On November 3, 2011, the Ministry of Labor and Social Affairs (MOL) issued Circular No 31/2011/TT-BLDTBXH implementing Government Decree Nos. 34/2008/ND-CP and 46/2011/ND-CP clarifying the MOLs position on certain foreign national hire scenarios. Circular No. 31 implements new labor reporting requirements for all Vietnamese companies sponsoring foreign workers. In addition, the circular clarifies the work permit requirements for commercial and NGO representative offices sponsoring foreign national representatives. The new requirements are scheduled to take effect on December 18, 2011.

On December 18, the MOL will require that all Vietnamese companies report the personal and work details of those foreign workers accepting new positions of employment, renewing immigration status or accepting transfer to another employer.

Circular 31 was also issued to clarify for regional labor offices an important distinction on the hiring of foreign nationals sponsored by Non-Governmental Office (NGO) representative offices and commercial representative offices. Any foreign national sponsored by a commercial representative office will be required to obtain a work permit. The only exemption available are for those foreign nationals assuming the Chief Representative role heading an NGO representative office located in Vietnam.