Australia has a strong dental industry, and Australian dental practitioners and investors have increasingly looked to Vietnam as an attractive destination for dental clinic investment. The Vietnamese Ministry of Health (MOH) imposes a comprehensive set of requirements on foreign-invested dental clinics, and understanding these requirements upfront is essential to avoiding costly compliance failures.
This guide covers all key MOH requirements under Decree 96/2023/ND-CP and related legislation for Australian dental clinic investors in Vietnam.
MOH Classification of Dental Facilities
The MOH classifies dental clinics under Decree 96/2023/ND-CP as specialty outpatient clinics (phong kham chuyen khoa – rang ham mat). This classification determines the applicable facility standards, staffing requirements, and licensing authority. For most Australian investors operating a single-location dental clinic, the relevant licensing authority is the provincial Department of Health (“DOH”).
Facility Infrastructure Requirements
Under Articles 40 and 47 of Decree 96/2023/ND-CP, dental clinics must meet the following physical requirements:
- Fixed location with structural safety compliance (Decree 105/2025/ND-CP for fire safety; relevant construction standards for load-bearing capacity – note that dental X-ray equipment imposes specific structural load requirements);
- Reception area for patients;
- Examination room of at least 10 m2;
- Minimum one dental chair with at least 5 m2 of dedicated floor space per chair;
- Dedicated implant room (minimum 10 m2) if implant procedures are performed;
- Sterilization area for reusable instruments (or a contract with another facility for sterilization);
- Anaphylaxis emergency kit;
- Signage, floor plans, and departmental guides.
Australian investors should also note the radiation safety requirements under Circular 59/2025/TT-BKHCN for dental X-ray equipment: the clinic must obtain a radiation practice permit from the provincial Department of Science and Technology, maintain individual radiation dose records for staff, and ensure that lead shielding meets prescribed standards.
Staffing Requirements and Practitioner Licensing
All dentists practicing at the clinic must hold valid Vietnamese medical practice licenses with a dental practice scope. Under Article 47 of Decree 96/2023/ND-CP:
- The responsible clinical director must be a physician with a dental or dental specialty scope of practice;
- All other practicing dentists must hold individual Vietnamese practice licenses;
- Support staff (dental assistants, hygienists) must meet applicable training and certification requirements.
Australian-trained dentists must have their credentials recognized by the Vietnamese MOH (AHPRA registration) before a Vietnamese practice license will be issued. This process must be factored into the clinic’s staffing plan and opening timeline.
Infection Control and Sterilization Requirements
The MOH applies strict infection control standards to dental facilities under Decision 5991/QD-BYT of December 26, 2019. Key requirements for dental clinics include:
- Implementation of all nine standard precautions, including hand hygiene protocols, personal protective equipment, respiratory hygiene, and environmental cleaning;
- Proper decontamination, disinfection, and sterilization of all reusable dental instruments;
- Annual and new-staff infection control training;
- Regular auditing of sterilization processes and environmental conditions.
Australian investors familiar with Dental Board of Australia standards will find many parallel requirements, but the documentation format and language requirements differ and must comply with Vietnamese MOH specifications.
Application Process and Key Timelines
The healthcare operating license application for Australian-owned dental clinics involves:
- Preparation and submission of the dossier to the provincial DOH; 2. DOH review (typically 60 days for a complete dossier); 3. On-site inspection (if required by the Department); 4. Issuance of the operating license.
Realistic timelines from initial investment to license issuance: 4–8 months, depending on document preparation speed, constructor’s compliance with facility requirements, and the speed of practitioner license issuance for the responsible director.
Conclusion
Australian dental clinic investors in Vietnam face a demanding but transparent MOH compliance framework. From facility design to staff credentialing, early planning and expert legal guidance are the keys to a smooth licensing process. TTVN Legal works with Australian dental clinic investors at every stage, from pre-investment legal due diligence through to operating license approval.
Ready to invest in Vietnam’s dental sector? TTVN Legal provides end-to-end legal support. 101 Nguyen Van Thu, Tan Dinh Ward, Ho Chi Minh City | +84 349661336 | tham@ttvnlegal.com.vn | https://ttvnlegal.com.vn/
