Guidelines for Business Registration Without a Personal Identification Number

Guidelines for Business Registration Without a Personal Identification Number When a business registration application involves individuals lacking a Personal Identification Number (PIN), strict compliance with legal identity provisions is required. The national population database sharing mechanism directly affects the administrative procedures for establishing an economic organization. Preparing the dossier requires absolute accuracy regarding the investor’s personal information. The following article by Long Phan Consulting Company analyzes the operational process for this specific scenario.

What should be noted when filling out business registration documents without a personal identification number?

Based on Clauses 2 and 3, Article 11 of Decree 168/2025/ND-CP, the declaration of personal information in business registration procedures when lacking a PIN is regulated as follows:

• Applicant: If the person submitting the application lacks a PIN, the dossier must be accompanied by a valid copy of their passport, foreign passport, or documents with substitute value for a foreign passport as prescribed.
• Key Individuals: If a PIN is not available, the business registration dossier requiring personal information of the owner, members, shareholders, legal representatives, authorized representatives of organizational members/shareholders, or heads of branches/representative offices/business locations must include a valid copy of their passport, foreign passport, or documents with substitute value.

This regulation ensures the business registration authority can accurately identify the individuals involved in establishing the economic organization. Submitting a valid copy of an alternative identity document is a mandatory condition for the state agency to appraise and approve the business registration dossier.

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Language used in business registration documents

According to Article 10 of Decree 168/2025/ND-CP, the language used in business registration dossiers is specified as follows:

1. Documents in the business registration dossier are prepared in Vietnamese.
2. If the dossier contains documents in a foreign language, it must include a notarized Vietnamese translation attached to the foreign language document.
3. If a document is drafted in both Vietnamese and a foreign language, the Vietnamese content is used to process the business registration procedure.

Compliance with language regulations ensures legality and consistency during administrative appraisal. The Vietnamese translation serves as the sole basis for the state management agency to accurately record the legal entity’s information on the National Business Registration Database.

Which agency is responsible for verifying the validity of business registration documents?

Based on Article 4 of Decree 168/2025/ND-CP, the principles for handling business registration procedures are:

• Applicant Responsibility: The enterprise founder or the enterprise self-declares the dossier and bears legal responsibility for the legality, truthfulness, and accuracy of the information provided in the dossier and reports.
• Multiple Legal Representatives: If an LLC or JSC has more than one legal representative, the representative performing the registration procedure must ensure and take responsibility for correctly exercising their rights and obligations under Clause 2, Article 12 of the Law on Enterprises.
• Agency Responsibility: The business registration authority is responsible for the validity of the dossier format, but is not responsible for any legal violations committed by the enterprise or its founders.
• Disputes: The business registration authority does not resolve disputes between members/shareholders, or between the enterprise and other organizations/individuals.
• Sealing: Enterprises are not required to stamp their seal on the registration request, meeting minutes, resolutions, or decisions within the dossier. Sealing other documents follows relevant legal provisions.
• Combined Procedures: Enterprises can simultaneously perform procedures to change registration contents, notify changes, update/supplement information, and correct information within a single dossier submission.

Thus, while the business registration authority verifies the dossier’s validity, it bears no responsibility for legal violations by the enterprise or its founders.

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Long Phan Consulting Company provides business registration document preparation and consulting services

Long Phan Consulting Company provides comprehensive consulting solutions for investors in the process of establishing and operating economic organizations in Vietnam. Our team of experts, with in-depth knowledge of the Enterprise Law and its implementing decrees, will guide clients in resolving any issues and concerns when filing business registration documents without a personal identification number.

The consulting services that Long Phan Consulting Company provides to our valued clients include:

• Consulting on guidelines for business registration without a personal identification number;
• Verification of legality and guidance on preparing a replacement passport copy for individuals without a personal identification number.
• Prepare the complete list of business registration documents, including the application form, articles of incorporation, shareholder list, and decision appointing the legal representative.
• We provide certified translation services for foreign-language documents into Vietnamese, ensuring accuracy in specialized legal terminology.
• Submit paper documents and declare data online through the National Business Registration Portal on behalf of the investor.
• We will monitor the progress of the application review, receive and hand over the original Business Registration Certificate to our valued customers.

Business registration applications involving foreign elements or those with incomplete population data often encounter administrative hurdles. Long Phan Consulting Company assists clients in analyzing capital structure and proposing governance models. We operate a closed-loop process, ensuring timely assessment of investor applications. Our in-depth consulting solutions help clients prevent internal disputes arising from company charters.

>>> See more: Procedures for correcting business registration information of a limited liability company

Frequently Asked Questions about guidelines for business registration without a personal identification number

Below are some frequently asked questions regarding guidelines for business registration without a personal identification number:

What personal data is shared by the residential system with business licensing authorities? 

The national database system provides essential data fields including full name, date of birth, personal identification number, and gender. Simultaneously, this platform extracts information about ethnicity, nationality, permanent residence, and current address of the individual. This data sharing process directly serves state management, enabling administrative agencies to comprehensively review and store legal entity records.

Legal basis: Clause 5, Article 11 of Decree 168/2025/ND-CP.

Is the second legal representative of a joint-stock company responsible for the information declared? 

In cases where an economic organization has more than one legal representative, the individual directly carrying out the registration procedure is solely responsible. This individual is obligated to ensure that the declarations in the application are within their authority and that they fulfill their duties as stipulated in the Enterprise Law. Other representatives who do not directly sign the application will not be held legally responsible for any inaccurate administrative information declared.

Legal basis: Clause 2, Article 4 of Decree 168/2025/ND-CP.

Can investors combine the procedures for notifying changes to the content and correcting legal entity information at the same time? 

Current legislation allows economic organizations to integrate multiple administrative requirements into a single business registration application. Specifically, businesses have the right to simultaneously carry out procedures for registering changes to the content, notifying updates, supplementing, and correcting legal entity information. This administrative procedure reform mechanism helps customers optimize costs and shorten the waiting time for assessment results from state management agencies.

Legal basis: Clause 6, Article 4 of Decree 168/2025/ND-CP.

What obligations must individuals fulfill if their declared information does not match the national data system? 

When discrepancies are discovered between self-declared information and data stored in the National Population Database, the applicant is responsible for reviewing the information. That individual has a legal obligation to proactively update and correct personal information fields to ensure absolute consistency. Failure to standardize data according to regulations will result in the business registration authority refusing to issue a business registration certificate.

Legal basis: Clause 1, Article 11 of Decree 168/2025/ND-CP.

What documents do applicants submitting paper applications to administrative agencies use to verify their identity? 

When submitting a paper application in person at the one-stop service center, applicants are required to present valid identification documents. Individuals may use their Citizen Identity Card, a hard copy of their Citizen Identity Card, or an identification application to provide electronic identification. The processing officer will use these identification documents to verify the applicant’s identity and ensure its authenticity before issuing a receipt.

Legal basis: Clause 2, Article 11 of Decree 168/2025/ND-CP.

Is the Business Registration Office responsible for verifying the authenticity of minutes from board meetings? 

The state management agency only performs the function of reviewing the validity of the dossier based on the number of document components and compliance with legal form formats. Administrative staff have absolutely no authority or responsibility to assess the truthfulness or accuracy of meeting minutes or the content of internal resolutions. If fraudulent declarations or forged signatures occur, the business and its founders are solely responsible to law enforcement agencies.

Legal basis: Clauses 1 and 3, Article 4 of Decree 168/2025/ND-CP.

Conclusion

Understanding the guidelines for business registration without a personal identification number ensures the licensing progress of an economic organization. Investors must strictly adhere to administrative language standards and document authenticity.

If you need comprehensive business registration support, please contact the consulting team at Long Phan Consulting Company via Hotline 1900636389 for immediate solutions.