5 Key Changes to Electronic Identification and Authentication for Foreigners under Decree No. 320/2026/ND-CP
From September 28, 2026, Decree No. 320/2026/ND-CP officially takes effect, introducing several important amendments to the regulations on electronic identification and authentication under Decree No. 69/2024/ND-CP. Among these changes, the provisions applicable to foreigners include notable updates regarding eligible individuals, registration procedures, processing timelines, and benefits related to immigration procedures.
These changes are particularly important for businesses employing foreign workers, as well as companies operating in travel, hospitality, and visa consultancy. Understanding the new regulations early will enable businesses to proactively adjust their internal procedures, while providing foreign employees and customers with accurate guidance and minimizing potential issues during implementation.
5 key changes businesses should take note of
Expanded eligibility for foreigners to obtain electronic identification accounts
Under the amended Article 7 of Decree No. 320/2026/ND-CP, foreigners who legally enter or reside in Vietnam may be issued an electronic identification account upon request, without being classified into different account levels.
This differs from the system applicable to Vietnamese citizens, under which electronic identification accounts are divided into Level 1 and Level 2 depending on the scope of information integrated beyond the electronic identity card.
In practice, businesses do not need to determine an account level when assisting foreign experts or workers with registration. As long as the individual is legally entering or residing in Vietnam and wishes to register, they may proceed in accordance with the regulations. This also makes it easier for HR departments to communicate and guide foreign employees through the registration process when they first join the company.
More specific registration procedures at immigration authorities
Decree No. 320/2026/ND-CP amends and supplements Article 11, providing more detailed procedures for issuing electronic identification accounts to foreigners.
Accordingly, foreigners must visit the immigration management authority under the provincial-level Police, present their passport or other valid international travel document, and provide complete and accurate information in the Application Form for an Electronic Identification Account (Form TK01). The registration information includes the individual’s registered mobile phone number and email address, if any.
After receiving the application, the authorized officer will enter the information into the system and collect facial images and fingerprints for verification and comparison with the National Immigration Database. Foreigners will also be guided to install the National Identification Application for use after their account is issued.
In practice, these are important requirements for HR departments and visa support service providers to understand when assisting foreign workers and experts. Preparing the passport, registered mobile phone number, and required information for Form TK01 in advance can help streamline the process and reduce the need for additional documents or repeated visits due to incomplete preparation.
Clear processing timelines help businesses plan ahead
Article 7 of Decree No. 320/2026/ND-CP amends Clause 3 of Article 13, specifying the processing time for electronic identification account applications submitted by foreigners.
The processing timeline depends on whether biometric information is already available in the National Immigration Database:
- No more than 2 working days if facial image and fingerprint information is already available.
- No more than 5 working days if facial image and fingerprint information is not yet available.
Clearly defined processing timelines give both foreigners and businesses greater certainty when preparing documents and planning work schedules. This is particularly useful for businesses that frequently receive foreign experts or workers on short notice, as knowing the expected 2-to-5-working-day processing period makes it easier to arrange work assignments, immigration schedules, and expected start dates.
Specific procedures apply to foreigners under 14 and persons under guardianship
Decree No. 320/2026/ND-CP supplements Article 11 with specific procedures for issuing electronic identification accounts to foreigners under 14 years old, persons under guardianship, and represented persons.
These individuals must complete the procedure together with their legal representative or guardian at the immigration management authority under the provincial-level Police. The representative or guardian may use their own registered mobile phone number to declare information and register an electronic identification account on behalf of the represented or protected individual.
In practice, this provision is particularly relevant to businesses hiring foreign experts who are accompanied by their families, as well as immigration, relocation, and international education service providers whose clients include foreign children under 14.
HR staff and personnel responsible for supporting applications should note that children and persons under guardianship cannot complete the registration independently. A legal representative or guardian must participate in the procedure in accordance with the regulations.
An electronic identification account may facilitate automated immigration control
Under Article 20 on implementation provisions, Decree No. 320/2026/ND-CP amends the requirements for foreigners to enter or exit Vietnam through automated immigration control gates under Decree No. 67/2024/ND-CP.
Under the new regulations, foreigners whose information has been fully collected and updated in the National Immigration Database, or who have been issued an electronic identification account, will be eligible to use automated immigration control gates for entry and exit procedures.
In practice, this provides a useful benefit that businesses can highlight when encouraging foreign employees and experts to proactively register for an electronic identification account. For individuals who frequently travel for business or move between Vietnam and other countries, meeting the requirements for automated immigration control may make immigration procedures more convenient.
What should businesses do next?
These changes go beyond administrative procedures and directly affect how businesses support and manage foreign employees and customers. Businesses should therefore proactively review and update their internal procedures rather than waiting until a new application arises.
Some practical steps businesses can take now include:
- Update internal guidance for HR, reception, and other teams that regularly assist foreigners, covering registration procedures, required documents, and information needed to apply for an electronic identification account.
- Proactively inform foreign experts and workers about the benefits of electronic identification accounts, particularly their eligibility to use automated immigration control gates, and encourage early registration when needed.
- Review family-related cases, especially spouses and children under 14, to correctly identify the legal representative or guardian and prepare the appropriate procedures.
- Monitor further guidance from the Ministry of Public Security regarding application forms and implementation procedures, particularly for businesses that regularly process large numbers of foreign worker applications.
Proactive preparation will help businesses not only minimize errors when supporting applications but also establish standardized procedures that are more convenient for both responsible departments and foreign employees.
Nhị Gia supports electronic identification procedures for foreigners
Nhị Gia provides comprehensive support to businesses and foreign individuals with procedures related to visas, work permits, and electronic identification. From document preparation and appointment scheduling with immigration authorities to guidance on registering and activating electronic identification accounts on the National Identification Application, Nhị Gia supports clients in accordance with the procedures introduced under Decree No. 320/2026/ND-CP.
For cases involving multiple procedures, such as foreign experts accompanied by family members, children under 14 who must register through a representative, or businesses handling applications for a large number of foreign workers simultaneously, Nhị Gia provides support in monitoring progress, addressing arising issues, and coordinating each stage of the process. This helps businesses minimize the risk of delays in immigration procedures and ensure that foreign employees can begin their work as planned.
Contact Nhị Gia for advice on the appropriate procedures and solutions for your specific case.
This article is provided for reference purposes only. Actual procedures and required documents should be verified against the applicable guidance and requirements of the competent authorities at the time of implementation.
