HM&P lawyer shares insights on electronic identification regulations for businesses

Amid Vietnam’s accelerated push for digital transformation in public administration, the Government issued Decree No. 69/2024/ND-CP on May 15, 2024, regulating electronic identification and authentication. Accordingly, from July 1, 2025, all administrative procedures must be carried out via electronic identification (eID) accounts issued by the Ministry of Public Security. This new regulation presents an urgent requirement for businesses to register and utilize eID accounts to avoid disruptions in digital administrative processes. In response to these changes, on June 4, 2025, Lawyer Nguyen Nhat Duong, representing HM&P Law Firm (“HM&P”), shared detailed insights in an online interview with Voice of Ho Chi Minh City (VOH) to help businesses understand the new regulation, grasp implementation procedures, and prepare accordingly.

Decree No. 69/2024/ND-CP on Electronic Identification and Authentication. Source: Government News

eID Accounts – The sole authentication tool for businesses

According to Lawyer Duong, an eID account constitutes the official legal identity of an enterprise as verified by the Ministry of Public Security, used for administrative procedures and electronic transactions. This account consolidates all key legal information, such as the enterprise's tax code, eID code, and legal representative details, and is the exclusive key to access and use online public services on platforms like VNeID, dichvucong.gov.vn, or dangkykinhdoanh.gov.vn. The unification of previously fragmented administrative accounts into a single eID account simplifies procedures, enhances data security and synchronization, and reduces errors in administrative transactions.

Registration process and key considerations when using eID accounts

Lawyer Duong outlined two methods for eID account registration:

• Online: via the VNeID app or vneid.gov.vn
• In person: at the Department of Administrative Management of Social Order (C06) or local Citizen ID issuance agencies

The application dossier includes:

• Application Form TK02 (as attached to Decree 69)
• Citizen ID card of the applicant
• Power of attorney (if the applicant is not the legal representative)

Typical processing time is 3 days for identity verification and 7 days for account activation from the date of result issuance.

Lawyer Duong also emphasized businesses’ obligations and associated risks during account usage:

• Ensure account information security and report any signs of unauthorized access;
• Be responsible for declared information and transactions conducted via the account;
• Fully comply with regulations on personal data management linked to digital identity.

It is also essential that businesses assign specific personnel to manage the eID account effectively and ensure compliance.

FDI enterprises and foreign legal representatives

Pursuant to Article 2 of Decree 69/2024/ND-CP, all foreign organizations and individuals operating in Vietnam, including foreign-invested enterprises (FDIs), are required to register eID accounts. For FDIs whose legal representatives are foreign nationals, there are two options:

1. The foreign individual obtains a Level-2 personal eID account (must have a valid residence card in Vietnam) and uses it to register for the enterprise;
2. Authorize a Vietnamese individual with a Level-2 account to complete the registration on behalf.

However, HM&P recommends that the legal representative personally complete the registration to ensure long-term convenience in account management and digital transactions. The second option should only be used in urgent cases.

Senior Associate Nguyen Nhat Duong

Automatic updates and mechanism for account suspension/restoration

An enterprise’s eID account information is automatically synchronized from the National Enterprise Registration Database and relevant sectoral databases. This ensures real-time accuracy and reduces the need for manual updates by the business.

However, the eID account may be suspended in the following scenarios: upon enterprise request, violations of VNeID’s terms of use, or if the business is dissolved, bankrupt, temporarily suspended, or terminated. Once the reason for suspension no longer exists, the account may be restored through the following process:

• The competent authority submits a suspension/restoration request to the Ministry of Public Security;
• Within 1 working day, the subordinate agency must process and escalate the request;
• Within the next 2 working days, the head of the identification authority will review and approve the request via the electronic system.

Lawyer Duong noted that enterprises must closely monitor their legal status and proactively coordinate with relevant authorities in case of technical or legal issues related to the eID account.

Proactive registration to avoid disruption – Practical challenges and recommendations

While there are currently no penalties for not having an eID account, from July 1, 2025, all previous administrative accounts (issued via ministerial/provincial portals) will be invalid. Failure to obtain an eID account will prevent businesses from performing any online administrative procedures, resulting in significant operational disruption.

In practice, Lawyer Duong observed that although the registration process is not complicated, many businesses face delays due to slow system responses—even when their applications are complete and valid. In several cases, businesses reported waiting over 2–3 months without receiving an account or further updates from the authorities.

Based on HM&P’s experience in supporting clients, Lawyer Duong strongly advises businesses to register early to avoid interruptions. HM&P also recommends that competent authorities review and upgrade technical infrastructure to ensure timely processing and facilitate a smooth transition for businesses during this digital transformation phase.

The registration and use of eID accounts is not merely a technical requirement but a strategic step to ensure continuity in administrative and digital operations. With practical experience, HM&P’s legal team stands ready to support businesses throughout this transition providing legal advice, technical assistance, and risk management solutions to ensure full compliance and smooth operations in the digital age.

Read more: Doanh nghiệp FDI vẫn phải đăng ký định danh điện tử VNeID