In the draft Law amending and supplementing a number of articles of the Labor Code, the Law on Archives, the Law on Gender Equality and the Law on Red Cross Activities, the Ministry of Home Affairs proposes to uniformly and synchronously adjust the content on cutting and simplifying administrative procedures and business conditions in the Investment Law, Resolution No. 66. 18/2026/NQ-CP.
Accordingly, it is not stipulated that labor subleasing is a conditional business line.
Labor subleasing activities are only carried out by labor subleasing enterprises, and apply to certain jobs, not applied to foreign workers working in Vietnam.
Thus, the new regulations are expected to remove "conditional business lines" and the condition of "licensing labor leasing activities".
This proposal is attracting the attention of the business community, especially flexible employers and human resource service providers, as it may create significant impacts on the business environment and labor management in the coming time.
According to Ms. Dang Ngoc Thu Thao - Director of Outsourcing & Labor Leasing Services, Manpower Vietnam, from a legal perspective, the abolition of the mechanism for issuing operating licenses for labor leasing is a positive step in the trend of administrative procedure reform and improving the investment and business environment in Vietnam.
The abolition of the mechanism for issuing operating licenses for labor leasing will help reduce time, compliance costs and administrative procedures for businesses. At the same time, this also reflects the trend of shifting from a management model based on licensing to a management model based on monitoring actual operations and corporate compliance responsibilities.
However, if only looking at the perspective of reducing licenses, it does not fully reflect the nature of the policy. Although licenses may be abolished, specific regulations on labor subleasing activities still need to be maintained to protect the legitimate rights and interests of subleasing workers.
Therefore, businesses participating in this activity still need to pay attention to complying with legal obligations such as carrying out procedures for notification of operations, maintaining deposit requirements, implementing periodic reporting regimes, ensuring obligations on wages, social insurance, labor safety and other rights of employees according to legal regulations.
From a market perspective, reducing entry conditions will create a more open business environment. However, businesses need to understand that compliance responsibility does not decrease but only shifts from pre-operation control to control throughout the operation process" - Ms. Thao said.
According to Ms. Thao, regularly updating policies, reviewing compliance management systems and strengthening labor management capacity are still key factors for businesses to develop sustainably in this field.
According to the Ministry of Home Affairs, as of December 31, 2025, there are 650 enterprises nationwide with valid Labor Leasing Licenses operating. These enterprises have headquarters in 29 provinces and cities directly under the Central Government, with a total of 342,083 workers hired.
In which, Ho Chi Minh City has 180 labor leasing enterprises; Dong Nai has 105 enterprises; Hanoi has 84 enterprises; Bac Ninh has 73 enterprises; Hai Phong has 66 enterprises.
