LEGAL UPDATES | Electronic Labor Contracts from July 1, 2026: What Businesses Need to Prepare Before Digital Transformation?

On May 15, 2026, the Ministry of Interior issued Circular No. 08/2026/TT-BNV guiding the implementation of certain provisions of Decree 337/2025/ND-CP on electronic labor contracts (E-Labour Contract). The Circular will officially take effect from July 1, 2026, establishing a unified management mechanism for the signing, storage, and exploitation of electronic labor contracts through the National Electronic Labor Contract Platform.

It is important to note that the use of electronic labor contracts is not mandatory. Businesses can still continue to sign paper contracts in accordance with the Labor Code. However, if they choose to adopt electronic contracts, businesses will have to comply with an entirely new management system related to identification codes, management platforms, access accounts, data storage, and information security.

1. Electronic labor contracts are not mandatory, but full compliance with procedures is required if adopted

Circular 08 does not compel all businesses to switch to electronic contracts.

Businesses can choose to:

• continue using paper contracts;
• fully switch to electronic contracts;
• or combine both forms simultaneously during different operational phases.

However, once electronic contracts are chosen, the entire process from signing, amending, terminating, storing, to exploiting data must be carried out according to the management mechanism of Circular 08 and the Electronic Labor Contract Platform.

OPLAW Insight: Businesses should not view electronic contracts merely as replacing handwritten signatures with digital signatures. This is a new labor data management model that requires coordination among HR, legal, and IT departments.

2. Each contract will have a unique identification code – the "legal passport" of the electronic contract

One of the important new points of the Circular is that each electronic labor contract will be assigned a unique identification code (ID) on the system.

What does the ID code mean?

The identification code will be used to:

• record the entire lifecycle of the contract;
• look up information;
• manage contract addenda;
• monitor amendments, suspensions, or terminations of contracts.

All documents generated during the execution of the contract will be linked to the same ID code instead of being managed separately as before.

ID code structure

The Circular stipulates that the ID code consists of 13 characters, where:

• the first character indicates the origin of the contract;
• the remaining 12 characters include the year of code issuance and a random sequence of numbers generated by the system.

Notably, electronic contracts not assigned an ID will not be recorded by the management system from July 1, 2026.

3. The ID issuance process will vary depending on the type of contract

The Circular divides this into three cases:

Case 1: New electronic contracts signed from July 1, 2026

The electronic contract service provider will send:

• contract content;
• transaction data;
• authentication information

to the Electronic Labor Contract Platform to be assigned an ID code.

Case 2: Converting paper contracts to electronic contracts

In addition to contract data, businesses must have a conversion log, digital signature, and timestamp to ensure data integrity.

Case 3: Electronic contracts signed before July 1, 2026

Businesses need to review and supplement technical elements such as digital signatures, timestamps, and data authentication before submitting them to the system for ID assignment.

4. Businesses need to pay special attention when choosing service providers

The Circular includes many provisions for electronic contract platform providers (eContract Providers).

This unit is responsible for:

• connecting with the Electronic Labor Contract Platform;
• submitting data for ID assignment;
• ensuring data integrity;
• supporting data conversion when businesses change systems.

The Circular also stipulates cases where providers may be temporarily suspended or terminated from connection, for example:

• failure to maintain technical conditions;
• violating security requirements;
• having 5% or more of contracts rejected for ID assignment in a month.

OPLAW recommends: When signing contracts with service providers, businesses should clearly define:

• incident handling mechanisms;
• responsibility for supporting re-issuance or supplementary ID issuance;
• data transfer plans upon service termination;
• liability for compensation in case of system interruption causing damage.

5. Access accounts and data will be centrally managed

The Circular stipulates that both businesses and employees will have access accounts on the Electronic Labor Contract Platform.

For businesses:

• login is performed through the organization's electronic identification account (VNeID);
• businesses need to decentralize user permissions and manage internal accounts.

For employees:

• electronic contracts can be looked up through individual electronic identification accounts for administrative procedures or electronic transactions.

6. Contract data must be stored for a minimum of 10 years

Another notable point is the data retention period.

According to the Circular:

• contracts;
• contract addenda;
• related documents

must be retained for 10 years from the date of termination of the labor contract.

If an employee signs multiple consecutive contracts with the same business, this period is calculated from the date of termination of the last contract.

This requires businesses to establish a long-term, secure data storage mechanism with the ability to retrieve data when needed.

7. Personal data protection will become a key requirement

Electronic labor contracts contain much important personal information of employees such as identification information, salary levels, job titles, contract terms, and data related to the working process.

Therefore, businesses need to simultaneously review:

• personal data processing notices;
• access authorization mechanisms;
• information security measures;
• data processing agreements with electronic contract service providers.

OPLAW Insight

Circular 08/2026/TT-BNV not only provides guidance on how to sign electronic labor contracts but also establishes a

Frequently Asked Questions

What should readers know about LEGAL UPDATES | Electronic Labor Contracts from July 1, 2026: What Businesses Need to Prepare Before Digital Transformation??

On May 15, 2026, the Ministry of Interior issued Circular No. 08/2026/TT-BNV guiding the implementation of certain provisions of Decree 337/2025/ND-CP on electronic labor contracts (E-Labour Contract).

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