I. . Highlights
1. Relaxed experience requirements for experts obtaining work permits
Under Clause 3, Article 3 of Decree 219/2025/ND-CP:
- Experts must have a university degree plus at least 2 years of relevant experience; or
- A university degree and at least 1 year of relevant experience if working in specialized fields such as science, technology, innovation, national digital transformation, or sectors prioritized for socio-economic development.
By contrast, Clause 3, Article 3 of Decree 152/2020/ND-CP had uniformly required a minimum of 3 years of relevant experience for all experts.
2. Provincial authorities authorized to issue work permits from August 7, 2025
Clause 1, Article 4 stipulates:
- Provincial People’s Committees (PPCs) are empowered to issue, extend, or revoke work permits, as well as issue certificates confirming exemption from work permit requirements.
- PPCs may delegate these powers to specialized agencies to expedite processing.
3. Online issuance of judicial record certificates alongside work permits
Clause 3, Article 6 of Decree 219/2025/ND-CP introduces an integrated online process:
- The National Public Service Portal now supports submission of both the work permit and judicial record certificate applications simultaneously.
- Successful applications generate both documents in electronic format, issued concurrently.
4. Expanded exemptions from work permit requirements
Whereas Decree 152/2020/ND-CP (amended by Decree 70/2023) outlined 14 exemption categories, Decree 219/2025/ND-CP (Article 7) increases this to 15 categories. Notably, it adds foreign workers in finance, science, technology, innovation, national digital transformation, and other sectors prioritized for socio-economic development.
5. Foreign workers working less than 90 days/year are exempt from work permits
According to Clause 13, Article 7 of Decree 219/2025/ND-CP:
- Foreign employees working in Vietnam for a total duration of under 90 days per calendar year are exempt from work permit requirements.
However, Clause 4, Article 9 mandates that:
- Employers must notify the competent authority in writing at least 3 working days before the foreign worker begins their assignment.
6. New notification requirements for exempt cases
Decree 219/2025/ND-CP, Clause 4, Article 9 specifies that:
- In situations where work permits are not required, employers must still notify authorities at least 3 working days before commencement.
- The notification must include: full name, date of birth, nationality, passport number, employer’s name, work location, and duration of employment.
7. New bases for determining the validity period of work permits and exemption certificates
Article 21 states:
- The validity of both the work permit and the exemption certificate shall not exceed 2 years.
- Validity is determined based on supporting documents such as labor contracts, business trip authorizations, international agreements, or enterprise operating licenses.
Decree 152/2020/ND-CP had the same maximum validity period but lacked explicit definitions for the supporting documents.
8. Work permit issued in one province allows work across multiple localities
Clause 5, Article 22 of Decree 219/2025/ND-CP allows:
- Foreign workers holding a valid work permit can work in multiple provinces or centrally-governed cities.
- Employers must notify the local competent authority at least 3 working days before each relocation.
Decree 152/2020/ND-CP had no provisions for such inter-provincial flexibility.
9. Work permits may now be extended only once, up to 2 years
Article 29 caps extensions as follows:
- Work permits can be extended only once, for a maximum of 2 years.
Previously, Decree 152/2020/ND-CP imposed a 2-year limit but did not restrict the number of renewal cycles.
10. Clarified grounds for revoking work permits and exemption certificates
Under Articles 30 and 32 of Decree 219/2025/ND-CP, revocation may occur if:
- Documents have expired;
- There are violations in issuance, renewal, or misuse of permits;
- The foreign worker is prosecuted or faces criminal charges;
- The employing enterprise ceases operations;
- A notice from the sending entity terminates the assignment.
Decree 152/2020/ND-CP mentioned revocation grounds only inconsistently and did not address exemptions explicitly.
II. Comments
Decree 219/2025/ND-CP reflects substantial improvements in managing foreign labor in Vietnam. By lowering experience thresholds for experts and delegating permit authority to provincial committees, it better facilitates talent attraction—especially in science, technology, and digital transformation—while enhancing administrative efficiency. The integration of judicial record certification with work permit issuance, clear exemption categories, standardized notification requirements, and defined permit durations all contribute to greater transparency and consistency. Granting inter-provincial mobility and limiting extensions further strengthen oversight. That said, the limitation of a single 2-year renewal may impose challenges for retaining long-term specialists; flexibility may be needed—especially in sectors facing acute skill shortages. Overall, Decree 219/2025 balances streamlined procedures with strengthened governance over foreign labor in Vietnam.
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