MVNO Licensing in Vietnam (2025): A Detailed Guide to Conditions & Application Dossiers

I. What are Telecommunications Services in Vietnam?

According to Clauses 7 and 8, Article 3 of the Law on Telecommunications 2023, telecommunications services are defined as follows:

7. Telecommunications services include basic telecommunications services and value-added telecommunications services:

a) Basic telecommunications service is the service of sending, transmitting, and receiving information between two individuals or a group of service users, or between terminal devices via a telecommunications network.

b) Value-added telecommunications service is a service that provides additional features for processing, storing, and retrieving information for users by sending, transmitting, and receiving information over a telecommunications network.

8. Basic telecommunications services on the Internet are telecommunications services whose primary function is to send, transmit, and receive information between two individuals or a group of service users on the Internet.

In summary, telecommunications services consist of both basic and value-added services.

II. The Non-Facility-Based Service Provider Model (MVNO)

This strategic business model, which is gaining significant traction, is formally defined and supported by the Law on Telecommunications 2023. A non-facility-based service provider is an enterprise that provides telecommunications services without establishing or owning a public telecommunications network.

Instead of investing billions in building and maintaining broadcast stations, these enterprises purchase wholesale traffic (voice, data) from one or more facility-based Mobile Network Operators (MNOs).

Subsequently, they repackage this traffic into their own unique products and service plans, selling them at retail to end consumers. This model allows businesses to focus their resources on their core strengths, such as marketing, brand building, customer care, and developing specialized digital services for niche markets.

III. Forms of Telecommunications Business

1. A telecommunications business includes the following forms:

a) Business in telecommunications services is the activity of investing in the establishment of a public telecommunications network and/or providing telecommunications services for profit.

b) Business in telecommunications goods is the activity of investing in the production, exchange, purchase, sale, or lease of telecommunications goods for profit.

2. The business of telecommunications services must comply with the provisions of this Law and other relevant legal regulations. The business of telecommunications goods must adhere to the provisions in Articles 42 and 55 of this Law and other relevant legal regulations.

IV. Telecommunications Licenses

1. A telecommunications license includes a license for business in telecommunications services and a license for telecommunications operations.

2. A license for business in telecommunications services includes:

a) A license to provide facility-based telecommunications services, with a term not exceeding 15 years, granted to enterprises providing services with network infrastructure.

b) A license to provide non-facility-based telecommunications services, with a term not exceeding 10 years, granted to enterprises providing services without network infrastructure (MVNOs).

V. Conditions for Licensing Non-Facility-Based Telecommunications Services

An applicant must meet the following conditions:

a) Possess an Enterprise Registration Certificate or an Investment Registration Certificate.

b) Not be in the process of dissolution or bankruptcy under a decision by a competent state authority.

c) Have a technical plan and a business plan that are consistent with the national information and communications infrastructure planning, and comply with this Law's regulations on telecommunications resources, interconnection, service charges, technical standards and regulations, quality of service, telecommunications infrastructure security, and the protection of the legitimate rights and interests of service users and other relevant legal provisions.

VI. Application Dossier for a Non-Facility-Based Telecommunications Service License

The enterprise applying for a license to provide non-facility-based telecommunications services must submit one (01) set of documents to the Ministry of Information and Communications (via the Vietnam Telecommunications Authority) and is responsible for the accuracy and authenticity of the dossier. The application dossier includes:

a) An application form for a license for business in telecommunications services, using Form No. 04 in the Appendix.

b) A valid certified copy of the Enterprise Registration Certificate or Investment Registration Certificate (or other equivalent valid certificates or licenses as prescribed by investment and enterprise laws). This can be a copy issued from the master register, a notarized copy, a copy printed by a competent authority from the national database, or a copy compared against the original.

c) A copy of the enterprise's current charter, bearing the enterprise's official seal.

d) A business plan for the first 05 years from the licensing date, using Form No. 07.

đ) A technical plan for the first 05 years, corresponding to the business plan, using Form No. 08.

VII. Conclusion

A thorough understanding of the legal regulations is the most critical first step to entering Vietnam's telecommunications market with the MVNO model. The Law on Telecommunications 2023 has laid out a clear roadmap, from service classification to the specific conditions and documentation required for licensing.

Although the process demands meticulous preparation of legal documents, a comprehensive business plan, and a solid technical plan, this foundation is essential for ensuring lawful and sustainable operations. Successfully completing the licensing procedure is not merely a legal obligation; it is the key that unlocks the door to a market brimming with potential, where innovation and flexible business models are actively encouraged.

Therefore, enterprises aspiring to become an MVNO should begin immediately by preparing a polished application dossier and a compelling business strategy. This is the starting point for transforming opportunity into a true competitive advantage in the digital era.

The information contained in this article is general and intended only to provide information on legal regulations. DB Legal will not be responsible for any use or application of this information for any business purpose. For in-depth advice on specific cases, please contact us.

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