Does opening a billiards shop require a business license? 

A Billiards business license is a mandatory compliance requirement for foreign investors operating billiards facilities in Vietnam. Launching operations without the Certificate of Eligibility for Sports Business Operations may lead to immediate suspension, administrative penalties, and substantial financial losses. Business registration alone does not authorize the provision of regulated sports services under the Law on Enterprises and Businesses.

Long Phan Consulting supports investors in assessing premises, technical standards, equipment, and licensing documents to establish compliant operations and reduce approval risks from the project planning stage.

Strategic Separation of Corporate Entity Registration and Sports Business Licensing

Foreign investors must understand that registering a business or household entity does not equate to a license to operate. This process merely establishes your legal personality; it does not replace the mandatory Certificate of Eligibility for Sports Business Operations.

The primary risk for investors is launching operations immediately after company formation. Under Clause 2 and Clause 4, Article 55 of the Law on Physical Training and Sports (2006, amended 2018), any enterprise conducting sports activities must possess specialized personnel and certified infrastructure. You may only commence business operations after receiving the official Certificate of Eligibility.

An optimal, risk-averse approach involves establishing your legal entity first, followed by a systematic application for the industry-specific permit. Inverting this sequence can lead to delayed openings, wasted rental expenses, and regulatory non-compliance during site inspections.

Identifying Risks in Confusing Sports Operational Permits with Corporate Registration

Misunderstanding these procedures frequently leads to premature, unauthorized openings. For investors securing long-term lease agreements, the risk extends beyond administrative penalties to include significant cash flow disruption, failed renovation investments, and compromised human resource planning.

Under the market nomenclature, the “billiards business license” must be accurately understood as the Certificate of Eligibility for Sports Business Operations. Pursuant to Clause 1, Article 23 of Decree 36/2019/NĐ-CP, this certificate may be revoked if the enterprise terminates sports activities or has its operational rights suspended due to administrative violations.

Key operational risks requiring strict control include:

• Launching operations with only an Enterprise Registration Certificate (ERC) while lacking the Certificate of Eligibility.
• Committing to premises, equipment procurement, and personnel recruitment before verifying physical facility standards and specialized documentation.
• Failing to maintain operational compliance records, leaving the facility vulnerable during sudden regulatory inspections.

The safest approach is to treat this industry-specific permit as a foundational prerequisite for opening. While entity registration provides the “legal shell,” the Certificate of Eligibility dictates your actual right to operate a billiards facility in Vietnam.

Beneficial Ownership Disclosure Obligations for Billiard Chains

For billiard chains operating via franchising, investment partnerships, or capital-raising models, business registration documents must be managed as essential legal assets. Inaccurate ownership information can significantly delay amendments to your business registration.

Pursuant to Clause 35, Article 4 of the 2020 Enterprise Law (amended 2025), a “Beneficial Owner” is defined as an individual who holds actual ownership of the charter capital or exercises control over the enterprise, excluding cases of state-owned capital representation.

This obligation is particularly critical when your business:

• Raises capital to expand chains or alters capital contribution structures.
• Transfers shares or capital contributions to new investors.
• Amends business registration details when establishing additional business locations.
• Restructures the legal entity to separate billiard operations from F&B or entertainment divisions.

To ensure compliance, enterprises should standardize beneficial owner records before applying for registration adjustments. Any inconsistencies in your legal entity records may trigger delays in securing the required sports operating permits and postpone the launch of new facilities.

Assess the infrastructure and standardize billiard facilities before signing a lease agreement

Investors should assess the premises before making a deposit or signing a long-term lease. The bottleneck in billiard business license applications often lies in the ability to demonstrate the physical facilities, not just in the administrative application form.

Businesses operating in the sports sector must have facilities and equipment that meet operational requirements. The Minister of Culture, Sports and Tourism is responsible for issuing national technical standards on sports facilities and equipment applicable to businesses, as stipulated in Clause 2, Article 24 of Decree No. 36/2019/ND-CP.

Items to review before renting include:

• Actual usable area to arrange tables, walkways, waiting areas, and operational areas.
• Table layout diagram to demonstrate the suitability of the premises when preparing the Summary of Business Conditions Preparation.
• Current condition of structure, roof, ventilation and escape routes. This aims to reduce the risk of renovations after the contract has been signed.
• Ability to meet fire safety, noise, and residential order requirements. If the model combines coffee, refreshments, or nighttime activities.

Surveying should be done before finalizing the site plan. If the lease agreement does not allow for renovations, the business may find itself paying rent but not being eligible to complete the necessary permit application.

Standard design for spatial layouts and industry-specific barrier systems

Businesses need to control the design of the space in a way that demonstrates safety, functionality, and suitability for sports activities. This is the foundation for ensuring that the application does not raise any doubts about the condition of the facilities.

Parameters such as the area where the table is placed, including the covered area and the distance from the outer edge of the table to the wall 1.5m and the distance between the tables 1.2m This provision was previously a reference point in the old specialized regulations. However, this provision in Circular No. 04/2018/TT-BVHTTDL has been repealed by Article 16 of Circular No. 21/2025/TT-BVHTTDL.

Therefore, businesses should not use outdated parameters as their sole legal basis. The safer approach is:

• The site is surveyed based on practical operational criteria and safe movement requirements.
• Create a layout plan showing the desks, walkways, support areas, and management staff areas.
• Check the latest guidelines from your local relevant authority before submitting your application.
• Keep photographs, drawings, and documentation of equipment to demonstrate the condition of the facilities.

The commercial risk lies in designing the shop based on market experience but failing to meet inspection criteria. Investors should include clauses in the lease agreement granting the right to renovate, remedy, and terminate the lease if the premises do not meet licensing requirements.

Review safety conditions and the professional personnel responsible for operation

A billiards facility requires more than just tables, cues, and space. Businesses must also demonstrate their ability to operate safely, especially if they provide training, instruction, or organize regular sporting activities.

Conditions for conducting sports business activities include having a qualified team of professional staff and facilities and equipment that meet requirements. Businesses are only allowed to operate after being granted a Certificate of Eligibility to conduct business, in accordance with Clauses 2 and 4 of Article 55 of the Law on Physical Education and Sports of 2006, as amended and supplemented in 2018.

The documents that should be prepared include:

• Personnel files for management staff, training instructors, or professional staff if the model includes training.
• The document describes the equipment, billiards/snooker tables, and operating area.
• Safety control procedures, operating hours, customer management, and incident handling.
• Documentation related to fire safety, noise control, and security is required if the business model involves large gatherings of people.

Preparing specialized personnel from the outset helps ensure the application is consistent with the nature of the sports activity. If the facility is only described as a regular entertainment service, the business is likely to be asked to provide explanations or additional documentation.

Procedure for submitting an application for a Certificate of Eligibility to Conduct Sports Business Activities

Businesses should view the procedure for applying for a Certificate of Eligibility to Conduct Sports Activities as a separate and independent process from business registration or household business registration. If the application is not properly prepared from the outset, the opening plan may be delayed due to the need for amendments and additions.

The execution sequence should be controlled according to the following steps:

1. Review pre-application requirements
   Businesses check the registered business activities, premises, equipment, professional personnel, and relevant fire safety documents. This is a risk screening step before submitting the application.
2. Prepare the documents for obtaining the Certificate.
   The application must clearly demonstrate the business conditions for operating sports activities, especially regarding facilities and personnel. The required number of documents is…1 set, in accordance with Clause 1, Article 19 of Decree No. 36/2019/ND-CP, amended and supplemented by Decree No. 31/2024/ND-CP.
3. Submit the application to the competent authority.
   Businesses can submit their applications directly, by mail, or electronically to the specialized agency for physical education and sports under the People’s Committee of the province where their business is registered.
4. Monitor feedback on revisions and additions.
   If the application is incomplete, the issuing authority will notify the applicant of the necessary amendments and additions.3 working days from the date of receipt of the application, according to Clause 2, Article 20 of Decree No. 36/2019/ND-CP.
5. Receive licensing results
   When the application is complete and valid, the competent authority will check the business conditions and issue a Certificate.7 working days from the date of receipt of complete and valid documents, in accordance with Clause 2, Article 20 of Decree No. 36/2019/ND-CP.

Effective management involves linking the licensing process to the timeline for leasing, renovation, and hiring. If additional documents are requested, businesses need to respond quickly to avoid missing the opening deadline.

Prepare a summary of business conditions and core documentation

The summary of business preparation is an often overlooked but crucial document. This is where the business demonstrates that the billiards facility meets the requirements to operate as a sporting event.

The application for a certificate needs to be standardized into 01 set of documents. This includes the Application for a Certificate and a Summary of the preparation of conditions for conducting sports business activities, as stipulated in Clause 1, Article 19 of Decree No. 36/2019/ND-CP, amended and supplemented by Decree No. 31/2024/ND-CP.

The application should clearly state:

• Legal information of the business or household business.
• The location for the billiards business and the right to use the premises are legitimate.
• Describe the facilities, equipment, billiards/snooker tables, and auxiliary areas.
• Layout diagram showing tables, walkways, management area, and customer service area.
• Documentation on professional personnel if the operating model includes training or instruction.
• Supplementary documents regarding fire safety, noise control, and security, if relevant to the scale of operation.

Businesses should review their applications using a logical “proof of eligibility” approach, not just filling out forms. If the summary lacks factual data, the processing agency has grounds to request revisions or further verification.

Jurisdiction for resolution and key administrative processing deadlines

The licensing authority needs to be correctly identified from the outset to avoid submitting applications to the wrong place. For billiard halls, the processing authority is not the business registration agency but the provincial-level specialized agency for physical education and sports.

Businesses submit their applications to the specialized agency for physical education and sports under the People’s Committee of the province where the business location is registered. This is the authority that issues the Certificate of Eligibility for Sports Business Activities, according to Clause 1, Article 19 of Decree No. 36/2019/ND-CP, amended and supplemented by Decree No. 31/2024/ND-CP.

The deadlines that need to be included in the opening plan are:

• 3 working days: The issuing authority shall notify the applicant directly or in writing if the application needs to be amended or supplemented, in accordance with Clause 2, Article 20 of Decree No. 36/2019/ND-CP.
• 7 working days: The competent authority shall inspect the business conditions and issue the Certificate from the date of receipt of a complete and valid application, in accordance with Clause 2, Article 20 of Decree No. 36/2019/ND-CP.
• 3 working days: When ceasing business operations related to sports activities, enterprises must return the Certificate of Eligibility to the licensing authority, in accordance with Point b, Clause 2, Article 23 of Decree No. 36/2019/ND-CP.

In terms of operations, these milestones need to be incorporated into the lease plan, opening communications, and staff recruitment. Opening before receiving the Certificate of Registration could create risks of inspections and disrupt cash flow.

Risk Management for Ancillary Licensing in Integrated Billiards Models

Possessing a Certificate of Eligibility for Sports Business Operations does not automatically authorize all associated services. For integrated models combining billiards with coffee, beverages, alcohol, or fee-based tournaments, the primary risk lies in your ancillary licensing ecosystem.

Enterprises should concurrently manage these document groups:

• Fire Prevention and Fighting (PCCC): Verify total floor area, emergency exits, fire suppression equipment, and safety management records.
• Tax Registration and Invoicing: Ensure revenue from billiards, F&B, tournaments, or ancillary services is accounted for correctly.
• Signage and Advertising: Regulate dimensions, placement, and content to comply with brand and business line registrations.
• Lease Agreements: Confirm authorization for billiards operations, renovation rights, and liability for facility-related licensing failures.
• Noise and Public Order: Establish operating hours, soundproofing measures, and customer management protocols.

The safest management strategy is to establish an interdisciplinary checklist prior to your opening date. Neglecting any ancillary license can disrupt your business model, even if the primary sports license has been granted.

Fire Safety (PCCC) Compliance and Functional Conversion Timelines

Billiards facilities often operate in enclosed, high-occupancy spaces with significant electrical infrastructure. Consequently, Fire Prevention and Fighting (PCCC) is a critical inspection point prior to launching or expanding floor area.

Pursuant to Section 14.4, Appendix I of Decree 105/2025/NĐ-CP, service businesses with a total floor area of 300 $m^2$ or more are subject to PCCC management. Investors must accurately assess the actual floor area before signing lease agreements or commencing renovations.

For existing facilities unable to meet current PCCC requirements, Clause 3, Article 43 of Decree 105/2025/NĐ-CP provides a grace period for technical improvements until July 1, 2028. If compliance remains unreachable after this deadline, a functional conversion is mandatory.

Incorporate PCCC costs into your legal budget early in the site survey stage. If the premises cannot accommodate mandatory safety exits or systems, a long-term lease may become a stranded asset.

Integrating F&B and Alcohol Licensing with Noise Control Management

Combining billiards with F&B services increases revenue but expands your compliance obligations. Do not assume that obtaining a sports license permits the unrestricted sale of food, beverages, or the hosting of commercial events.

Critical risk areas include:

• F&B Compliance: Adhere to food safety regulations, including standards for preparation areas, ingredient storage, and serving protocols.
• Alcohol Licensing: Verify specific conditions for selling or serving alcoholic beverages on-site.
• Commercial Tournaments: Standardize competition rules, fee collection methods, sponsorship contracts, and organizational liability.
• Noise Control: Implement sound management, strictly observe operating hours, and manage surrounding community feedback.
• Public Order: Establish clear customer management regulations, shift personnel duties, and incident response procedures.

Operate with a broad compliance roadmap. As you add services, you must explicitly separate revenue streams, licensing requirements, and management responsibilities to avoid regulatory exposure.

Professional Legal Consulting and Licensing Services at Long Phan Consulting Company

The application process for a billiards business license is far more than a routine administrative filing. It is a comprehensive legal audit encompassing site suitability, human resources, and ancillary permits. Long Phan Consulting Company supports enterprises in designing a licensing roadmap tailored to your specific operational model, especially for facilities integrating F&B, entertainment, or chain expansion.

Our core consulting tasks include:

• Legal Due Diligence: Assessing site usage rights, lease terms, renovation feasibility, and PCCC risks prior to contract execution.
• Entity Structuring: Reviewing your business registration, sectors, and corporate structure before applying for the Certificate of Eligibility.
• Facility Validation: Inspecting infrastructure, table layouts, support areas, and safety documentation to ensure compliance.
• Personnel Compliance: Advising on specialized staff requirements for models involving coaching or training.
• Dossier Drafting: Preparing the Application Form and Summary Report to meet exact regulatory standards and minimize amendment requests.
• Government Liaison: Representing your firm during submission and monitoring feedback from Provincial Sports Authorities.
• Ancillary Licensing: Reviewing permits for PCCC, F&B, alcohol, signage, noise management, and commercial tournament organization.
• Amendment Handling: Promptly addressing and resolving feedback during the licensing review process.

The primary value of professional legal counsel is preventing costly mistakes such as securing unsuitable premises, failing renovation standards, or launching without a full legal permit. To initiate a preliminary evaluation, please send your facility documents, business registration, and proposed operational model to Email: info@longphanpmt.com or contact us via Zalo/WhatsApp: +84 906 735 386.

Frequently Asked Questions about the Comprehensive Guide to Completing Your Billiard Business License Application

Establishing and operating a large-scale billiards business requires investors to overcome complex legal hurdles related to specialized sports operating conditions. Carelessly opening a facility after only completing business registration procedures without possessing the necessary “billiards business license” risks immediate suspension of operations. A thorough understanding of administrative timelines and inter-agency fire safety standards is key to optimizing premises costs and ensuring absolute compliance throughout sustainable operation.

Conclusion

Securing a billiards business license in Vietnam demands meticulous alignment of your corporate entity, facility infrastructure, specialized personnel, and ancillary permits. Prematurely launching operations based solely on general business registration exposes your investment to severe regulatory sanctions, operational suspension, and substantial financial risk. To ensure long-term compliance and safeguard your capital, verify all PCCC standards and specialized sports requirements before finalizing your operational strategy.

For comprehensive legal support in navigating these complex Vietnamese administrative procedures and to optimize your facility’s compliance roadmap, contact the senior legal team at Long Phan Consulting Company via our direct hotline at 1900636389 for immediate professional assistance.