How can a company complete electronic identification when its foreign director hasn’t yet received a temporary residence card?
Company D, located in Long Hậu Industrial Park (Long An), found itself in a tricky situation. After appointing Mr. T, a Singaporean national, as director, they tried to register the company’s electronic ID account through the VNeID system. However, as soon as they input the data, the system flagged an error: the legal representative didn’t meet the requirements because he didn’t have a personal VNeID Level 2 account. To open such an account, a temporary residence card is required. In short, the entire registration process was held up simply because one card hadn’t been issued yet.
So what can a company do if its foreign director doesn’t have a temporary residence card and needs to complete electronic identification without getting stuck in administrative procedures?
Why does corporate electronic identification have to go through the legal representative?
Under new regulations, all companies that transact with state agencies through digital platforms must complete electronic identification via a VNeID account. The catch: this registration must be done in the name of the company’s legal representative. Specifically:
The legal representative (director or chairperson as per business registration) must have a personal VNeID Level 2 account.
To obtain Level 2, they must hold either a citizen ID card (for Vietnamese nationals) or a valid temporary/permanent residence card (for foreigners) issued in Vietnam.
This poses a dilemma for many foreign-invested enterprises. The newly appointed director has just entered the country and hasn’t yet obtained a residence card, meaning he cannot open a VNeID personal account. Without a personal account, the company cannot register its corporate account, leaving processes indefinitely delayed.
Two solutions for companies when the foreign director lacks a temporary residence card
When a company appoints a foreign director but hasn’t yet obtained the necessary temporary residence card, electronic identification registration immediately hits a roadblock. This “stuck” status can stall administrative tasks and even disrupt internal operations—especially for FDI companies that frequently interact with government agencies digitally. So, while waiting for the residence card, how can a company avoid missing important deadlines? Here are two flexible solutions to consider:
1. Add a backup legal representative who is Vietnamese
This is the fastest workaround if the company doesn’t want to experience delays. The company updates its business registration to add another legal representative—either a Vietnamese national or a foreigner with a valid residence permit.
That person can register the corporate electronic ID on behalf of the director.
However, companies must take note:
The company charter must clearly define independent representations for each legal representative.
Otherwise, when multiple representatives are in place, any official document or administrative procedure may require signatures from both, leading to complications later.
2. Expedite the temporary residence card application for the director
If the company wants to maintain the original legal structure, the only viable solution is to quickly complete the foreign director’s residence card application. Required documents include:
Original passport
3×4 photo (white background, no glasses)
Work permit or exemption document
Business registration certificate and investment certificate (if applicable)
Forms NA6 and NA8 (as per the Immigration Department’s template)
After the card is issued, the director can obtain a personal VNeID Level 2 account and thus complete the company’s electronic identification.
In practice, many companies opt for a combined strategy: add a Vietnamese backup representative to handle urgent tasks and simultaneously file for the foreign director’s residence card.
How has DEDICA supported FDI companies?
As a trusted legal partner for many foreign-invested enterprises, DEDICA has successfully resolved numerous cases like this—Company D being a prime example.
Upon receiving the request, DEDICA proposed a dual strategy:
Assisted the company in updating their registration to add a Vietnamese legal representative with an existing VNeID account.
Simultaneously prepared and submitted the director’s residence card application according to the latest Immigration Department guidelines.
But it didn’t stop there; DEDICA fully supported the company by:
Drafting and reviewing the TK01 form (for registering the corporate ID account)
Guiding biometric enrollment at the police department
Linking personal VNeID data with the corporate account to ensure consistency
Results: within 10 working days, Company D successfully used its electronic ID to fulfill obligations—from tax declaration and digital signing to e-transactions with customs, tax, and social insurance authorities.
Foreign directors without temporary residence cards don’t just risk their personal compliance—they can bring the entire company’s digital activities to a standstill. But with the right procedures and legal strategy, companies can overcome these hurdles quickly.
Are you in the process of appointing a foreign director?
Worried about missing deadlines for registering your company’s electronic ID?
DEDICA stands ready to support you—from strategic legal advice to full implementation of your ID application.
Contact DEDICA Law Firm today for expert legal consultation!
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