ABOLISHMENT OF THE CERTIFICATE OF REGISTRATION FOR OVERSEAS STUDY CONSULTANCY SERVICES: WHAT SHOULD BUSINESSES NOTE?

Enterprises conducting business in overseas study consultancy services should note Resolution No. 23/2026/NQ-CP as this regulation has cut down several procedures related to overseas study consultancy services under Decree No. 125/2024/ND-CP. The new regulation simplifies administrative procedures but is also a matter that enterprises need to pay attention to in order to avoid legal risks when state authorities conduct inspections. Lexsol presents the details in the article below.

1. Entities permitted to conduct business in overseas study consultancy services

Entities permitted to conduct business in overseas study consultancy services are organizations under Clause 1, Article 115 of Decree No. 125/2024/ND-CP, specifically:

1.1. Enterprises and enterprise branches established and operating in accordance with the provisions of the Law on Enterprises;

1.2. Public service units with the function of conducting business in overseas study consultancy services;

1.3. Foreign educational institutions operating lawfully in Vietnam.

In addition to the above entities, foreign-invested companies are also included. This is because overseas study consultancy services belong to the Educational Services sector under Vietnam's Schedule of Specific Commitments in Services in the WTO, specifically under Other Education Services - CPC 929. According to the Schedule of Commitments, foreign investors have the right to invest in conducting business in overseas study consultancy services through establishing 100% foreign-owned companies without restriction.  

See more: Foreign Investment Legal Advisory in Vietnam  

2. Scope of of overseas study consultancy services

Conducting business in overseas study consultancy services includes the activities under Clause 2, Article 115 of Decree No. 125/2024/ND-CP:

2.1. Introducing and providing advisory information on educational policies of countries and territories; providing advisory services on selecting schools, courses, majors, and qualifications suitable for the capabilities and aspirations of learners;

2.2. Organizing advertising, conferences, seminars, fairs, and exhibitions on study abroad in accordance with the provisions of law;

2.3. Organizing student recruitment and enrollment for study abroad;

2.4. Organizing training for necessary skills for Vietnamese citizens going abroad to study;

2.5. Organizing sending Vietnamese citizens abroad to study, sending parents or guardians to visit training locations abroad in accordance with the provisions of law;

2.6. Other activities related to conducting business in overseas study consultancy services.

3. Business conditions for overseas study consultancy services

The above organizations must fully satisfy the conditions specified in Article 116 of Decree No. 125/2024/ND-CP to be permitted to conduct business in overseas study consultancy services:

3.1. Possess a stable operating head office, physical facilities, and equipment to organize overseas study consultancy activities; introductory and advisory materials on educational policies of countries and territories; advisory materials on schools, courses, majors, and training qualifications.

3.2. Possess a team of staff directly providing overseas study consultancy satisfying the following requirements:

3.2.1. Hold a bachelor’s degree or higher; have the capability to use at least one foreign language at Level 4 or higher according to the 6-level Foreign Language Proficiency Framework for Vietnam and equivalent;

3.2.2. Hold a certificate of training in overseas study consultancy operations issued by the Ministry of Education and Training.

4. New regulations on overseas study consultancy services 

4.1. Reduction of administrative procedures

Resolution No. 23/2026/NQ-CP, issued and effective from April 29, 2026, provides for the reduction and simplification of administrative procedures applicable to sectors and fields under the management of the Ministry of Education and Training, including overseas study consultancy services. 

With respect to overseas study consultancy services, Resolution No. 23/2026/NQ-CP provides that the procedures for the issuance, adjustment, supplementation, and extension of the Certificate of Registration for overseas study consultancy services, as well as the procedure for requesting permission to resume providing overseas study consultancy services, under Decree No. 125/2024/ND-CP shall not be implemented[1]. 

Businesses should note that the mechanism for reducing administrative procedures for overseas study consultancy services under Resolution No. 23/2026/NQ-CP shall apply from July 1, 2026 through February 28, 2027. 

4.2. Notification of overseas study consultancy service activities

Instead of performing business registration procedures as previously, currently, enterprises conducting business in overseas study consultancy services shall fulfill the notification obligation as follows[2]:

4.2.1. At least 05 working days prior to operation, enterprises must notify in writing of their business activities in overseas study consultancy services to the Department of Education and Training where the business activities are implemented. 

4.2.2. Notify updates when there are changes to the contents or upon termination of operations.

4.2.3. Provide fully, accurately, and promptly relevant information and documents.

4.2.4. Publicly disclose operational information on the website of the enterprise (if any).

4.2.5. Implement reporting regimes. 

4.2.6. Take self-responsibility for satisfying the business conditions for this activity. 

5. Common errors made by enterprises

Some common errors that enterprises often commit are as follows: 

5.1. Misunderstanding that the reduction of license issuance procedures means no longer needing to satisfy business conditions.

5.2. Failing to perform or being delayed in performing the notification obligation under Resolution No. 23/2026/NQ-CP.

5.3. Incomplete notification content or lacking supporting documents. 

5.4. Failing to update new information upon changes in content or upon termination of business activitie.

5.5. Subjectivity in storing dossiers and publicly disclosing business operation information

6. Conclusion

Transitioning from the licensing mechanism to notification procedures under Resolution No. 23/2026/NQ-CP brings great initiative to enterprises conducting business in overseas study consultancy services, but at the same time increases legal liability. To operate sustainably and avoid legal risks, enterprises need to proactively review business conditions, complete notification dossiers, and maintain information transparency throughout their operation process.

If Clients still have questions regarding this matter, please contact Lexsol for timely support. Lexsol can assist in reviewing specific cases before enterprises perform the procedures.