2026 UPDATE: INTERNAL LABOR REGULATIONS REGISTRATION PROCEDURE — RECEIVING AUTHORITY HAS CHANGED

Adjustments regarding the competent authorities receiving internal labor regulation registrations in 2026 reflect administrative reform and the decentralization of state management in the labor sector. Correctly identifying the competent authority responsible for receiving registration dossiers is crucial to the legal validity of internal labor regulations, as these documents only officially take effect upon successful completion of statutory registration procedures. Timely updates on shifting jurisdictional competence and procedural requirements enable enterprises to proactively ensure regulatory compliance, maintain the legal enforceability of internal policies, and mitigate legal risks arising from misdirected submissions.

1. Scope of Application

The procedure for registering Internal Labor Regulations (ILR) is mandatory for employers with 10 or more employees. This applies to both first-time registration and re-registration whenever the ILR is amended. Employers with branches, units, or production/business facilities across multiple locations must submit the registered ILR to the competent authority in each location where a branch or unit is based.

2. Key Update to the 2026 Procedure

The most notable change in 2026 concerns the authority receiving the registration dossier. Previously, dossiers were submitted to the specialized labor agency under the provincial People’s Committee. Under the newly published administrative procedure in Decision No. 628/QĐ-BNV of 2025, employers now submit their ILR registration dossier to the specialized home affairs (nội vụ) agency under the provincial People’s Committee, or the equivalent agency at the commune level where authorized by the provincial authority. This change reflects the reorganization of state labor management functions into the home affairs sector following the streamlining of the administrative apparatus.

In terms of timeline and processing steps, the core rules remain unchanged: employers still have 10 days from the date of issuance to submit the dossier; the receiving authority has 7 working days to review it; and the ILR takes effect 15 days after the authority receives a valid, complete dossier.

3. Legal Procedure Required

Procedure name: Registration of Internal Labor Regulations (updated process).

Step 1: Within 10 days of issuing the ILR, the employer prepares the required dossier and submits it to the specialized home affairs agency under the provincial People’s Committee (or the commune-level equivalent, if authorized) where the business is registered. The dossier may be submitted in one of three ways: in person at the receiving authority; via the National Public Service Portal; or by postal service.

Step 2: Within 7 working days of receiving the dossier, if the receiving authority identifies any unlawful provisions in the ILR, it notifies the employer and provides guidance for revision and re-submission.

Outcome: The ILR takes effect 15 days after the competent authority receives a valid and complete dossier. Where an employer amends a previously registered ILR, it must go through the re-registration process described above.

4. Penalties for Violations

An employer that fails to submit the registration dossier to the correct authority under the updated procedure, fails to register the ILR, or applies an ILR that has not been registered or is not yet effective, may be subject to administrative penalties under current labor law regulations. Notably, amending an ILR without completing re-registration is also treated as a violation of the registration obligation, subject to penalties similar to those for never having registered at all.