As part of the shift from pre-approval to post-inspection management, together with stronger inspection and supervision, Government Resolution No. 66.18/2026/NQ-CP, effective from July 1, 2026, to February 28, 2027, suspends procedures for issuing, renewing, reissuing, and revoking labour outsourcing licences. Under the new management mechanism, enterprises are required to make a deposit of 2 billion VND, notify the authorities when commencing or terminating operations, and submit quarterly reports. At the same time, state management agencies are tasked with expanded responsibilities for disclosure, monitoring, inspection, and supervision.
However, this field poses potential risks concerning wages, social insurance, labour outsourcing periods, jobs permitted for outsourcing, and the misuse of service contracts or work-contracting agreements to conceal the true nature of labour outsourcing. As a result, challenges will likely emerge during the initial implementation period.
In many cases, the boundary between labour outsourcing and service provision, work contracting, or subcontract manufacturing remains ambiguous. Some contracts are labelled as “service” or “work contracting” agreements, while the employees remain directly managed and supervised by the hiring enterprise. This is one of the most difficult issues in post-inspection, requiring management officials to assess the substance of the actual relationship rather than relying solely on the name of the contract.
At present, management data remain fragmented. Information on business registration, deposits, social insurance, labour fluctuations, complaints, disputes, occupational accidents, and the handling of violations is dispersed across different agencies. Meanwhile, the management apparatus is being streamlined and can no longer conduct broad-based inspections manually.
The essence of the shift in management methods is to move the “point of control” from before enterprises enter the market to their active operational phase. Post-inspection will only succeed if management agencies have timely data, clear risk-identification criteria, and sufficiently rapid intervention mechanisms to protect employees.
Each locality therefore needs to proactively manage all relevant groups of enterprises and continuously update information on their operations, deposits, the number of outsourced workers, hiring enterprises, jobs, outsourcing periods, social insurance participation, incidents, complaints, and handling results. This approach will help resolve issues where data are duplicated while compliance histories remain difficult to track.
Another critical priority is the need to train post-inspection officials to identify the true nature of labour outsourcing relationships, distinguish them from service and work-contracting arrangements, interpret social insurance data, assess risks, and handle administrative violations.
At the same time, hotlines, online reporting channels, and mechanisms for receiving information from employees, hiring enterprises, trade unions, and grassroots authorities should be maintained. All reports must be screened and verified before being made public, so that post-inspection does not become an enterprise-ranking mechanism lacking clear legal foundations.
The Ministry of Home Affairs should issue a unified post-inspection process for labour outsourcing activities, together with a set of risk-classification criteria and detailed guidance on distinguishing labour outsourcing from service provision, work contracting, and subcontract manufacturing.
It should also urgently develop a national database of labour outsourcing enterprises and establish mechanisms for connecting and sharing data with related management databases. Common data standards should be prescribed so that localities can begin implementation immediately and connect their systems smoothly in subsequent phases.
