Many single-member limited liability companies in Vietnam consist of exactly one person: an owner who is also the director, with no staff and no salary paid to themselves. A common assumption is that “no employees means no insurance to pay”. Since 1 July 2025 that assumption no longer holds, and the social insurance authority has now moved to proactive monthly checks.
On 14 September 2026, Vietnam Social Security (VSS) issued Official Letter No. 3603/BHXH-QLT to its provincial branches on continuing to strengthen the management and collection of social insurance and health insurance for “one-person enterprises”.
Quick summary
| Item | Official Letter 3603/BHXH-QLT |
|---|---|
| Issued by | Vietnam Social Security, addressed to the social security offices of all provinces and centrally governed cities |
| What is a “one-person enterprise”? | A business model run by a single individual with no employees (footnote 1 of the letter) |
| What will the authority do? | Every month, obtain data from the tax authority and the business registration authority and identify operating or newly established enterprises and household businesses not yet participating in social and health insurance |
| After the review | Immediately take steps to bring people into compulsory social and health insurance, including “one-person enterprises” and household business owners |
1. What does Official Letter 3603/BHXH-QLT require?
The letter implements the Minister of Finance’s instructions in Notice No. 586/TB-BTC dated 17 July 2026. VSS asks its provincial offices to carry out two sets of tasks:
First — monthly screening. Each month, coordinate with the tax authority and the business registration authority to request information or data sharing on enterprises and household businesses, and assign direct collection officers to fully and promptly identify operating or newly established enterprises and household businesses that have not yet enrolled in social and health insurance. On that basis, immediately implement measures to bring into compulsory social and health insurance the employees of enterprises (including “one-person enterprises”) and household business owners, following Official Letter No. 1584/BHXH-QLT dated 15 July 2025.
Second — collection and issuance under the proper procedures. Management and collection of social and health insurance, and the creation and issuance of social insurance books and health insurance cards for employees and household business owners, must follow Circular No. 09/2026/TT-BTC dated 3 February 2026 of the Ministry of Finance and Decision No. 366/QĐ-BHXH dated 29 April 2026 of VSS on the procedure for collecting social, health and unemployment insurance and issuing insurance books and cards.
The “direct collection officer” approach follows Official Letter No. 3411/BHXH-QLT dated 28 August 2026 of VSS (footnote 2 of the letter).
The practical point for businesses: business registration data and tax data will be matched against social insurance enrolment data every month. A company that has a tax code and is operating, but has no one enrolled in social insurance, is likely to appear on the review list.
2. Why is a company with no employees still within compulsory social insurance?
Official Letter 3603/BHXH-QLT does not create a new obligation. The obligation comes from Law on Social Insurance No. 41/2024/QH15, effective from 1 July 2025.
Point n, Clause 1, Article 2 of the 2024 Law brings into compulsory social insurance: enterprise managers, controllers, representatives of state capital and representatives of an enterprise’s capital as prescribed by law who do not receive a salary. Under the 2014 Law, only enterprise managers who received a salary were covered.
In a “one-person enterprise”, the only individual is usually the owner and director — that is, an enterprise manager. Therefore:
- If that person takes no salary — they fall under Point n, Clause 1, Article 2 of the 2024 Law and choose their own contribution base (see Section 3).
- If that person is paid a salary by the company — they fall within the group of salaried enterprise managers and contribute on the salary paid, in the same way as an ordinary employee.
In other words, having “no employees” does not take a company outside compulsory social insurance, because the manager is already a covered participant.
3. How much does an unsalaried manager contribute?
Contribution base. Under Point d, Clause 1, Article 31 of the 2024 Law, an unsalaried enterprise manager may choose their contribution base, from a minimum of the reference level up to 20 times the reference level at the time of contribution. The chosen base can only be changed after at least 12 months of contributions.
Until the statutory base salary is abolished, the reference level equals the base salary. From 1 July 2026 the base salary is VND 2,530,000 per month, so the permitted range is VND 2,530,000 to VND 50,600,000 per month.
Contribution rates:
| Item | Rate | Legal basis |
|---|---|---|
| Sickness and maternity fund | 3% | Point a, Clause 4, Article 33, Law on Social Insurance 2024 |
| Retirement and survivorship fund | 22% | Point a, Clause 4, Article 33, Law on Social Insurance 2024 |
| Health insurance | 4.5% | Decree No. 188/2025/NĐ-CP guiding the Law on Health Insurance |
| Total | 29.5% | Paid in full by the manager |
Payment method. Under Point b, Clause 4, Article 33 of the 2024 Law, the manager pays directly to the social security office or through the enterprise they manage, monthly, every 3 months or every 6 months. Payment is due no later than the last day of the month immediately following the payment cycle.
4. Worked examples
Example 1 — Owner-director, no salary, no employees
Mr A is the owner and director of single-member LLC X. He takes no salary and the company has no employees. Mr A chooses the minimum contribution base of VND 2,530,000 per month (applicable from 1 July 2026).
- Social insurance: 2,530,000 × 25% = VND 632,500 per month
- Health insurance: 2,530,000 × 4.5% = VND 113,850 per month
- Total: VND 746,350 per month; if paid every 6 months, VND 4,478,100 per cycle.
Example 2 — Corporate owner, appointed director
Single-member LLC Y is 100% owned by an overseas parent company, which appoints Ms B (a Vietnamese citizen) as director. The company has not yet hired any staff.
- If Ms B receives a salary from Company Y — she participates in compulsory social and health insurance on the salary paid, like an employee, and Company Y pays the employer’s share.
- If Ms B receives no salary — she is an unsalaried manager, chooses her own contribution base and pays 29.5% as in Example 1.
In both cases, Company Y is not outside the scope of the review simply because it has “no employees yet”.
5. Points for foreign-invested companies
Many small FDI companies operate exactly as a “one-person enterprise”: a Vietnamese subsidiary with a single seconded director or a single legal representative. Points to note:
- Manager is a Vietnamese citizen — Point n (unsalaried) or the salaried-manager rules apply directly, as explained in Section 2.
- Manager is a foreign national — compulsory social insurance for foreign workers is governed separately by Clause 2, Article 2 of the 2024 Law and its implementing regulations, and depends on conditions such as the work permit and the form of engagement. These cases need a specific review; do not assume either way.
- Representative of an enterprise’s capital — this group is also listed in Point n, Clause 1, Article 2 of the 2024 Law where no salary is received.
6. What should companies do now?
- Identify who counts as an enterprise manager — owner, company chairman, director, capital representative — and whether each of them receives a salary.
- Check the current social and health insurance status of each manager and of the company. If not yet enrolled, contact the competent social security office to register and to clarify the start date of participation and any amounts payable.
- Choose a contribution base that matches the benefits sought (retirement, maternity, sickness). The chosen base must be kept for at least 12 months.
- Choose a payment cycle (monthly, 3 months or 6 months) and track the deadline.
- When the first employee is hired, enrol them in social and health insurance under the general rules rather than waiting for a review.
At the same time, the social security authority is also pushing compulsory social insurance for household business owners. That topic is outside the scope of this article.
Disclaimer
This article is based on:
- Official Letter No. 3603/BHXH-QLT dated 14 September 2026 of Vietnam Social Security on continuing to strengthen the management and collection of social and health insurance for “one-person enterprises”;
- Law on Social Insurance No. 41/2024/QH15 (Articles 2, 31 and 33);
- Decree No. 188/2025/NĐ-CP of the Government detailing and guiding certain articles of the Law on Health Insurance;
- The base salary of VND 2,530,000 per month applicable from 1 July 2026.
Three notes on scope:
- Official Letter 3603/BHXH-QLT is an internal directive from Vietnam Social Security to its provincial offices, not a legal normative document. The obligation to pay social and health insurance arises from the Law on Social Insurance, the Law on Health Insurance and their implementing regulations.
- The documents cited in the letter (Official Letters 1584/BHXH-QLT and 3411/BHXH-QLT, Circular 09/2026/TT-BTC, Decision 366/QĐ-BHXH and Notice 586/TB-BTC) are not analysed in detail in this article.
- The figures in the examples are illustrative only and use the reference level in force at the time of writing. Cases where the manager is a foreign national need a separate assessment.
This article is for reference only, does not replace the original legal text, and does not constitute advice for any specific case. Companies should check the regulations in force at the time of application and consult a qualified professional before making decisions.
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