How to Start a Headhunting Company in Vietnam

Start a headhunting company in Vietnam is a highly attractive opportunity for foreign investors and HR entrepreneurs seeking entry into one of Southeast Asia’s fastest-growing markets. With a strong economy, a young and skilled workforce, and rising demand for professional recruitment services, Vietnam is becoming a strategic hub for talent acquisition businesses. This guide provides a clear, practical overview of how to establish a headhunting company in Vietnam, covering legal requirements, licensing, investment conditions, and key operational considerations. Whether you are an individual investor, an international recruitment agency, or a global HR firm expanding into Vietnam, this article will help you understand the process, avoid common pitfalls, and build a compliant, scalable recruitment business in the Vietnamese market.

What is a Headhunting Company?

A headhunting company in Vietnam, also referred to as a recruitment agency or executive search firm, is a specialized service provider that helps businesses identify and hire top-tier talent. These companies focus on sourcing highly qualified candidates for mid-level, senior management, and specialized positions. Foreign investors and multinational companies often rely on headhunting firms in Vietnam to build strong local teams using tailored recruitment strategies that align with their business goals.

Legal Framework for Headhunting Companies in Vietnam

Establishing a headhunting or recruitment agency in Vietnam requires compliance with Vietnam’s labor and business regulations governing employment services and foreign investment. In practice, the legal framework for licensing and operating a recruitment company is primarily based on the following regulations:

• Employment Law 2019 – Governs employment-related activities in Vietnam, including recruitment, labor contracts, and employment service operations.

• Decree No. 23/2021/ND-CP – Provides detailed regulations on the licensing conditions, operational requirements, and management of employment service providers, including headhunting and recruitment agencies.

• Law on Enterprises 2020, as amended by Law No. 76/2025/QH15 (effective from 1 July 2025) – Regulates business establishment, corporate governance, legal representation, and enterprise registration procedures applicable to recruitment companies in Vietnam.

Foreign investors planning to open a recruitment agency in Vietnam must fully understand and comply with these laws to ensure proper licensing, ongoing compliance, and smooth business operations.

Business Code and Industry Classification- Start a headhunting company in Vietnam

To legally register a headhunting company or recruitment agency in Vietnam, foreign investors must select the appropriate business line in accordance with the Vietnam Standard Industrial Classification (VSIC 2025), issued under Decision No. 36/2025/QD-TTg and applicable to all new enterprise registrations from 2025 onward. Under VSIC 2025, recruitment and employment service activities fall under:

• VSIC Group 7810 – Activities of Employment Placement Agencies. This group covers services related to job placement, talent sourcing, executive search, and recruitment consultancy for employers across various industries.

The selected VSIC code must be clearly stated in the Enterprise Registration Certificate (ERC). Proper classification is essential, as incorrect or outdated industry codes may result in rejection of the registration dossier or difficulties when applying for the recruitment service operation license.

Conditions to Obtain a Recruitment License in Vietnam

To lawfully operate a headhunting or recruitment agency in Vietnam, foreign investors must obtain a Recruitment Service Operation License issued by the competent labor authority. Following the nationwide administrative restructuring effective from 2025, recruitment licensing and employment service management are now handled by the Department of Home Affairs (DOHA) at the provincial level. This license is a mandatory legal requirement and can only be granted when the company fully satisfies all statutory conditions prescribed under Vietnamese labor and investment regulations.

First, the company must maintain a legally leased physical office or branch office in Vietnam that serves as its official location for recruitment and employment service activities. At the time of submitting the application, the office lease must have a remaining term of at least 36 months. The premises must be eligible for business registration, compliant with local zoning and commercial use regulations, and suitable for professional recruitment operations. A valid lease agreement, together with any required supporting documents, must be included in the licensing dossier to demonstrate a stable and legitimate business presence in Vietnam.

In addition, the company is required to meet the financial deposit obligation applicable to recruitment service providers. This deposit is intended to safeguard the interests of job seekers and ensure the company’s ability to fulfill its legal and contractual responsibilities throughout its operations in Vietnam.

Finally, the company must appoint a qualified legal representative or operational manager who meets all professional and legal eligibility criteria. This individual must hold at least a university-level degree or possess a minimum of 24 months of relevant experience in employment services, human resources, or labor supply management within the previous five years. The appointed person must not be under criminal investigation or prosecution, must not be serving a prison sentence, and must not be subject to any legal or administrative restrictions that would prevent them from managing the company’s operations. This role is critical to ensuring ongoing compliance with Vietnam’s labor, employment, and recruitment regulations.

Step-by-Step Procedure to Establish a Headhunting Company

Establishing a headhunting or recruitment agency in Vietnam as a foreign investor involves several regulatory steps under Vietnam’s investment, enterprise, and labor regulations. In practice, the process can be summarized into the following key stages:

Step 1: Investment Registration Certificate (IRC)

For projects involving foreign ownership, investors are required to obtain an Investment Registration Certificate (IRC) as the first regulatory step. The IRC records key details of the investment project, including the intended business activities, investment capital, capital contribution structure, investor information, and the project’s operational duration.

Following the administrative reform effective from 2025, IRC applications are submitted to the Investment Registration Division under the provincial Department of Finance (DOF). The IRC must be issued before the investor can proceed with incorporating the company in Vietnam.

Step 2: Enterprise Registration Certificate (ERC)

Once the IRC is granted, the company is incorporated by applying for an Enterprise Registration Certificate (ERC). The ERC formally establishes the legal entity and sets out core corporate information such as the company’s name and registered address, charter capital, ownership structure, legal representative(s), and registered business lines in accordance with VSIC 2025.

Under the Law on Enterprises 2020, as amended by Law No. 76/2025/QH15, enterprises are also required to declare information on their beneficial owners as part of the enterprise registration process and to maintain this information on an ongoing basis. In practice, this involves identifying individuals who ultimately own or exercise control over the company, whether directly or indirectly, submitting such information together with the ERC application, and updating it in the event of any changes in ownership or control. Failure to properly declare beneficial ownership may result in delays during registration or compliance issues in post-licensing inspections.

Step 3: Recruitment License Application

After the company has been legally established, it must obtain a Recruitment Service Operation License in order to lawfully conduct headhunting and employment placement activities in Vietnam. This license is issued by the competent labor authority.

Following the administrative restructuring in 2025, recruitment licensing and other labor-related procedures are handled by the Department of Home Affairs (DOHA) in many provinces, including Ho Chi Minh City, while certain localities may still apply transitional arrangements under the former labor management structure.

Without this license, a company is not permitted to provide recruitment or employment placement services, even if it has already obtained both the IRC and ERC.

Step 4: Public Announcement

Within 20 working days from the date the Recruitment Service Operation License is issued, the company is required to publicly announce its licensing information. This announcement may be made via the company’s official website or through a printed publication such as a local or national newspaper.

The published information typically includes the company’s name, license number, scope of licensed activities, and relevant contact details, ensuring transparency and compliance with regulatory requirements..

Post-License Obligations

After obtaining the Recruitment Service Operation License, recruitment and headhunting companies in Vietnam are subject to ongoing compliance obligations. In practice, post-licensing compliance focuses on three key areas that licensing authorities typically review during inspections or renewals.

First, the company must maintain continuous compliance with its licensed scope and public disclosure requirements. The recruitment license must be used strictly for the approved employment service activities, and any changes to core information, such as the company’s name, address, legal representative, or scope of services, must be duly notified to the competent authority. Failure to properly update or disclose licensing information may be treated as operating beyond the licensed scope, which can lead to administrative penalties or suspension of recruitment activities.

Second, proper record-keeping and operational transparency must be ensured throughout the company’s operations. Recruitment agencies are expected to maintain complete and accurate records relating to recruitment activities, including service contracts with employers, candidate placement documentation, and relevant transaction records. These documents must be readily available for inspection by the Department of Home Affairs (DOHA) or other competent authorities. Inadequate record-keeping is one of the most common issues identified during compliance inspections and may result in fines or corrective measures.

Third, the company must comply with periodic reporting and license validity requirements. Recruitment service licenses are issued for a fixed term and must be renewed prior to expiration to avoid interruption of operations. In addition, recruitment agencies are required to submit periodic operational reports in accordance with regulations issued by the labor authority. Late submission, inaccurate reporting, or failure to renew the license on time may expose the company to penalties or the risk of license revocation.

Non-compliance risks:
In practice, violations of post-licensing obligations may result in administrative fines, suspension of recruitment activities, refusal of license renewal, or reputational risks when dealing with clients and partners. Ensuring ongoing compliance after licensing is therefore essential for the long-term and stable operation of a recruitment business in Vietnam.

Conclusion

Start a headhunting company in Vietnam offers significant potential in a fast-growing and increasingly competitive labor market, but it also requires strict compliance with Vietnam’s regulatory framework. As a conditional business line, recruitment services demand careful attention to investment approval, company formation, licensing, and ongoing compliance obligations. From securing the Investment Registration Certificate and Enterprise Registration Certificate to obtaining and maintaining the Recruitment Service Operation License, each step plays a critical role in the long-term success of your business. With the right legal strategy and local expertise, foreign investors can confidently start a headhunting company in Vietnam and operate efficiently and compliantly.

Contact us today to receive tailored legal and regulatory support for starting and growing your recruitment or headhunting business in Vietnam.