Clinic Setup Vietnam: Facility Standards, Room Requirements, and MOH Compliance for American Investors

When US investors evaluate real estate for a medical facility in Vietnam, they typically approach the process through a commercial property lens — square footage, location, lease terms. What they frequently underestimate is the extent to which Vietnamese law prescribes not just the size of clinical spaces but their specific layout, surface materials, ventilation, sterilization infrastructure, and safety systems.

This article provides a technically detailed overview of Vietnam’s facility standards under Decree 96/2023/ND-CP — the most current implementing regulation for the Law on Medical Examination and Treatment 2023 — so that US investors can make informed decisions from the outset.

Article 40 of Decree 96/2023/ND-CP establishes universal baseline conditions that apply to every healthcare facility in Vietnam regardless of type or specialty. US investors should review these in conjunction with any prospective lease or purchase:

Structural Safety (Clause 2, Article 40):

• Fixed premises with structural load-bearing compliance under Vietnamese construction law
• Fire prevention and suppression systems in full compliance with Decree 105/2025/ND-CP
• Infection control infrastructure per Decision 5991/QD-BYT (December 26, 2019)
• Environmental protection systems (waste management, wastewater treatment where applicable)
• Radiation safety compliance under Circular 59/2025/TT-BKHCN if any X-ray, CT, or other radiation-emitting equipment is used
• Sufficient and reliable electrical and water supply for all clinical operations

Identification and Navigation (Clause 2, Article 40):

• Facility signboard visible and compliant with content requirements
• Floor plan maps displayed at entry points
• Directional signage to all departments, consultation rooms, and administrative offices

The general polyclinic (Phong kham da khoa) under Article 39 Point a and Article 42 of Decree 96 is the most common structure chosen by US medical groups entering Vietnam. Requirements are substantial:

Specialty Requirements (Article 42, Clause 1):

• Minimum of 3 specialties required
• At least 2 of the 4 core specialties must be represented: internal medicine, general surgery, obstetrics, or pediatrics
• Mandatory paraclinical departments: laboratory services AND diagnostic imaging
• Emergency treatment room is mandatory
• Patient holding room is mandatory
• Minor surgery room is required if minor surgical procedures will be performed

Room Area Minimums (Article 42, Clause 2):

• Emergency room:  minimum 12 m²
• Patient holding room:  minimum 15 m² with at least 2 holding beds; if 3 or more beds, minimum 5 m² per bed
• Specialist consultation rooms:  minimum 10 m² each
• Procedure rooms:  minimum 10 m² (physical therapy procedure rooms minimum 20 m²)

Additional Infrastructure:

• Sterilization area for reusable medical instruments (unless all instruments are single-use or a sterilization service contract exists with a licensed facility)
• Anaphylaxis emergency kit and specialty-specific emergency medications

Vietnam’s infection control framework requires implementation of 9 standard precaution categories, which directly affect your facility design:

• Hand hygiene stations — placement requirements at entry to every clinical zone
• Personal protective equipment storage and disposal facilities
• Respiratory hygiene accommodation (waiting area design implications)
• Patient segregation capacity — ability to isolate patients with infectious conditions
• Instrument processing: cleaning, disinfection, and sterilization workflow
• Safe injection and sharps disposal infrastructure
• Linen handling and processing facilities
• Environmental hygiene — surface materials must be non-porous and washable
• Healthcare waste management — compliant waste storage, segregation, and disposal chain

Staff training in infection control is also mandatory upon hiring and annually thereafter. This is a compliance obligation, not merely a best practice, and inspectors will verify training records during facility licensing inspections.

Any facility intending to operate X-ray equipment — even a basic digital dental X-ray unit — must comply with the updated radiation safety framework under Circular 59/2025/TT-BKHCN. Key requirements US investors should understand:

• Room specifications:  The previous minimum area requirement for X-ray rooms has been removed, but physical shielding requirements remain stringent. Walls, floors, and ceilings must provide adequate radiation attenuation
• Lead shielding:  Diagnostic shielding materials (lead rubber) must have a minimum equivalent thickness of 0.5 mm lead
• Equipment controls:  X-ray units must display kV, mA, and exposure time parameters; automatic exposure cutoffs are required
• Operating distance:  Mobile X-ray equipment must provide a minimum 2-meter operator distance via extension cable
• Licensing:  Radiation work permits must be obtained from the provincial Department of Science and Technology before operation
• Personnel dosimetry:  Individual radiation dose monitoring records must be maintained for all radiation workers
• Emergency response plan:  A facility-level radiation incident response plan is mandatory under the 2025 circular

Fire safety compliance is a prerequisite for facility licensing, and inspectors from both the fire authority and the Department of Health will verify compliance independently. Key requirements include:

• Submission and management of fire safety dossier with local fire authority
• Installation of approved fire detection and suppression equipment
• Clearly marked and unobstructed evacuation routes
• Electrical system compliance with fire-related standards
• Establishment of a facility-level fire safety team
• Regular fire safety training for all staff

For US-based diagnostic companies or investors planning laboratory components, Article 53 of Decree 96/2023/ND-CP specifies:

• Single-type lab (hematology, biochemistry, genetics, or immunology):  minimum 10 m²
• Two or three lab types combined:  minimum 15 m²
• All four types:  minimum 20 m²
• Histopathology and cytology:  minimum 20 m² in a room physically separate from other laboratory types
• Microbiology lab:  minimum 20 m² in a physically separate room

Surface materials for all laboratory rooms must be non-porous and water-resistant from floor to ceiling. Laboratory benches must be non-porous and corrosion-resistant, with integrated wash basins and clean water taps installed directly at the bench.

TTVN Legal’s clinic setup service includes a pre-lease facility assessment that evaluates any prospective property against the full requirements matrix of Decree 96/2023/ND-CP and all associated technical standards. We identify compliance gaps before you sign a lease, provide a remediation plan, and coordinate with architects and contractors to ensure that the buildout meets MOH standards before the inspection application is filed.

This pre-lease service has saved our US clients significant sums by identifying properties that would require cost-prohibitive modifications to meet standards — before any financial commitment was made.