, the following conditions must be met:

  • The legal representative must hold a Level 2 electronic ID account to log in to the VNeID app and submit the registration request on behalf of the organization.
  • If the company has multiple legal representatives, the registration must be agreed upon by all of them.

Guide to Registering a Level 2 VNeID Account for Foreigners Acting as Legal Representatives

According to Article 11 of Decree No. 69/2024/NĐ-CP, the procedure to register a Level 2 VNeID account for foreigners is as follows:

Step 1: SUBMIT REQUIRED INFORMATION

Where to apply: In person at the Immigration Department under the Ministry of Public Security or at a provincial police department.

Applicant: The foreign individual.

Note: For foreigners aged 6 to under 14, the guardian or legal representative must accompany the child and use the guardian’s registered mobile number for account registration.

Documents to present: Passport or internationally valid travel document.

Application includes:

  • Application Form TK01 (per Decree No. 69/2024/NĐ-CP), including:
    • Personal information;
    • Mobile phone number registered under the applicant’s (or guardian’s) name;
    • Email address (if available);
    • Optional integration requests into the VNeID system (e.g., residence and immigration details, work permit, dependents, etc.);
  • Facial image and fingerprints (collected directly by the receiving officer).

Step 2: INFORMATION VERIFICATION AND ACCOUNT ISSUANCE REQUEST

Handled by: The receiving officer.

Processing time:

  • Within 03 working days if facial image and fingerprints already exist in the national immigration database;
  • Within 07 working days if such biometric data has not yet been recorded.

Step 3: RECEIVE REGISTRATION RESULTS

Issuing authority: Department of Administrative Management on Social Order – Ministry of Public Security.

Notification channels:

  • The VNeID mobile application;
  • Registered email address;
  • Registered mobile phone number.

Fees and charges: None.

(Articles 11 and 13 of Decree No. 69/2024/NĐ-CP)

Step-by-step guide: VNeID registration for FDI companies

Foreign legal representatives (or authorized persons) can follow these steps:

Step 1: Log into the VNeID app using the Level 2 account and choose “Organization ID.”

Step 2: On the switch account screen, select “Register Organization ID.”

Step 3: Enter the passcode to authenticate.

Step 4: On the Organization ID screen, select the declarant:

  • The legal representative (if they already hold a Level 2 account);
  • Or the authorized person (if the legal rep has delegated authority).

Step 5:Enter required organization information.

Step 6:Review and confirm the details, then submit the request.

Step 7:Enter the passcode again to complete authentication.

Step 8:Registration results will be sent via the “Notification” section in the app.

>> View more: Guide to the Latest Business e-Identification via VNeID
>> View more: Is VNeID Registration Mandatory for Enterprises Before July 1, 2025?
>> View more: How to Register an Organizational Vietnam Electronic Identification (VNeID) Account?

What businesses should keep in mind

According to the decree, starting from July 1, 2025, VNeID will become a mandatory element in electronic administrative transactions. Late registration may disrupt access to essential administrative services.

For more detailed information about this or related Business Advisory, please don’t hesitate to contact us.
Website: https://kmc.vn/
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Email: info@kmc.vn