What is a Sub-License? Detailed Application and Procedures for Obtaining a Sub-License in 2025.

A sub-license is an additional license that a business or individual needs to operate in certain conditional business sectors as regulated by Vietnamese law. Apart from the business registration certificate, the sub-license plays a crucial role in ensuring that the business meets the required standards for safety, hygiene, environmental protection, and professional expertise as stipulated by regulatory authorities.

What is a Sub-license?

A sub-license refers to licenses, certificates, or approval documents issued by competent state authorities to allow individuals or organizations to operate in a conditional business sector.

According to the 2020 Investment Law (effective from January 1, 2021), the list of conditional business sectors is outlined in Appendix IV. If a business operates in these sectors, apart from the business registration certificate (BRC), they must apply for additional sub-licenses to meet legal business requirements.

Characteristics of Sub-licens

Sub-licenses have several important characteristics:

They are documents issued by competent state authorities, which may vary depending on the specific sector. These licenses are granted only after a business has obtained a business registration certificate.
A sub-license is mandatory for businesses operating in conditional sectors.
Each sector has specific requirements and standards to obtain a sub-license.
Most sub-licenses are valid for a fixed period, and businesses must renew or reapply to continue legal operations.
Sub-licenses can exist in various forms such as permits, certificates, or approval letters from regulatory authorities.

Important Notes

Conditional business sectors are those that may directly affect issues like national security, public order, social ethics, and public health. Therefore, the law stipulates that businesses must meet certain conditions before being allowed to operate.

Businesses can refer to the detailed list of conditional business sectors in Appendix IV of the 2020 Investment Law.

When Is a Sub-license Required?

Obtaining a sub-license is mandatory when a business operates in conditional industries according to legal regulations. Some common sectors requiring sub-licenses include:

Food and medicine: Food safety certification, medical practice licenses
Education, real estate brokerage
Finance and insurance sectors: Securities company operating licenses, insurance licenses
Education: Education operation permits, foreign language center establishment licenses
Construction and real estate: Construction competence certificates, real estate permits
Information technology: Social network establishment licenses, telecommunications service provision licenses
Other specialized industries: Transportation business licenses, public security licenses, fire safety permits

Documents Required for Sub-license Application

Each conditional sector has specific documentation requirements. However, generally, the documents for applying for a sub-license include the following:

Basic Legal Documents:
- Business registration certificate (notarized copy)
- Identity card/passport/citizen ID of the legal representative (copy)
- Business location lease contract (if required)
- Floor plan, documents proving the location meets regulatory requirements
Industry-Specific Documents:
- Personnel: Professional certificates, degrees of key personnel or business leaders
- Facility Conditions: Fire safety certificates, labor safety, environmental hygiene certificates
- Financial Documents: Confirmation of charter capital, required legal capital (if applicable)
- Compliance Commitment Documents: Food safety, environmental protection, etc.

Procedures for Obtaining a Sub-license in 2025

The procedures for obtaining a sub-license vary by sector but generally follow these steps:

Prepare Documents:

- Businesses prepare the necessary documents based on the requirements for each specific license. It may be necessary to refer to regulations in decrees and circulars for each specific sector.

Submit Documents:

- Businesses submit the documents to the relevant authority: ministries, departments, or specialized agencies (e.g., Ministry of Health, Ministry of Construction, Food Safety Agency…).
- Submission methods: Direct submission, postal submission, or online service portals (if supported).

Authority Reviews the Documents:

- The receiving authority will review the validity of the documents.
- If the documents are incomplete, the business will be required to supplement or correct them.
- The authority may conduct an inspection at the business location (for some industries).

Receive Sub-license:

- If the documents are valid and meet the required conditions, the business will be issued the sub-license.
- If the application is rejected, the authority will issue a written explanation for the refusal.

Publish Information and Comply with Regulations:

- Some licenses require businesses to publish information after receiving the permit.
- Businesses must comply with renewal or reissuance regulations if the license expires.

Important Notes When Applying for a Sub-license

When applying for a sub-license, businesses should pay attention to several important factors to ensure the process goes smoothly and complies with legal requirements:

Understand Legal Requirements and Regulations:
- Each type of sub-license has its own specific legal requirements and procedures as outlined in laws such as the Investment Law, the Enterprise Law, and various decrees and circulars from relevant ministries. Businesses should thoroughly understand these regulations to ensure they follow the proper steps.
Prepare Accurate and Complete Documents:
- Sub-license applications typically require numerous legal documents, such as the business registration certificate, labor contracts, financial reports, and documents proving the business’s compliance with specific conditions. Proper preparation of these documents is crucial for fast approval.
Meet Specific Conditions for Each License:
- Sub-licenses often have specific requirements regarding infrastructure, management systems, labor safety, environmental standards, or product quality. Before applying, businesses should verify that they meet all these conditions to avoid delays in the approval process.
Control Timeline and Document Processing Time:
- The process for obtaining a sub-license can take several weeks or even months. Businesses need to proactively monitor the progress of their applications and have contingency plans in case of delays.
Comply with Reporting and Inspection Regulations After License Issuance:
- After receiving a sub-license, businesses need to fulfill regular reporting obligations or undergo inspections from competent authorities. Failure to comply with these regulations could result in the license being revoked or administrative penalties.

Sub-license Service Process at BKC Law

BKC Law provides professional services to help businesses and organizations obtain the necessary sub-licenses for legal operation in regulated sectors. The process is structured, efficient, and ensures full compliance with current legal requirements.

Initial Legal Consultation:
- BKC Law begins the service process by offering free consultations on the types of sub-licenses required based on the client’s business area and specific legal requirements. This consultation helps clients understand the necessary steps, conditions, and associated costs.
Drafting and Preparing Documents:
- Based on the collected information, BKC Law’s legal team will draft the sub-license application documents. The documents will be prepared accurately and comprehensively, including legal documents such as the business registration certificate, contracts, meeting minutes, and other relevant papers depending on the license type.
Submitting Documents and Tracking Progress:
- Once the documents are complete, BKC Law will submit the sub-license application on behalf of the client to the relevant authorities. We will monitor the entire approval process, resolve any issues that arise, and respond to requests for additional documents to ensure timely issuance of the license.
Receiving Results and Delivering License:
- When the sub-license is granted, BKC Law will notify the client and hand over the license or related documents. We ensure that the client receives the license on time, fully compliant and legal.
Post-License Support:
- After the client receives the sub-license, BKC Law continues to provide support for related administrative procedures, such as license renewal, information changes, or fulfilling legal obligations during business operations. We are committed to assisting clients in maintaining legal compliance throughout their business activities.