Over 630,000 MLM participants must update under Decree No. 137

The Government has issued Decree No. 137 on the management of multi-level marketing (MLM) activities, clarifying conditions for individuals participating in MLM. The Decree will take effect from July 1, 2026.

Key eligibility requirements

Under Article 28, MLM participants must be individuals with full civil capacity as prescribed by law and resident in Vietnam.

Cases where MLM participation contracts cannot be signed

The Decree also specifies circumstances in which an MLM participation contract is not allowed to be signed. This includes individuals who are serving a prison sentence or have a prior conviction related to offenses such as:

• Producing or trading counterfeit goods
• Producing or trading banned goods
• Fraudulent advertising
• Fraud
• Misappropriation of assets
• Possession of assets in violation of MLM regulations

Participation is also prohibited for civil servants as defined by law, as well as officers, professional soldiers, military workers, and public security personnel.

In addition, foreigners without a valid work permit in Vietnam are not allowed to participate in MLM, except for those exempt from work permits under the law.

Additional restrictions for prior violations and revoked MLM registrations

The Decree tightens restrictions for individuals who have previously violated MLM-related regulations or consumer rights. Those who have not yet served the applicable sanction period are considered still prohibited from participating.

It also bars individuals who previously held managerial or ownership roles in MLM businesses whose registration certificates have been revoked. Such roles include general partners, private enterprise owners, company members or shareholders, the legal representative, or the enterprise manager.

Purpose and oversight rationale

The stated objective of adding and clarifying these conditions and prohibitions is to strengthen oversight, reduce risk, and protect consumer rights amid ongoing changes in MLM activities.

MoIT data on the MLM sector

The Ministry of Industry and Trade (MoIT) said that as of June last year, the total number of MLM participants in the first half of 2025 reached 634,567, down 13.43% year-on-year. MoIT noted that participants are mainly concentrated in five large enterprises, accounting for about 91% of the sector.

On revenue, MLM revenue in the first six months of 2025 exceeded 7,000 billion VND, down more than 9% year-on-year. The top five enterprises accounted for nearly 93% of total sector revenue. Herbalife Vietnam Co., Ltd. recorded the largest revenue, over 4,000 billion VND, roughly 53% of sector revenue.