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During the period awaiting guidance from competent authorities, the issuance, reissuance, renewal, and revocation of employment service operating licenses, as well as the withdrawal of deposits by employment service providers, will continue to be carried out in accordance with Decree No. 352/2025/ND-CP.
Mr. Truong Le Van Khoa said current regulations on the conditions for conducting employment services are inconsistent across legal documents.
Under the Investment Law 2025, employment services have been removed from the list of industries with conditional investment, effective from July 1, 2026.
However, Mr. Khoa noted that the Employment Law 2025 and Decree 352/2025/ND-CP (effective from January 1, 2026) still require enterprises to obtain an operating license and deposit 300 million VND.
According to Mr. Khoa, this overlap creates significant confusion for enterprises seeking to enter the market between now and July 2026.
Mr. Khoa asked whether state agencies are currently drafting amendments to the Employment Law 2025 and Decree 352/2025/ND-CP to abolish the licensing and deposit procedures, in order to align with the Investment Law 2025 before July 1, 2026.
On the issue, the Ministry of Home Affairs stated:
Pursuant to Clause 2, Article 51 and Appendix IV of Investment Law No. 143/2025/QH15 (effective from July 1, 2026), the industry of employment service business is not included in the list of sectors with conditional investment.
Under Clause 15, Article 52 of Investment Law No. 143/2025/QH15, enterprises operating employment services may continue to use the employment service operating license until its expiration date.
Authorities are currently reviewing and proposing transitional guidance for sectors or investment activities no longer included in the conditional investment sectors list in Appendix IV of Investment Law No. 143/2025/QH15.
Therefore, during the waiting period for the guidance, the issuance, reissuance, extension, revocation of employment service licenses, and withdrawal of deposits for employment service providers will continue to be carried out in accordance with Decree No. 352/2025/ND-CP dated December 30, 2025, detailing a number of provisions of the Employment Law on employment services.
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