Recruitment Company in Vietnam: 2026 Setup Guide
How to Set Up a Recruitment Company in Vietnam in 2026
Vietnam significantly simplified the requirements for establishing and operating a recruitment company in 2026.
From July 1, 2026, ordinary employment placement and recruitment services are no longer included in Vietnam’s list of conditional business lines. The procedures for obtaining, renewing and reissuing an employment service licence have also been suspended under the new regulatory framework.
This means that a recruitment company in Vietnam generally no longer needs to obtain the former employment service licence or maintain the VND 300 million deposit previously required for employment service businesses.
However, the reform does not remove every legal obligation. A recruitment company must still be properly established, register the correct business activities, complete the required operational notifications, protect candidate data and submit periodic reports.
Foreign investors must also distinguish ordinary recruitment from labour subleasing, overseas employment services and other regulated staffing activities.
Quick Answer
A company providing ordinary recruitment, headhunting or employment placement services in Vietnam generally does not need an employment service licence under the rules effective from July 1, 2026.
The company must still:
Establish and register a legal entity in Vietnam;
Complete foreign investment procedures where applicable;
Register the correct recruitment business line;
Notify the provincial Department of Home Affairs before starting operations;
Publicly disclose its business information;
Comply with employment service reporting requirements;
Protect candidates’ personal and employment data; and
Confirm that its activities do not constitute labour subleasing or overseas employment services.
The licence exemption should not be interpreted as an exemption from company registration or post-establishment compliance.
Key Takeaways
Ordinary recruitment and employment placement services were removed from the list of conditional business lines from July 1, 2026.
The previous employment service licence procedures are no longer implemented under the current temporary regulatory framework.
The former VND 300 million deposit is no longer required for ordinary recruitment services.
Existing employment service companies may withdraw their deposits without obtaining prior written approval from the competent authority.
Recruitment companies should generally register business code 7810 or 78100.
Foreign investors must still satisfy market-access and investment registration requirements.
Recruitment is different from labour subleasing, which remains subject to a VND 2 billion deposit and separate operational requirements.
Recruitment companies must notify the Department of Home Affairs before commencing operations.
Candidate information must be processed and protected in accordance with Vietnam’s personal data regulations.
What Changed for Recruitment Companies in 2026?
Before July 1, 2026, employment service businesses were treated as conditional businesses. A company normally needed an employment service licence and had to maintain a VND 300 million deposit.
The regulatory position changed through two important resolutions:
Resolution No. 66.17/2026/NQ-CP reduced the list of conditional business lines and introduced a stronger post-inspection approach.
Resolution No. 66.18/2026/NQ-CP discontinued the procedures for granting, reissuing, extending and revoking employment service licences.
The reforms took effect on July 1, 2026.
Recruitment company requirements before and after July 1, 2026
Requirement | Before July 1, 2026 | From July 1, 2026 |
Employment service licence | Required | Licensing procedures are not implemented |
VND 300 million deposit | Required | No longer required for ordinary recruitment |
Company registration | Required | Still required |
Business activity registration | Required | Still required |
Notification before starting operations | Required under the applicable regime | Required |
Periodic reporting | Required | Still required |
Candidate data protection | Required | Still required |
Government inspection | Primarily licence-based control | Greater emphasis on post-inspection |
A company that already holds a valid employment service licence may continue using it until it expires. Existing recruitment companies that maintained the former deposit may withdraw it from July 1, 2026 without obtaining written approval from the competent authority.
However, the new resolutions are scheduled to remain in force only until February 28, 2027. Businesses should therefore check whether replacement legislation has been issued before relying on the licence exemption.
Can Foreign Investors Establish a Recruitment Company in Vietnam?
Foreign investors may establish a recruitment company in Vietnam, but the removal of the employment service licence does not automatically remove foreign market-access requirements.
Before proceeding, a foreign investor should check:
The investor’s nationality;
The applicable international investment treaty;
The exact recruitment services to be provided;
Whether the company will only introduce candidates or will employ and supply workers;
Whether candidates will be recruited for jobs in Vietnam or overseas;
Whether the business will operate an online recruitment platform; and
Whether candidate data will be transferred outside Vietnam.
Under the Law on Investment No. 143/2025/QH15, foreign investors have greater flexibility regarding the order of company establishment and investment registration.
Depending on the investment structure, a foreign investor may:
Obtain an Investment Registration Certificate before establishing the Vietnamese company; or
Establish the company first and obtain the Investment Registration Certificate for its investment project within the applicable period.
The appropriate route should be determined before filing because it affects the documents, capital plan and permitted activities of the company.
Foreign ownership should be reviewed case by case. Investors should not assume that removing a domestic business condition automatically guarantees unrestricted foreign ownership.
Which Business Code Should a Recruitment Company Register?
Vietnam introduced an updated national economic sector classification under Decision No. 36/2025/QD-TTg, effective from November 15, 2025.
For an ordinary recruitment or headhunting company, the main business code is generally:
Business code 7810 – Activities of employment placement agencies
The corresponding detailed code is:
78100 – Activities of employment placement agencies
This business line covers activities such as:
Searching for and selecting candidates;
Introducing candidates to employers;
Executive search and headhunting;
Talent recruitment;
Online recruitment agency activities;
Career placement services; and
Recruitment of actors or models.
The defining feature is that candidates introduced by the agency do not become employees of the recruitment agency.
Recruitment, Labour Subleasing and Overseas Employment Are Different
One of the most common mistakes is registering
a recruitment company when the actual business model is labour subleasing or overseas workforce supply.
Business model | Typical activity | Business code | Main distinction |
Recruitment and headhunting | Finding and introducing candidates to employers | 7810/78100 | The candidate becomes an employee of the client |
Temporary labour supply | Employing workers and assigning them temporarily to a client | 7821/78210 | The agency remains the employer |
Other domestic human resources supply | Long-term domestic workforce supply or management | 78221 | May involve ongoing workforce administration |
Overseas human resources supply | Supplying or managing workers working overseas | 78222 | Separate overseas employment regulations may apply |
Labour subleasing
Labour subleasing is not the same as recruitment.
In a labour subleasing arrangement, the service provider signs employment contracts with workers and then assigns those workers to work under the supervision of another company.
Under the 2026 framework, labour subleasing follows a separate notification and compliance regime and continues to require a VND 2 billion deposit. A company providing only recruitment services should not sign contracts or structure its operations in a manner that unintentionally creates a labour subleasing relationship.
Sending Vietnamese workers abroad
Recruiting Vietnamese workers for employment overseas remains a separately regulated activity. It should not be treated as ordinary recruitment under business code 7810.
Companies offering overseas employment services must review the specific licensing, capital, deposit and operational requirements applicable to sending Vietnamese workers abroad.
Step-by-Step Process to Set Up a Recruitment Company in Vietnam
Step 1: Define the Exact Business Model
The investor should first confirm whether the company will provide:
Candidate search and screening;
Executive search;
Headhunting;
Online recruitment;
Career placement;
Recruitment process outsourcing;
Payroll or human resources administration;
Temporary staffing;
Labour subleasing; or
Overseas employment services.
This step determines the correct business codes and whether additional conditions apply.
For example, executive search normally falls under ordinary recruitment, while hiring workers and placing them under a client’s supervision may constitute labour subleasing.
Step 2: Review Foreign Market-Access Conditions
Foreign investors should conduct a market-access review based on:
Investor nationality;
Proposed ownership ratio;
Relevant international treaties;
Scope of services;
Proposed contracts;
Source and destination of candidate data; and
Whether the company will operate a digital recruitment platform.
This review should be completed before preparing the company documents because the stated business scope must remain consistent across the investment and enterprise registration filings.
Step 3: Select the Company Structure
A recruitment company in Vietnam is commonly established as:
A single-member limited liability company;
A multiple-member limited liability company; or
A joint-stock company.
A limited liability company is often the most practical structure for a new foreign-owned recruitment business because it provides limited liability and a relatively straightforward management structure.
The investor should also determine:
Company name;
Registered office;
Charter capital;
Legal representative;
Ownership structure;
Investment term;
Expected operating costs; and
Proposed recruitment services.
Step 4: Prepare the Investment and Company Documents
A typical foreign investment dossier may include:
Passport or incorporation documents of the investor;
Documents proving the investor’s legal status;
Audited financial statements, bank confirmations or other evidence of financial capacity;
Proposed investment project information;
Office lease documents;
Company charter;
List of members or shareholders;
Details of the legal representative; and
Explanation of the proposed business activities.
Documents issued outside Vietnam may need to be consularly legalised, translated into Vietnamese and certified before submission.
The final document list depends on whether the investor uses the pre-IRC or post-IRC establishment route.
Step 5: Obtain the IRC and ERC
Foreign-invested companies will normally need to complete the relevant investment registration and enterprise registration procedures.
The two principal documents are:
Investment Registration Certificate: Records information about the foreign investment project.
Enterprise Registration Certificate: Formally establishes the Vietnamese legal entity and provides its enterprise registration number.
Under the current investment framework, investors may have more flexibility regarding the order of these procedures. However, the company should not commence recruitment activities until its investment scope, enterprise registration and operational notifications are properly completed.
Step 6: Complete Post-Establishment Procedures
After incorporation, the recruitment company should complete the standard post-establishment tasks, including:
Obtaining and activating the company’s electronic identification account;
Opening the required bank accounts;
Registering for electronic tax and invoice systems;
Making the required capital contribution;
Registering the company’s labour and payroll arrangements;
Installing an accounting system;
Preparing recruitment service agreements; and
Establishing candidate privacy and data retention policies.
These procedures remain necessary even though the specialist employment service licence has been removed.
Step 7: Notify the Department of Home Affairs
A recruitment company must notify the provincial Department of Home Affairs through the National Employment Exchange:
At least five working days before commencing employment service activities; and
At least five working days before terminating those activities.
The notification should be consistent with the company’s registered office, business scope and legal representative information.
Step 8: Publish the Required Business Information
Within 20 working days from the date the company begins providing employment services, it must publicly disclose:
Business location;
Scope of services;
Name of the legal representative;
Website, if available;
Email address; and
Contact telephone number.
The disclosure must be made publicly through an appropriate mass-media channel.
Does a Recruitment Company Need Minimum Capital?
Under the current regulations, there is no separate statutory minimum charter capital specifically imposed on an ordinary recruitment company operating under business code 7810.
The previous VND 300 million employment service deposit is also no longer required under the regulations effective from July 1, 2026.
However, foreign investors should not register an unrealistically low capital amount. The registered capital should be sufficient to cover:
Office rent;
Employee salaries;
Recruitment software;
Marketing expenses;
Data security systems;
Professional fees;
Tax and accounting costs; and
Working capital during the initial operating period.
The investment registration authority may assess whether the proposed capital is credible in relation to the scale and duration of the project.
The removal of the recruitment deposit does not apply to every workforce-related business. Labour subleasing businesses continue to be subject to a VND 2 billion deposit under the current regime.
Ongoing Compliance Requirements
Removing the employment service licence shifts regulatory attention from pre-approval to post-inspection. Recruitment companies must therefore maintain appropriate compliance systems after starting operations.
Publicly display service information
The company should publicly display at its head office and branches:
Working hours;
Recruitment service fees;
Company name;
Head-office and branch addresses;
Website;
Email address; and
Contact telephone number.
Update recruitment results
Within 20 working days after an employer provides information about a recruitment requirement, the recruitment company must update the recruitment result on the National Employment Exchange.
The company must also monitor the employment status of an introduced candidate for at least one month. If the employment contract is shorter than one month, monitoring should continue for the duration of that contract.
Maintain employment service data
The company must establish and update records relating to:
Job seekers;
Employers;
Vacancies;
Candidate introductions;
Recruitment results; and
Employment status following placement.
The company may also be required to connect and share employment service information with the relevant national employment system.
Protect candidate personal data
Recruitment companies process sensitive information, including:
Identification information;
Contact details;
Employment history;
Education records;
Salary information;
Interview assessments;
References; and
In some cases, health or background information.
The company should establish a lawful process for collecting, storing, sharing and deleting candidate data.
If candidate information is transferred to a foreign parent company, overseas client or cloud-based applicant tracking system, the company should review Vietnam’s cross-border data transfer requirements before the transfer takes place.
Prevent recruitment fraud
Recruitment companies must implement measures to prevent, detect and report fraudulent recruitment activities.
This is particularly important for online recruitment platforms, which may be exposed to:
False job advertisements;
Impersonation of employers;
Illegal recruitment fees;
Identity theft;
Collection of candidate documents for fraudulent purposes; and
Misleading overseas employment offers.
Submit periodic reports
Recruitment companies must submit reports on their employment service activities to the provincial Department of Home Affairs through the National Employment Exchange:
Six-month report: before June 20; and
Annual report: before December 20.
The reporting periods generally close on June 14 and December 14 respectively.
Branches are also subject to reporting requirements in the province where they operate.
Estimated Setup Timeline
The time required to establish a recruitment company depends on the ownership structure and the completeness of the application.
Stage | Typical planning estimate |
Business model and market-access review | 3–7 working days |
Document preparation and legalisation | 1–3 weeks |
Investment and enterprise registration | Case-specific |
Tax, banking and post-establishment procedures | 1–2 weeks |
Employment service notification | At least five working days before operations |
A domestic recruitment company may be established more quickly than a foreign-owned company.
For foreign investors, an overall planning period of approximately four to eight weeks may be reasonable for a straightforward project. This is not a statutory guarantee and does not include delays caused by legalisation, amendments, market-access review or additional approval requirements.
Common Mistakes to Avoid
Assuming that no licence means no registration
The employment service licence has been removed under the current framework, but the company must still complete enterprise, investment, tax and operational notification procedures.
Registering the wrong business code
Ordinary recruitment should generally be registered under code 7810 or 78100. Temporary labour supply and other workforce services use different codes and may create different obligations.
Confusing recruitment with labour subleasing
A recruitment company introduces candidates who will be employed by its clients. A labour subleasing company remains the employer and assigns its employees to work for another business.
Contracts, invoices and operational practices must reflect the correct model.
Using outdated business codes
Vietnam’s national economic sector classification changed under Decision No. 36/2025/QD-TTg. Companies should check whether older codes such as 7820 or 7830 need to be replaced by the updated codes 7821, 78221 or 78222.
Ignoring the five-day notification requirement
A recruitment company should not wait until after commencing operations to notify the Department of Home Affairs. The notification must be submitted at least five working days before operations begin.
Transferring candidate data without a compliance review
Sending CVs to overseas clients, foreign affiliates or international recruitment platforms may involve cross-border personal data transfers. Candidate consent alone may not satisfy every applicable obligation.
Treating the 2026 reform as permanent
The current resolutions are scheduled to apply until February 28, 2027. Recruitment companies should monitor replacement legislation and update their compliance procedures when new rules are issued.
How VINEX Can Help
The 2026 reform makes it easier to establish a recruitment company in Vietnam, but investors must still select the correct business model and complete the required registration and notification procedures.
VINEX can assist foreign investors with:
Market-access and business activity review;
Company structure and foreign ownership planning;
IRC and ERC applications;
Registration of recruitment business activities;
Review of recruitment and service agreements;
Post-establishment tax and accounting procedures;
Employment service notifications;
Candidate data compliance; and
Ongoing corporate, labour and regulatory reporting.
Before establishing a recruitment company in Vietnam, investors should confirm whether the proposed activity is ordinary recruitment, labour subleasing, human resources management or overseas employment services. This distinction determines the company’s registration, capital and continuing compliance obligations.
Contact VINEX for a preliminary review of your recruitment business model and a customised company establishment plan.
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