Sub-licenses are a common legal term, but they pose significant challenges for businesses during the startup phase. Understanding this type of license helps organizations avoid legal risks and ensures smooth business operations in accordance with Vietnamese law.
Understanding sub-licenses in business operations correctly.
A sub-license is essentially the common name for a conditional business license. This is a legal document issued by a competent state agency to a business after it has met all the standards regarding facilities, capital, personnel, or professional certifications. In the current economic climate, defining what a sub-license is is more important than ever, as regulations governing various industries are gradually tightening to protect consumers.
The difference between a Business Registration Certificate and a Sub-license lies in their timing and purpose. While the Business Registration Certificate establishes legal entity status, the sub-license is the practical key to conducting conditional business activities under the Investment Law. In international terminology, a sub-license is often referred to as a "Sub-license" or "Conditional Business License," indicating its accompanying function after the main license.
Legal characteristics and role of sub-licenses
Sub-licenses possess unique characteristics aimed at controlling industries that directly impact national security, public health, and social order. To identify this type of document, businesses need to pay attention to the following key points.
- Mandatory nature: Businesses are only permitted to operate after being inspected and officially licensed by the relevant authorities.
- Conditional requirements: These are linked to stringent professional qualifications of the head of the facility or fire safety standards of the establishment.
- Validity Period: Unlike business registration certificates which are valid indefinitely, many of these types of licenses have a specific validity period (usually 3 to 5 years) and require timely renewal.
- Diverse forms: Beyond its common name, it also exists as a Professional Practice Certificate, a Certificate of Eligibility, or other specialized approval documents.
Common industries require sub-licenses.
According to legal regulations, there are over 200 conditional business sectors. Identifying the correct category is the first step in helping businesses develop legally compliant operational plans. Below is a summary table of some typical industry groups and their corresponding regulatory agencies.
| Occupational groups | Typical license types | The competent authority |
|---|---|---|
| Education and Training | License to establish a foreign language and computer training center. | Department of Education and Training |
| Transportation | License for road transport business | Department of Transportation |
| Public order and security | Certificate of eligibility regarding security and order | Department/Division of Police for Administrative Management of Social Order |
| Healthcare and Pharmaceuticals | Clinic operating license, GPP (Good Pharmacy Practice) | Health service |
| Tourism | Travel service business license | Vietnam National Tourism Administration |
The table above only lists common business sectors; in reality, each type of license will have its own detailed documentation requirements and assessment process that businesses need to carefully research.
In addition to the list above, the following sectors are also key areas that frequently generate application needs. sub-licenses.
- Education sector: Focus on establishing skills training centers, study abroad counseling services, or private preschool systems.
- Transportation sector: Includes passenger transportation by contract vehicles, inland waterway freight transport, and specialized logistics services.
- Security services industry: Strict requirements for personnel and security plans approved by the local police authority.
- Healthcare and cosmetics industries: Strict control from cosmetics production to the operation of private medical facilities.
- Food industry: A Certificate of Food Safety and Hygiene Compliance is mandatory for products to be marketed.
What are the conditions and procedures for applying for a sub-license?
The licensing process can vary depending on the industry, but generally, businesses should follow these standardized steps to optimize time. So where should businesses apply for sub-licenses? Typically, the authority will be the specialized departments in the province/city where the business is headquartered.
- Identifying industry categories: You need to look up the industry codes based on the 2020 Investment Law (amended and supplemented) to know the exact minimum conditions that must be met.
- Prepare legal documents: A standard application package typically includes a completed application form, a copy of the business registration certificate, a floor plan, a list of personnel, and relevant professional certifications.
- Submitting applications to specialized agencies: Depending on the type of license, businesses can submit applications directly or through the online public service portal of departments such as the Department of Health, the Department of Education, or the Department of Transport.
- On-site assessment: This is a crucial step where authorities directly visit the facility to inspect infrastructure and equipment and compare them with the actual records.
- Receiving the results: After the review period (usually 10 to 30 working days), the business will be granted a license or receive a written response if any modifications or additions are needed.
Important notes to avoid administrative penalties.
Operating a business without a sub-license or with an expired license not only affects reputation but also leads to serious legal consequences. According to the summary report of the General Department of Market Management (2025), the number of businesses penalized for lacking specialized licenses tends to increase due to the strengthening of inter-agency inspections.
- Penalties: Based on Decree 122/2021/ND-CP, conducting business without a license can result in fines ranging from 50 million to over 100 million VND, depending on the severity of the violation.
- Risk of suspension of operations: In addition to fines, businesses may be forced to cease operations immediately and have their business registration certificate revoked if serious and prolonged violations occur.
- Deadline tracking: Business owners should set up a reminder system or delegate the legal department to track deadlines and proceed with renewals at least one month before they expire.
Comprehensive consulting and support services for obtaining sub-licenses.
For newly established businesses or those with complex business models, handling the procedures yourself often wastes time due to repeated rejections of documents. Using professional licensing services is a solution that allows you to fully focus on market development.
Reputable consulting firms nowadays typically offer comprehensive support packages that include the following items.
- Review and advise on requirements regarding minimum registered capital, personnel certifications, and site standards to ensure the highest possible application approval rate.
- On behalf of the business, we prepare the necessary documents and submit them to the competent government agencies.
- The representative received the inspection team and explained any issues that arose during the on-site inspection at the business premises.
- Helping businesses optimize costs and time, ensuring projects are launched on schedule as committed.
Conclude
Sub-licenses are not only a mandatory administrative procedure but also a measure of a business's capacity and credibility with regulatory agencies and the community. Full compliance with regulations on conditional business licenses from the outset will help the business develop steadily and avoid unfortunate legal risks.
If you still have questions about current regulations or need assistance with expediting your specialized licensing application, please contact us. contact Contact us today to receive comprehensive, professional advice and support from our team of legal experts.
Contact information for MAN – Master Accountant Network
- Address: 19A, 43rd Street, Tan Thuan Ward, Ho Chi Minh City
- Mobile/Zalo: 0903 963 163 – 0903 428 622
- Email: man@man.net.vn
Content production is overseen by: Mr. Le Hoang Tuyen – Founder & CEO of MAN – Master Accountant Network, CPA Vietnam with over 30 years of experience in accounting, auditing, and financial consulting.
