What Are the Fines for Working at the Wrong Location on Your Vietnam Work Permit?
Working at a location that does not match the address registered on your Vietnam work permit is a direct violation of Vietnamese labor law and carries penalties equivalent to working without a work permit at all. Under Decree 12/2022/ND-CP, the foreign worker faces a fine of VND 15 to 25 million plus mandatory deportation under Clauses 3 and 5, Article 32. When the employer is the party directing the unauthorized placement, that employer faces an additional independent fine of VND 30 to 75 million scaled by worker count under Clause 4, Article 32, doubled for organizational employers under Clause 1, Article 6. Both penalties apply simultaneously and neither party’s liability reduces the other’s.
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What Counts as Working at the Wrong Location Under Vietnam’s Work Permit Law?
A wrong-location violation occurs when a foreign teacher performs paid work at a physical address that is not the employer and location registered on their issued work permit. A Vietnam work permit specifies three binding conditions: the named employer, the registered work address, and a validity period of up to two years under Decree 219/2025/ND-CP. A permit that is still within its validity dates does not authorize work at any address other than the one listed. Working at a different address, even for a single class, means the teacher is operating at that location without a valid work permit.
According to Le Tran Law’s 2025 work permit violations guide, “performing duties not aligned with the job title or location stated in the permit” is classified as a work permit violation under Vietnamese labor regulations, with the same penalty framework applying as for operating with no permit at all.
Common wrong-location scenarios in the education sector:
- Teaching at a different school not listed on the permit, whether the teacher arranged this independently or was sent there by their employer
- Teaching at a branch or partner site of the same employer where that address is not included in the work permit registration
- Freelancing at a second school outside the teacher’s registered employer, either openly or informally, while holding a permit that only covers the primary school
Teaching at a different school means the work permit covering School A creates no authorization for School B, even if the same person owns or manages both. Under Decree 219/2025/ND-CP, each employer entity with a distinct business registration number is a separate employer for work permit purposes. The work permit does not travel with the teacher to a new address.
Teaching at an unregistered branch or partner site is a common scenario in language center chains and school franchise groups. An employer who operates multiple locations must ensure each location where a foreign teacher is placed is covered in the permit registration. Placing a teacher at a site not covered by their permit is a violation on the employer’s side, regardless of whether the teacher knew about the registration gap.
Freelancing at a second school is the scenario where the teacher independently arranges extra work outside their registered employer. The teacher is personally liable for this unauthorized work. The school that takes on the teacher without verifying their permit coverage also faces independent liability.
What Are the Fines for a Foreign Worker Who Works Outside Their Permitted Location?
A foreign teacher who works at a location not covered by their work permit faces a principal fine of VND 15 to 25 million and mandatory deportation as a supplementary penalty under Clauses 3 and 5, Article 32 of Decree 12/2022/ND-CP. These penalties apply whether the teacher independently chose the unauthorized location or was directed there by their employer. Vietnamese administrative law does not reduce individual fines based on an employer’s instruction.
According to DNP Viet Nam Law Firm’s 2025 legal analysis of Decree 12/2022/ND-CP, the VND 15 to 25 million penalty applies to any foreign employee “engaging in employment without a valid work permit,” which includes working at a location for which no valid permit exists. Payment of the fine does not retroactively authorize the work performed or prevent deportation from proceeding.
Penalties for the individual foreign worker:
- VND 15 to 25 million principal fine: assessed per violation, issued through DoLISA or the Provincial People’s Committee under Clause 3, Article 32 of Decree 12/2022/ND-CP
- Mandatory deportation: supplementary penalty required under Clause 5, Article 32 of Decree 12/2022/ND-CP, cannot be waived once the violation is confirmed
- Temporary Residence Card cancellation: follows automatically when the underlying work permit is revoked, removing the legal basis for continued residency
- Re-entry restriction: a ban on re-entering Vietnam may be imposed following deportation for an employment violation, with duration determined under Vietnam’s immigration law
VND 15 to 25 million is the individual-rate penalty. Under Clause 3, Article 32 of Decree 12/2022/ND-CP, this range covers all cases of working without a valid permit for the actual location, including wrong-location violations.
Mandatory deportation under Clause 5, Article 32 of Decree 12/2022/ND-CP is a supplementary penalty that authorities cannot waive after confirming the violation. According to Tân Văn Lang’s 2026 work permit penalties guide, deportation proceedings are coordinated between the Vietnam Immigration Department and DoLISA following confirmation.
TRC cancellation follows because the TRC is tied to the employment status verified by the work permit. Under Article 32.1 of Decree 219/2025/ND-CP, a work permit is revoked when working outside the authorized scope is confirmed. According to Tân Văn Lang’s 2026 guide, the TRC becomes legally void at revocation without a grace period.
Re-entry restriction affects the teacher’s ability to re-enter Vietnam and apply for future work permits. The specific duration is determined under Vietnam’s immigration law on a case-by-case basis.
For a full breakdown of how Vietnam’s no-permit penalty framework applies across all violation types, see Working Without a Work Permit in Vietnam: Fines and How to Avoid Them.
What Penalties Apply When an Employer Assigns a Teacher to an Unauthorized Location?
An employer who assigns a foreign teacher to work at a location not covered by that teacher’s work permit faces scaled fines of VND 30 to 75 million under Clause 4, Article 32 of Decree 12/2022/ND-CP, based on the number of workers affected. Organizations and company-structure employers pay double the individual rate under Clause 1, Article 6 of the same decree, bringing the effective organizational fine range to VND 60 to 150 million at the upper end.
According to Le Tran Law’s 2025 work permit violations guide, deploying a foreign worker to an address not covered by their permit is treated as equivalent to employing that worker without a valid permit for that site. Vietnamese labor law places primary compliance responsibility on the employer, and the scale-based penalty structure applies whether the unauthorized placement was deliberate or the result of an administrative oversight.
Employer fine tiers under Clause 4, Article 32 of Decree 12/2022/ND-CP:
| Workers at Unauthorized Location | Fine for Individual Employers | Fine for Organizations (Double Rate) |
|---|---|---|
| 1 to 10 workers | VND 30 to 45 million | VND 60 to 90 million |
| 11 to 20 workers | VND 45 to 60 million | VND 90 to 120 million |
| 21 or more workers | VND 60 to 75 million | VND 120 to 150 million |
1 to 10 workers is the most common bracket for language centers or small schools assigning one or two teachers to partner or franchise sites. An organization-structure employer in this bracket faces VND 60 to 90 million per DoLISA inspection decision, in addition to whatever penalty the individual teacher faces independently.
11 to 20 workers applies to school groups assigning multiple teachers across unregistered branches. Organization penalties in this tier reach VND 90 to 120 million per inspection cycle, assessed per confirmed violation.
21 or more workers triggers the maximum bracket at VND 120 to 150 million for organizations. Tân Văn Lang’s 2026 work permit penalties guide documents that repeat violations at any scale bring additional consequences beyond fines: suspension of foreign worker hiring approvals, mandatory repatriation of affected workers at the employer’s cost, and increased frequency of future DoLISA inspections.
What Is the Legal Difference When a Worker Chooses the Wrong Location Versus When an Employer Directs It?
The key legal difference between the two scenarios is who shares liability with the worker. When a worker independently works at an unauthorized location, only the worker and the employer at that unauthorized site face penalties. When the worker’s employer directs the unauthorized placement, both the directing employer and the worker face simultaneous, independent penalties under Decree 12/2022/ND-CP. In both scenarios, the individual worker faces the same VND 15 to 25 million fine and mandatory deportation. An employer’s instruction provides no legal defense for the worker.
According to Le Tran Law’s 2025 work permit violations guide, Vietnamese labor law applies penalty provisions based on the objective act of working at an unauthorized location, not on intent or on who initiated the arrangement. Both Clause 3 and Clause 4 of Article 32, Decree 12/2022/ND-CP operate independently, meaning an employer and worker are each assessed separately without either assessment reducing the other.
How liability is distributed in each scenario:
| Factor | Worker Independently Works at Wrong Location | Employer Directs Worker to Wrong Location |
|---|---|---|
| Worker’s fine | VND 15 to 25 million plus deportation | VND 15 to 25 million plus deportation |
| Directing or original employer’s liability | Not liable for the unauthorized location | VND 30 to 75 million, doubled for organizations |
| Unauthorized site employer’s liability | VND 30 to 75 million if they engaged the teacher | Not applicable |
| Worker’s defense via employer instruction | Not recognized under Decree 12/2022/ND-CP | Not recognized under Decree 12/2022/ND-CP |
Scenario 1: Worker independently works at wrong location. A teacher who arranges private classes or informal work at a second school outside their registered employer is personally liable under Clause 3, Article 32 of Decree 12/2022/ND-CP. The original permitted employer bears no liability for this unauthorized activity since they are not the party “using” the worker at the second location. The school that takes on the teacher, however, is “using a foreign employee without a valid work permit” for that site and faces the employer-tier penalty under Clause 4.
Scenario 2: Employer directs worker to wrong location. When an employer assigns a teacher to a location not covered by the teacher’s permit, both parties face simultaneous and independent penalties. The worker cannot use the employer’s instruction as a defense under Decree 12/2022/ND-CP. Clause 3 and Clause 4 of Article 32 operate in parallel: the teacher is fined as the individual who performed unauthorized work, and the employer is fined as the entity that directed and facilitated it.
The practical implication of this distinction for foreign teachers is significant. A teacher who is sent to a different school by their employer may believe compliance is the employer’s responsibility. Under Vietnamese administrative law, that assumption is incorrect. The teacher’s personal liability under Clause 3 is assessed regardless of whether the employer issued the instruction, arranged the schedule, or processed the payment. The only protection available to the teacher is to verify that their permit covers the location before teaching there, and to refuse any assignment that cannot be confirmed in writing.
How Do Labor Authorities in Vietnam Detect Wrong-Location Violations?
Vietnamese labor authorities detect wrong-location violations primarily through unannounced on-site inspections at physical teaching premises, supported by cross-referencing between permit records and operational addresses. According to Tân Văn Lang’s 2026 work permit penalties guide, enforcement by the labor inspectorate has become “increasingly standardized nationwide since 2023,” with inspectors verifying actual work locations rather than relying on administrative filings alone.
Detection channels currently in operation:
- Unannounced DoLISA on-site inspections: Inspectors arrive at the physical teaching location and require every teacher present to show a work permit listing that specific registered address. A permit naming a different school fails this check immediately.
- Integrated permit and police database: Under Article 4 of Decree 219/2025/ND-CP, Provincial People’s Committees coordinate directly with police departments during the permit application process, creating cross-linked records that can surface discrepancies between registered addresses and known operational sites.
- Unified foreign worker database: Under Article 36.3 of Decree 219/2025/ND-CP, the Ministry of Home Affairs is building a national database linked to the entry-exit system, enabling real-time multi-province work location tracking.
- Third-party complaints: Disputes between competing schools, former employees, or subcontractors can result in regulatory complaints filed directly with DoLISA, triggering targeted inspections at specific premises.
Unannounced on-site inspections are the primary detection mechanism in practice. A language center, private school, or tutoring center can be inspected without advance notice, and any teacher who cannot produce a work permit listing that premises address is in an immediately confirmable violation.
Third-party complaints are a significant detection channel in Vietnam’s education sector specifically, where commercial disputes between school chains, franchise operators, and subcontracted language centers have led to regulatory referrals that produced enforcement action at specific sites.
What Compliance Steps Prevent Wrong-Location Fines?
Preventing wrong-location fines requires verifying the exact address on the work permit against every site where classes are scheduled before teaching begins, refusing any assignment that cannot be confirmed in writing as covered by the current permit, and filing new permit applications 10 to 60 days before any location or employer change under Decree 219/2025/ND-CP. A work permit that is valid within its issued date range still provides zero authorization at any address it does not list.
According to Le Tran Law’s 2025 HR compliance guide, employers reduce violation risk by aligning the location listed in the permit with the employee’s actual placement, maintaining accurate and current personnel records, and reporting changes in employment status to DoLISA without delay.
Compliance actions for foreign teachers:
- Verify information: Check the exact address on your work permit against every site in your teaching schedule before any class
- Request documentation in writing: If an employer directs you to a new location, ask for written confirmation that your current permit covers that address or that a new permit is already in process
- Refuse unconfirmed assignments: Do not teach at any site your employer cannot confirm in writing as covered. The individual fine falls on you, not the employer.
- Update permits proactively: Apply for the new permit before any location change takes effect and do not begin teaching until it is physically received
- Keep records: Carry a copy of your current work permit to every teaching site for on-demand inspection
Compliance actions for employers and HR teams:
- Verify information: Cross-reference each teacher’s permit address against the actual teaching location before scheduling any assignment
- Proactive reporting: Submit new permit applications to the Provincial People’s Committee 10 to 60 days before placing any teacher at a location outside their current permit scope under Decree 219/2025/ND-CP, rather than waiting for an inspection to surface the gap
- Update permits proactively: Obtain a new or reissued permit before any unauthorized placement occurs, not after
- Keep records: Maintain an internal record for each teacher showing permitted work address, employer entity, job position, and permit expiry date
- Audit commercial arrangements: Review all partnership, franchise, and subcontractor agreements to confirm no commercial deal results in teachers being placed at unregistered sites
Verifying information is the non-negotiable first step for teachers. A work permit lists the employer’s registered address as the authorized work location. No commercial relationship between schools, no verbal instruction, and no informal arrangement changes this.
Proactive reporting by employers means filing applications and notifications before a location change is made, not after. Under Decree 219/2025/ND-CP, the 10 to 60 day application window exists specifically to enable this approach.
Keeping records allows both teachers and HR teams to demonstrate compliance during an unannounced DoLISA inspection. Every teacher should be able to produce their work permit on demand at any site where they are teaching.
For how Vietnam’s deportation framework applies to foreign nationals following employment violations, see Decree 59/2026/NĐ-CP: What Are Vietnam’s 12 New Deportation Rules for Foreign Nationals?
What Should You Do If a Wrong-Location Violation Has Already Occurred?
If a wrong-location violation is confirmed, whether through a DoLISA inspection, a self-review, or an employer notification, the immediate priority is to stop work at the unauthorized location and preserve all relevant employment documents. Under Decree 12/2022/ND-CP, fines of VND 15 to 25 million for the worker and VND 30 to 75 million for the employer apply from the point of confirmed violation. Cooperating with labor inspectors is the required procedural response under Vietnam’s Law on Handling of Administrative Violations and does not eliminate the penalty.
According to Le Tran Law’s 2025 compliance guidance, cooperation with DoLISA and transparent documentation of the employment relationship are standard expectations during labor inspections. Misrepresenting or withholding information during an administrative inspection creates additional liability.
Immediate steps when a wrong-location violation is confirmed:
- Stop work at the unauthorized location immediately: Continuing after the violation is identified does not reduce the fine already incurred and may compound the administrative record
- Preserve all employment documents: Labor contracts, work permit copies, teaching schedules, and all employer communications are material to the administrative assessment
- Consult a Vietnamese labor law attorney: Penalty determination and available procedural options are governed by Vietnam’s Law on Handling of Administrative Violations; legal representation is permitted throughout the process
- Cooperate fully with DoLISA: Transparent conduct during the inspection is the required response under Vietnamese administrative law
- Begin the correct permit application without delay: For continued legal employment, the employer should file the correct permit application for the intended location using the 10 to 60 day window under Decree 219/2025/ND-CP
Stopping work at the unauthorized location removes ongoing exposure. Continuing after identification does not reduce the assessed fine but creates grounds for continued enforcement action.
Consulting a Vietnamese labor law attorney is particularly important for assessing whether the specific situation falls under Article 32 of Decree 12/2022/ND-CP or a lesser provision, and for understanding any procedural options under Vietnam’s administrative review framework.
Beginning the correct permit application ensures the fastest path back to legal employment. Under Decree 219/2025/ND-CP, a complete application is processed within 10 working days from receipt.
Frequently Asked Questions
Is working at the wrong location treated the same as working with no work permit at all?
Under Vietnamese labor law, a work permit authorizes employment only at the specific employer and location stated on the document. Working at a different address means no valid authorization exists for that site. Clauses 3 and 5, Article 32 of Decree 12/2022/ND-CP apply in full: VND 15 to 25 million and mandatory deportation for the teacher, regardless of whether they hold a valid permit for a different location.
If the employer directs the wrong placement, does the teacher still face personal fines?
Yes. Clause 3, Article 32 of Decree 12/2022/ND-CP imposes individual liability on the foreign worker for the act of working at an unauthorized location, regardless of who issued the instruction. An employer’s direction provides no legal defense under Vietnamese administrative law. The teacher faces VND 15 to 25 million and mandatory deportation personally, while the employer faces a separate and independent penalty under Clause 4 of the same article.
Does the employer face additional liability specifically for giving the instruction?
Yes. Under Clause 4, Article 32 of Decree 12/2022/ND-CP, an employer who “uses” a foreign worker at an unauthorized location faces VND 30 to 75 million scaled by the number of workers, doubled for organizations under Clause 1, Article 6. This is assessed independently from the worker’s fine. Both penalties apply simultaneously under Decree 12/2022, and neither payment reduces the other party’s liability.
What is different if the teacher moonlights at a second school without the employer knowing?
In this scenario, the teacher is personally liable under Clause 3, Article 32 for working at an unauthorized location. The original permitted employer is not liable for that specific unauthorized work because they are not “using” the worker at the second school. However, the second school that engaged the teacher without verifying permit coverage faces the employer-tier penalty under Clause 4, Article 32, since it is the entity using a foreign worker without a valid permit for that site.
How long does it take to get a work permit covering a new location?
Under Decree 219/2025/ND-CP, the competent authority processes a complete application within 10 working days from receipt, integrated from the previous combined process of 15 working days for demand approval plus 5 working days for the permit. The application must be filed 10 to 60 days before the intended start date. No teaching at the new location is authorized until the permit is physically issued.
Does holding a valid work permit for one school protect a teacher who also teaches elsewhere?
No. A work permit’s validity period only means the document has not expired for the employer and location it names. It creates no authorization at any other address. Teaching at a second school while holding a valid permit for the first school is a wrong-location violation at the second school, regardless of the permit’s validity dates.
What happens to the Temporary Residence Card if a work permit is revoked for a location violation?
Once the underlying work permit is revoked, the TRC linked to that employment becomes legally void. According to Tân Văn Lang’s 2026 work permit penalties guide, TRC cancellation is enforced by immigration authorities without a grace period following work permit revocation. The foreign worker must exit Vietnam and complete a full compliance process before applying for new documentation.
Stay current with Vietnam’s work permit regulations, immigration enforcement updates, and legal changes affecting foreign teachers and education professionals. Browse the full Updates and Long-Term Planning category for comprehensive regulatory guides and compliance resources.
