For Canadian dental investors who have successfully established a first clinic in Vietnam, expansion to multiple locations represents the next growth horizon. Vietnam’s large population, underpenetrated dental care market, and growing middle class make multi-location dental chains an attractive proposition. However, each additional clinic location requires a separate healthcare operating license, a separately credentialed responsible clinical director, and independent compliance with all facility standards under Decree 96/2023/ND-CP.
This guide provides the legal roadmap for Canadian dental investors planning multi-location expansion in Vietnam.
Each Clinic Location Requires Its Own Operating License
The most important principle for multi-location expansion is that there is no ‘chain license’ in Vietnam. Each healthcare facility—even within the same company—requires an individual healthcare operating license (giay phep hoat dong) from the relevant provincial Department of Health.
For Canadian dental investors expanding within the same city (e.g., opening a second clinic in Ho Chi Minh City), both clinics are under the jurisdiction of the HCMC Department of Health, but each requires a separate license application, separate facility inspection, and separate license issuance.
For inter-provincial expansion (e.g., opening in both HCMC and Da Nang), two different provincial Departments of Health are involved, and separate applications must be filed with each.
Responsible Clinical Director Requirements Per Location
Each clinic location must appoint a responsible clinical director (nguoi chiu trach nhiem chuyen mon ky thuat) who:
Holds a valid Vietnamese dental practice license covering the relevant scope;
Has at least 54 months of post-graduation clinical practice experience;
Is physically present at the clinic during operating hours;
May serve as responsible director at a maximum of one additional facility (i.e., one person can cover at most two locations).
For Canadian investors expanding to three or more locations, this means at least two qualified responsible directors are needed. Recruiting, credentialing, and retaining qualified Vietnamese dental directors is often the most critical bottleneck in multi-location expansion.
Corporate Structure for Multi-Location Operations
Canadian investors with multiple dental clinic locations in Vietnam typically use one of two corporate structures:
1. Single entity, multiple locations: The same foreign-invested LLC holds the operating licenses for all clinic locations. This is simpler from a corporate governance perspective but concentrates all regulatory risk in a single entity. 2. Holding company with subsidiary entities: A Vietnamese holding company (or the foreign parent) owns multiple subsidiary LLCs, each holding its own operating license. This structure provides liability isolation between locations and can be more flexible for future M&A activity.
The choice of structure has implications for tax reporting (consolidated vs. separate entity filings), labor law compliance (each entity has separate employment and social insurance obligations), and regulatory reporting requirements.
Expansion Licensing Timeline
For each new location, Canadian investors should plan the following timeline:
Location selection and lease negotiation: 1–3 months;
Facility construction/fit-out to meet Decree 96/2023/ND-CP standards: 2–4 months;
Supporting permits (fire safety, radiation if applicable): 1–2 months after construction;
Responsible director credentialing (if a new director is being onboarded): 6–12 months (parallel to construction);
Operating license application and review: 2–4 months;
Total per additional location: approximately 9–15 months.
Experienced Canadian dental investors who have been through the first licensing process can streamline subsequent applications by reusing standard documentation templates and maintaining established relationships with the relevant Department of Health.
Staffing Compliance for Multiple Clinics
Each clinic location requires independent compliance with labor law, social insurance enrollment, and staffing standards:
Each clinic must maintain a current list of all licensed practitioners registered at that facility (Form No. 01 of Decree 96/2023/ND-CP), updated whenever staff changes occur.
Foreign staff at each location require individual work permits specifying the location of employment. A Canadian dentist with a work permit for one clinic cannot practice at a second clinic without a work permit amendment specifying that location.
Social insurance enrollment and contribution obligations are separate for each employing entity if the multi-location structure uses separate companies.
Brand and Quality Consistency Across Locations
From a regulatory perspective, Vietnamese law does not restrict Canadian investors from implementing consistent branding, clinical protocols, and quality standards across multiple clinic locations. However, maintaining brand consistency requires:
Standardized operating procedures (SOPs) adapted to Vietnamese regulatory requirements (in particular, infection control protocols consistent with Decision 5991/QD-BYT);
Regular internal clinical audits and quality assurance reviews;
Training programs for all clinical staff at each location;
A central compliance function monitoring license validity, permit renewals, and regulatory changes across all locations.
Canadian dental investors who treat each location as an independent compliance unit (rather than relying on a centralized compliance function) tend to encounter fewer regulatory issues during MOH inspections.
Conclusion
Multi-location expansion for Canadian dental investors in Vietnam is a legally structured but achievable growth strategy. The per-location operating license requirement, responsible director staffing constraints, and independent compliance obligations are the primary planning challenges. TTVN Legal provides multi-location expansion legal support for Canadian dental investors, from corporate structure design through to operating license approval for each new clinic.
Need expert legal support for healthcare investment in Vietnam? TTVN Legal | 101 Nguyen Van Thu, Tan Dinh Ward, Ho Chi Minh City, Vietnam +84 349661336 | tham@ttvnlegal.com.vn | https://ttvnlegal.com.vn/