Regulations applicable to foreign investors engaging in dental clinic services

1. Legal Basis

- The WTO Schedule of Specific Commitments on Trade in Services (GATS);

- Law on Investment No. 143/2025/QH15 dated 11 February 2025;

- Law on Medical Examination and Treatment No. 15/2023/QH15 dated 9 January 2023;

- Decree No. 96/2023/ND-CP dated 30 December 2023 detailing certain provisions of the Law on Medical Examination and Treatment;

- Decision No. 36/2025/QD-TTg dated 29 September 2025 promulgating the Vietnam Standard Industrial Classification System.

2. Definition of Dental Services

Pursuant to Section 93 of the Annex on Explanatory Notes for Services Listed in the United Nations Central Product Classification (CPC) in Vietnam’s WTO Services Trade Commitment Manual, dental services (CPC 93123) are defined as follows:

93123 - Dental Services

Dental services refer to services involving the diagnosis and treatment of diseases or disorders of the teeth, as well as services aimed at preventing the development of dental diseases, including dental surgery and services provided in hospitals for inpatients.

Dental services may be provided in healthcare facilities located in schools, companies, nursing homes, etc., as well as in dental offices and treatment rooms. These services include general dental care services, such as routine dental examinations and treatment, preventive dental care, treatment of tooth decay, etc.; orthodontic services, including the treatment of protruding teeth, impacted teeth, etc.; oral surgery services; and other specialized dental services, such as periodontics, cleft lip and palate treatment, and dental implantation.

3. Market Access Restrictions

Pursuant to Section II.8 (Health and Social Services) of Vietnam’s WTO Schedule of Specific Commitments on Services, dental services and medical examination services (CPC 9312) are committed as follows:

“NForeign service suppliers are permitted to provide services through the establishment of 100% foreign-invested hospitals, joint ventures with Vietnamese partners, or business cooperation contracts.

The minimum investment capital required for a hospital is USD 20 million, for a general clinic (policlinic) is USD 2 million, and for a specialized treatment facility is USD 200,000.”

Accordingly, foreign investors are permitted to conduct dental clinic service business through a joint venture with a Vietnamese partner or through a business cooperation contract. In the case of establishing a hospital, foreign investors are permitted to establish a 100% foreign-owned hospital. The minimum investment capital requirement for a dental clinic is USD 200,000.

4. Classification of Economic Sector Codes under Vietnamese Law

Pursuant to Appendix I (Vietnam Standard Industrial Classification System) issued together with Decision No. 36/2025/QD-TTg, the relevant economic sector code (VSIC) applicable for business registration is:

Code 8620 – Activities of general, specialized and dental clinics

This group includes activities of general clinics, specialized clinics, and dental clinics where patients are mainly examined and treated on an outpatient basis according to prescriptions and treatment plans provided by experienced doctors and medical practitioners.

• 86201: Activities of general and specialized clinics

This group includes:

- Medical examination, treatment, consultation, and healthcare services in general and specialized medical fields performed by doctors, medical specialists, and surgeons;

- Activities of family planning centers providing medical treatments such as sterilization or abortion, without accommodation facilities;

- These activities may be conducted at private clinics, group medical practices, outpatient clinics of hospitals, nursing homes, labor organizations, as well as at patients’ homes;

- Personal consultation services for inpatients.

Exclusions:

- Inpatient medical care activities classified under Group 86101 (Hospital activities);

- Medical assistance activities such as the activities of midwives, nurses, and physiotherapists classified under Group 86990 (Other human health activities not elsewhere classified).

• 86202: Activities of dental clinics

This group includes:

- Activities of dental clinics;

- General or specialized dental activities, such as dental departments, pediatric dentistry, and research into oral and dental diseases;

- Orthodontic activities;

- Dental surgery activities;

- Dental consultation and oral healthcare services.

Exclusion: The manufacture of dentures, artificial teeth, and dental prosthetic devices for dental clinics is classified under Group 32501 (Manufacture of medical and dental instruments and supplies).

5. Conditions for Conducting Dental Services Business under Vietnamese Law

5.1. General Conditions for Granting an Operating License to Medical Examination and Treatment Facilities

Article 40 of Decree No. 96/2023/ND-CP stipulates the general conditions for granting an operating license to medical examination and treatment facilities as follows:

(i) Scale: The facility must have a scale appropriate to each type of medical examination and treatment facility organization.

(ii) Facilities:

• The facility must have a fixed location that satisfies legal requirements regarding: structural safety, fire prevention and firefighting, infection control, environmental protection, and radiation safety (if applicable); and must ensure adequate electricity and water supply for the operation of the medical examination and treatment facility;

• The facility must have signage, diagrams, and directions to departments, rooms, professional units, and administrative sections;

• In cases where the facility has additional premises located outside the main premises of the medical examination and treatment facility, such premises must satisfy the specific conditions applicable to each type of medical examination and treatment facility organization.

(iii) The facility must have medical equipment appropriate to the approved list of professional and technical services and the registered scope of operations.

(iv) Human resources:

• The facility must have a sufficient number of licensed practitioners corresponding to its scale, list of technical services, and the practitioner ratio prescribed by the Minister of Health;

The person responsible for technical expertise must be a full-time practitioner at the facility and must have a scope of practice appropriate to the facility’s professional activities. Such person must have at least 36 months of professional practice experience within that scope of practice, except in cases where the practitioner holds the title of traditional medicine practitioner, possesses a family remedy, or applies a family traditional healing method;

Where the medical examination and treatment facility consists of multiple specialties, the practicing license of the person responsible for technical expertise must include a scope of practice corresponding to one of the specialties registered by the facility;

•  The person in charge of a professional department or specialized unit of the facility must hold a practicing license appropriate to that specialty and must work full-time at the facility;

• Practitioners must be assigned duties that are consistent with the scope of practice approved by the competent authority;

• Medical technicians whose scope of practice is medical laboratory testing and who hold university qualifications are permitted to read and sign laboratory test results. Where the medical examination and treatment facility does not have a practitioner holding a practicing license with one of the following titles: a medical specialist doctor in laboratory medicine, or a medical technician with a university-level qualification in medical laboratory testing, the doctor who orders the test shall read and sign the test results;

• Medical technicians whose scope of practice is medical imaging and who hold university qualifications are permitted to read and describe diagnostic images. Where the medical examination and treatment facility does not have a practitioner holding a practicing license with one of the following titles: a medical specialist doctor in medical imaging technology, or a medical technician with a university-level qualification in medical imaging, the doctor who orders the diagnostic imaging procedure shall read and sign the diagnostic imaging results;

• Other individuals participating in the medical examination and treatment process who are not required to obtain a practicing license under Point (d), Clause 2, Article 19 of the Law on Medical Examination and Treatment (including medical physics engineers, radiotherapy engineers, biotechnology engineers, biotechnology graduates, and other individuals, hereinafter referred to as “employees”) may perform professional activities as assigned by the person responsible for technical expertise of the medical examination and treatment facility. Such assignments must be consistent with their professional qualifications and capabilities;

• Where a practitioner is also a lecturer at a health sciences training institution and works concurrently at a medical examination and treatment facility that serves as a practice facility of such training institution, such practitioner may concurrently hold a leadership position in the facility’s professional departments or units.

5.2. Conditions for Granting an Operating License to Specialized Clinics

In addition to satisfying the general conditions, specialized clinics must meet the specific requirements prescribed in Article 43 of Decree No. 96/2023/ND-CP as follows:

(i) Scale and organizational structure of the clinic::

• The clinic must have at least one specialty;

• Where a specialized clinic satisfies the conditions applicable to other forms of medical examination and treatment facilities as prescribed in Article 39 of Decree No. 96/2023/ND-CP (excluding hospitals), the clinic may expand its scope of professional activities corresponding to such forms of medical examination and treatment facilities, provided that the total number of organizational forms does not exceed three.

(ii) Facilities:

• The clinic must have a patient reception area and an examination room with a minimum area of 10 m²;

• Where the clinic performs technical procedures or interventions, in addition to the examination room, it must have a separate room for performing such technical procedures or interventions with a minimum area of 10 m²; where physical therapy techniques are performed, the room for such technical procedures or interventions must have a minimum area of 20 m²;

• The clinic must have a sterilization area for processing reusable medical instruments, except where no instruments require resterilization or where the clinic has entered into a contract with another medical examination and treatment facility for sterilization services.

(iii) The clinic must have an anaphylactic emergency kit and sufficient specialized emergency medicines appropriate to the specialties within the clinic’s scope of professional activities.

5.3. Conditions for Granting an Operating License to Dental and Maxillofacial Clinics

In addition to satisfying the general conditions, dental and maxillofacial clinics must meet the specific requirements prescribed in Article 47 of Decree No. 96/2023/ND-CP as follows:

(i) Facilities:

• The clinic must have a patient reception area and an examination room with a minimum area of 10 m²;

• The clinic must arrange at least one dental chair, with a minimum area of 5 m² allocated for each dental chair;

• Where dental implant procedures are performed, the clinic must have a separate room dedicated to dental implant procedures with a minimum area of 10 m².

(ii) Human resources: The person responsible for technical expertise must be a practitioner holding one of the following professional titles:

• Doctor with a scope of practice in dentistry and maxillofacial medicine;

• Doctor with a scope of practice in dental and maxillofacial specialty.

(iii) The clinic must have an anaphylactic emergency kit and sufficient specialized emergency medicines appropriate to the specialties within the clinic’s scope of professional activities.

Investment in the dental clinic sector in Vietnam presents significant development opportunities due to strong market demand and an increasingly improved investment environment. However, to ensure smooth implementation and compliance with legal requirements, foreign investors must fully satisfy market access conditions, requirements for obtaining medical examination and treatment operating licenses, and other relevant sector-specific regulations. Thorough legal research during the investment preparation stage not only helps minimize legal risks but also establishes a solid foundation for long-term business operations. In cases where investors encounter difficulties regarding investment procedures or regulatory requirements, they should seek advice from legal professionals to receive appropriate guidance and support tailored to each specific project.