Vietnam assignment checklist: permit validity, notification timing, document returns

The deadline is the first thing to check. From September 10, 2026, Vietnam's Decree 283/2026/ND-CP takes effect and sets administrative penalties for labor, social insurance, and overseas employment violations involving foreign workers and their employers. An assignee cannot start work on a lapsed paper trail, so the pre-assignment check treats permit validity, notification timing, and document returns as separate failure points.

The fine schedule makes the employer the target

The worker fine is direct, but the employer fine is what should drive the file. A foreign worker in Vietnam who works without a work permit or exemption certificate, or uses an expired permit or certificate, can be fined VND15 million to VND25 million. Companies hiring foreign staff on lapsed or missing permits, or without the required waiver, can be fined VND30 million to VND45 million for one to ten employees, VND45 million to VND60 million for 11 to 20, and VND60 million to VND75 million for 21 or more. A single missed renewal can move the exposure from one bracket to the next.

More triggers sit closer to day-to-day management. An employer can be fined VND5 million to VND10 million for each foreign worker whose job does not match the work permit or exemption certificate, and the same per-worker fine, capped at VND75 million, applies if they fail to recover or return those documents. The role part catches job drift. The document part requires a clear owner for retrieval and return before the assignment ends.

Notification timing is the failure point

When a foreign employee qualifies for the under-90-days-per-year waiver, the hiring company must give the relevant labor regulator notice no later than three working days before the job starts. Decree 283/2026/ND-CP introduces a first-time employer fine of VND1 million to VND3 million for failing to meet the pre-work notification requirement. A clean permit does not cure a missing notice.

Companies can be fined VND1 million to VND3 million if they fail to file, delay, or submit incomplete notices for permit-exempt foreign staff, or for permit or exemption holders who work for the same company across several centrally administered cities or provinces. The multi-province notice is a separate filing duty: the assignee may be properly permitted, but the employer still needs the correct notice filed for the correct location.

The checklist makes the fine schedule a start-date test

Run this before the assignee's start date. Each item is a yes/no check that maps to a fine trigger in the decree.

• Confirm the Vietnam work permit or work permit exemption certificate is valid on the start date.
• Check the assigned role and duties against the permit or certificate.
• If the assignment uses the under-90-day exemption, confirm the labor authority notice was filed at least three working days before work starts.
• If the assignee will work in more than one centrally governed city or province for the same employer, confirm the multi-province work notification is complete.
• Confirm a document recovery or return step is assigned before the assignment ends.

Validity stops the most expensive error: an expired document that the assignee still carries. The role check catches a mismatch that can create a per-worker fine. Notification items protect the notice file, where a missing, late, or incomplete notice can trigger a fine even when the underlying permit is clean. Return steps close the file before the assignee leaves, because an unreturned document can remain an employer exposure.

Assign an owner to the file and set a reminder before the start date. The owner should keep the permit, the notice, the role details, and the return step in a single place. If any item fails, stop the start date and fix the gap before the assignee begins work.

If the assignee changes role or location during the assignment, rerun the checklist. A clean start date does not carry forward. The same document that was valid at the start can become the problem after a transfer or a project change. The file should show the change and the corrected notice or permit step.