Foreign Investor Guide: Opening a Polyclinic in Vietnam

Private polyclinics are being opened increasingly to meet the healthcare demands of the population, especially as public hospitals remain overloaded. In recent years, polyclinic models with foreign capital have begun to emerge in major urban centers, contributing to healthy competition, improving healthcare service quality, and diversifying options for patients. However, to officially operate a polyclinic in Vietnam, foreign investors must comply with a strict legal framework, including regulations on investment conditions, operation licenses, professional standards, and medical personnel. Below is an overview provided by Viet An Law regarding the Foreign Investor Guide: Opening a Polyclinic in Vietnam.

Investment conditions

• WTO, FTAs, AFAS: Unrestricted, except for the minimum investment capital of USD 2 million.
• Vietnamese law: Does not stipulate specific investment conditions applicable to foreign investors.

Foreign Investor Guide: Opening a Polyclinic in Vietnam

To open a polyclinic, foreign investors must first obtain an Investment Registration Certificate by Clause 1, Article 22 of the Law on Investment 2020, and carry out business registration procedures as prescribed.

According to Articles 40 and 42 of Decree No. 96/2023/NĐ-CP, the conditions for obtaining an operating license for a polyclinic are as follows:

Scale

• A polyclinic must have at least three medical specialties, of which at least two must be among internal medicine, surgery, obstetrics, and pediatrics. In addition, the facility must be equipped with paraclinical support departments, including laboratory and diagnostic imaging.
• The clinic must also have an emergency room for urgent situations, a minor surgery room (if minor procedures are performed), and a patient observation area for post-treatment monitoring. If the clinic is built by one of the medical examination and treatment models specified in Article 39 of Decree 96/2023/NĐ-CP, it may be considered for an expanded scope of specialization according to that model.

Facilities

The clinic must operate at a fixed location and meet legal requirements regarding:

• Structural safety, fire prevention, and fighting;
• Infection control, environmental hygiene, and radiation safety (if radiation equipment is used);
• Stable power and water systems with sufficient capacity for operations.

In addition, the clinic must have signage, guidance diagrams, and nameplates clearly indicating the administrative and professional areas. In case of opening a branch or facility not located within the same premises, it must meet the standards applicable to healthcare establishments as per regulations.

Functional area sizes

• Emergency room: minimum 12m²;
• Patient observation room: minimum 15m² with at least 2 beds; for 3 beds or more, each bed must have a minimum of 5m²;
• Specialty clinic room: minimum 10m²;
• Procedure/technical room: at least 10m² for procedures, 20m² for physical therapy techniques.

If reusing medical equipment, the clinic must have a sterilization area or a contract with a licensed medical facility for instrument processing.

If the clinic processes or prepares traditional medicine, it must comply with the relevant technical regulations issued by the Ministry of Health.

Medical equipment

Depending on the registered scope of specialties and techniques, the clinic must be equipped with compatible medical equipment. It must also have emergency drugs and anti-shock equipment meeting regulatory standards to ensure patient safety in emergencies.

Conditions on personnel and professional practice

• Practicing personnel
  • The facility must have sufficient staff practicing within the registered scale and specialties. The minimum practitioner-to-patient ratio as required by the Ministry of Health must be maintained, including practitioners formerly in the armed forces who now practice in civilian medical facilities, provided their licenses remain valid.
• Person in charge of technical expertise
  • This person must work full-time at the clinic and hold a practicing certificate appropriate to the clinic’s field of operation.
  • They must have at least 36 months of experience in the relevant field, except for traditional medicine practitioners or those with recognized proprietary remedies.
  • If the clinic has multiple specialties, the technical manager must have a valid practicing certificate in at least one of those specialties.
• Heads of specialties
  • Each specialty must have a designated person in charge, with a valid practicing certificate, working full-time at the clinic.
  • All medical staff must be assigned duties by their approved practicing scope.
• Regulations for laboratory and imaging technicians
  • Technicians with a university degree in laboratory sciences may sign and validate test results. If no qualified technician is available, the requesting physician will sign the results.
  • Similarly, imaging technicians with a university degree in medical imaging may interpret and describe diagnostic imaging results; in their absence, the requesting physician is responsible for interpreting and signing the results.
• Personnel not requiring a practicing certificate
  • Personnel not directly involved in treatment but supporting technically—such as medical physicists, biotechnology engineers, radiotherapy engineers, etc.—may participate in professional activities if assigned tasks appropriate to their qualifications and competencies by the technical director.
  • In addition, medical faculty members working at training institutions may also assume technical leadership roles at the clinic if concurrently working at the practice facilit

Other specific conditions

• The clinic must be adequately equipped in terms of infrastructure, staff, medical devices, and procedures to conduct general health checks or driver’s health assessments in accordance with Ministry of Health standards.
• Data from driver’s health examination certificates must be connected to the national health examination and treatment management system or other interoperable medical databases approved by the government.

Investment procedures

Opening a foreign-invested company (100% foreign-owned or joint venture with a Vietnamese partner)

Case 1: Joint venture with a Vietnamese partner

• Step 1: Open a Vietnamese-invested company registering a polyclinic operation. The establishment period ranges from 6–8 working days and includes business registration certificate issuance, company seal engraving, and notification of seal specimen.
• Step 2: Apply for the operating license for the polyclinic.
• Step 3: Transfer the contributed capital portion to the foreign investor.

Case 2: Open a 100% foreign-owned company

• Step 1: Apply for the Investment Registration Certificate at the investment registration authority.
• Step 2: After obtaining the Investment Registration Certificate, the investor opens a company and applies for a Business Registration Certificate at the business registration authority;
• Step 3: After completing the company establishment procedure, the investor submits a dossier for the polyclinic’s operating license.

The above is Viet An Law’s consultation on Foreign Investor Guide: Opening a Polyclinic in Vietnam. Please contact Viet An Law for more specific and detailed advice. Should you have any related questions or require further consultation on company establishment procedures, please contact Viet An Law for the best advice and support!