1. Education and Training Working Group – Position Paper Vietnam Business Forum: December 2015
Page 1 of 14
EDUCATION AND TRAINING POSITION PAPER
Prepared by
Mr Brian O’Reilly, Chair E&T WG
Ms Hoa Pham Co-Chair E&T WG
Education and Training Working Group
Vietnam Business Forum
Executive Summary
The Vietnamese economy continues to grow and in order to sustain this growth at desired levels
the need for quality education and training is imperative. Vietnam needs to improve the
productivity of its workforce and although a challenge at the present time with effective
strategies it can become an opportunity. This will be best achieved through a coordinated effort
by all major stakeholders lead by the Vietnamese Government.
The paper focuses on two main areas firstly, Decree 73 and secondly, issues relating to Technical
and Vocational Education and Training (TVET).
Decree 73 applies to foreign investment and cooperation projects in education and vocational
training in Vietnam. It sets out the framework for the future of foreign investment in education in
Vietnam. The quality of education in Vietnam has been an issue and this can be improved, in
part, by attracting foreign institutions that have a record of delivering quality education.
A number of issues and recommendations have been raised and made to help make decree 73
more effective in establishment of quality education institutions in Vietnam. It is important that
the decree focus on outcomes, i.e. quality graduates, and then establish the framework to make
this happen.
Having effective TVET institutions lays the foundation for economic growth by supplying work
ready graduates with the necessary knowledge, skills, and attitude to make a positive
contribution in the workplace. To achieve this it is necessary to know what competencies are
needed by industry and then developing and delivering curriculum to produce the graduates that
industry needs.
The capacity of the institutions needs to be raised to the required levels to be able to produce
these graduates. This requires training of TVET staff in areas such as leadership, curriculum
development, market research and analysis etc. In addition, TVET institutions need to be able to
attract capable students and the development of a National Qualifications Framework (NQF) and
a single articulation system for Vietnamese education.
In conclusion the Vietnamese economy continues to grow and this is of benefit to the citizens of
Vietnam. There are opportunities for Vietnam, however, it needs a highly competent workforce
to drive growth in the economy.
Quality education and training is required and this would also require the combined efforts of
relevant stakeholders working closely together to find effective solutions. The Education and
Training Working Group, through the VBF, will continue with its commitment to assist Vietnam
in achieving it economic potential.

2. Education and Training Working Group – Position Paper Vietnam Business Forum: December 2015
Page 2 of 14

3. Education and Training Working Group – Position Paper Vietnam Business Forum: December 2015
Page 3 of 14
1. Introduction
The Vietnamese economy is entering a new era with the formation of the ASEAN Economic
Community (AEC) and the Trans Pacific Partnership (TPP). This should lead to many growth
opportunities in the Vietnamese economy. However, in order to take full advantage of these
opportunities the Vietnamese workforce needs relevant knowledge and skills. The size of the
Vietnamese workforce has been a key factor in Vietnam’s economic growth, however, this
cannot continue. Vietnam needs to focus on making its workforce more productive.
A recent report from the International Labour Organisation (ILO) showed that Vietnam’s labour
productivity rate in 2013 was among the lowest in Asia Pacific. It was 15 times lower than
Singapore, 11 times lower than Japan, and 10 times lower than South Korea. In addition, another
report stated that despite considerable improvement in recent years, Vietnam’s labour
productivity is lagging decades behind regional countries. The opportunity for Vietnam is to
increase the skills of its workforce to rapidly improve the productivity of its workforce.
The World Bank report “Skilling up Vietnam: Preparing the workforce for a modern market
economy” states that “Equipping its workforce with the right skills will, therefore, be an
important part of Vietnam’s effort to accelerate economic growth and further its economic
modernization in the coming decade and more”. Therefore, efficient and effective education and
training is integral to the development of the Vietnamese workforce and economic growth.
The success in improving the quality of education and training in Vietnam will require the
combined efforts of relevant stakeholders working closely together to find effective solutions.
The Education and Training Working Group, through the VBF, will continue with its
commitment to assist Vietnam in achieving it economic potential through improvements in
education and training.
This report will focus primarily on Decree 73 and the Technical and Vocational Education and
Training through the identification of relevant issues and opportunities to improve.

4. Education and Training Working Group – Position Paper Vietnam Business Forum: December 2015
Page 4 of 14
2. Decree 73
Decree 73 replaces Decree 06, and applies to foreign investment and cooperation projects in
education and vocational training in Vietnam including foreign-invested tertiary institutions,
schools and kindergartens, twinning programs, and representative offices of foreign education
institutions. We firmly believe that the most important goal is to have quality graduates
entering the workforce and that Decree 73 is integral in this respect. The following are the
main issues raised by the education and training working group with proposed
recommendations.
2.1 Licensing-related issues
2.1.1 Requiring 3 kinds of licenses
Under the Decree 73, the working group views it as being much more complicated
than in the past, as it requests to have an investment license, then an establishment
license, then an operations license. This applies even when setting up a branch of
an already licensed organization. A lot of paperwork/steps are repeated during
these processes and assessed by many of the same departments. This results in an
inefficient use of time for investors/organizations and agencies issuing licenses.
New investors to Vietnam, as well as current investors, feel that it is far too
onerous to overcome all these complicated licensing procedures. In addition, this
is in contradiction with what was stated by the Government and National
Assembly on the investment law (i.e. simplifying administrative procedures for
investors).
The license application now has 3 steps instead of 2 like before (the additional
step is the establishment license). The application required is exactly the same for
all 3 licenses and involves the same departments for approval, which is
duplicating processes and, therefore, simplification is strongly recommended.
The investment certificate requires the involvement of 7 departments/government
bodies including the Department of Planning and Investment, the Department of
Education and Training (DOET), the Construction Department, the People
Committee of the District (they need to get 2 more Departments’ approval: the
Architects Department, and the Fire Department then finally approval by the
Peoples Committee.
The establishment license requires the involvement of 3 departments/government
bodies, which are DOET, the Provincial People’s Committee, and the Department
of Internal Affairs.
The operations license requires only the approval of DOET.
Recommendation
• Retain the two-step process previously provided in Decree No. 06 and Circular
14.

5. Education and Training Working Group – Position Paper Vietnam Business Forum: December 2015
Page 5 of 14
2.1.2 The list of application documents
Currently, the list of application documents is not clearly understood and it leads
to licensing authorities requiring similar documents for 3 kinds of licenses. This
poses a big challenge for investors.
For example, at the stage of applying the establishment license, the completed
profiles of foreign teachers that need to be submitted, include their work permit
and labour contract However, the foreign invested educational institution are not
allowed to start operating until the operation license is granted.
Articles 38 and 48 of Decree 73 states that “it needs 60 working days to issue the
establishment license and 32 working days to issue the operation license”.
Therefore, the total duration is 92 workings days, approximately 4 months. This
means that the foreign invested educational Institution must pay 4 months salary
to these teachers until they obtain the necessary licenses to commence operations.
Recommendations
• That the documents required to obtain each type of license are clarified.
• Circulars to guide the implementation of the Decree 73 need to include clear
penalties when government officials process applications in order to avoid
time-consuming delays and unnecessary costs for investors.
2.1.3 Inspection the facilities of foreign invested educational Institution
Due to ambiguous regulations in Decree 73, licensing authorities need to conduct
a number of inspections of the facilities before issuing each license. Prior to
commencing operations, each educational institution will have 3 inspections by
three different licensing authorities at the same location. This is an inefficient use
of both time and manpower for both investors and licensing authorities.
Recommendations
• Decree 73 should include provisions that classify at which period of the license
application the facilities of the foreign invested educational institution need to
be inspected.

6. Education and Training Working Group – Position Paper Vietnam Business Forum: December 2015
Page 6 of 14
2.2 Article 74 – Point 1
The following is what is proposed in Decree 73.
IMPLEMENTATION PROVISIONS - Article 74. Transitional provisions
1. Foreign-capitalized educational institutions and their campuses that have been issued
with the Investment certificates concurrently the Business registration certificates and
the Licenses to provide education before this Decree takes effect are exempted from
reappraisal, but they must supplement and complete the dossiers within 06 months as
from this Decree takes effect to be issued with the Decisions on approving the
establishment of educational institutions and campuses.
Recommendations
• If the establishment license is still retained, we respectfully recommend the Ministry
to amend Article 74 of Decree 73 as recommended below so that non state higher
education organizations can obtain a decision on approving the establishment of
educational institutions and campuses in a timely manner.
Currently, some members of the Education and Training Working Group are
preparing dossiers following the requirements as set out in this Article. However,
officials are requesting that new requirements under Decree 73 must be met instead
of requirements under Decree 06. We respectfully request that the Ministry indicates
in the guiding regulations of Decree 73 that it does not require retroactive
applications when applying for the decision.
Suggested modification to Article 74.1.
1. Foreign-capitalized educational institutions and their campuses that have been
issued with the Investment certificates concurrently, the Business registration
certificates and the Licenses to provide education before this Decree takes effect are
exempted from reappraisal, but have to submit an application for establishment
license and report actual activities in the last 3 years in order to be issued with the
Decisions on approving the establishment of educational institutions and campuses.
2.3 Invested Capital (Article 28.6)
Article 28.6: The projects of investment in establishing higher education
institutions must reach at least 150 million VND per student (not including the expense
on land tenancy). The total minimum capital is calculated when the estimated education
scale is greatest, but must not be lower than 300 billion VND.
This provision lacks clarity and creates confusion for investors.

7. Education and Training Working Group – Position Paper Vietnam Business Forum: December 2015
Page 7 of 14
Recommendations
• It is requested that the total invested capital to be calculated based on the total
number of full-time equivalent students, instead of basing it on the time when the
estimated education scale is greatest. In reality, the total education and training
capacity can be 3 times greater than the total number of full-time equivalent students.
• In addition, the total invested capital for the project will be disbursed through each
stage of the project’s expected implementation. Thus, the invested capital must be
registered on the investment certificate based on each implementation stage.
2.4 Conditions for approving educational activities (opening a new degree program)
The establishment of disciplines of university and college is prescribed in Circular No.
08/2011/TT-BGDDT dated February 17, 2011 of the Ministry of Education and Training
stipulating conditions, dossiers, procedures for opening disciplines of training university,
college level. However, this regulation on establishing disciplines is very complicated and
not in accordance with foreign-invested educational institutions.
Recommendations
• It is proposed that there should be separate regulations on establishing educational
disciplines of foreign-invested educational institutions.
• We respectfully request to make the guiding regulations of Decree 73 clear in term of
establishing new facilities for foreign educational institutions to come under one set
of separate regulation OR, as an alternative, to come under the existing regulations on
establishing new facilities under colleges and universities issued by the MOET.
2.5 Facilities and equipment (Article 29)
Not all students are present at campus at a single point of time. A student may register
from one to four courses per semester, and thus shall attend class for 3-12 hours per
week. Students will have to spend time for preparation and doing assignment that do not
require them to be present at the campus. Therefore, stipulating minimum land/floor
areas for students without taking into account the number of students present at the
campus at a point of time is not reasonable, and may bring higher costs to education
institutions that will then increase tuition fees.
Recommendations
• Minimum land/floor areas for students should not be specified in proportion to
number of students. Decree 73 should be amended to provide that the minimum
land/floor areas for students should be in proportion to the maximum number of
students present at the campus at a point of time, and not simply in proportion to
number of students.

8. Education and Training Working Group – Position Paper Vietnam Business Forum: December 2015
Page 8 of 14
Furthermore, the facilities and equipment requirements on non-state higher education
student ratio etc. may become an increasing challenge with land pressures. Therefore,
we suggest greater transparency in how the specific ratios were determined; perhaps
this ratio could be lowered.
2.6 The lack of a legal framework for extension of operation term of educational
institution
Decree 73/2012 regulated that if the educational institution registers its operation term for
more than 20 years it must meet the condition of construction its own buildings. There is
no requirement of construction its own buildings if it registers for less than 20 years.
However, the decree does not mention the situation where the operation term of the
educational institution has expired. In this case, the licensing authority will add the
previous term to the extended term, and is the total is greater that 20 years then the
conditions of construction of its own building will apply. This is deemed very unfair and
needs to be revised.
Recommendations
• We respectfully request the MOET to amend Article 29.6 of Decree 73 as follows: A
foreign-capitalized educational institution that register or applies for extension of
operation’s license for less than 20 years do not have to build their own facilities.
• The amendment to Decree 73 should add more regulations on registering extension
the operation term is less than 20 years, will not require construction of its own
buildings.
2.7 The teaching staff (Article 31)
2.7.1 Minimum qualification of instructors
We are very much concerned about requirements for teaching staff being too
high/challenging for some transnational education delivery especially:
o For tertiary education institutions, 60% of course modules must be delivered by
permanent teachers, and 80% of teaching staff must hold postgraduate degrees.
o Article 10.2.b. mandates the minimum qualification of instructors at college
level to be a master degree.
Recommendation
• We respectfully request the Ministry and the Government to re-consider
amending this clause to reflect the reality that professional instructors in a
range of fields may not have post graduate education. However, they earn
their expertise and mastery through years of practicing, which may be
certified by a professional association. Their instruction is indispensable to
the students in the program. Examples of those fields include culinary art,
performing art, and fashion design amongst others

9. Education and Training Working Group – Position Paper Vietnam Business Forum: December 2015
Page 9 of 14
2.7.2 Years of teaching experience of foreign lecturers
A number of foreign lecturers are highly experienced experts in their professions,
especially in design, fashion and textile programs. However, they do not possess 5
years of teaching experience in the same teaching area. As the requirements for
study in those programs have increased, we have tried hard to find appropriate
candidates with 5 years of teaching experience in the same teaching area, but still
are not be able to recruit sufficient lecturers meeting these requirements
Recommendation
• It is recommended that Decree 73 be amended to decrease number of years of
teaching experience of foreign lecturers in special teaching areas such as
design (digital media), fashion (merchandise management) to less than 5 years.
The combination of experience and qualifications in the relevant field should
be considered.
2.7.3 Requirements for recruitment of English language teachers
As with the case of foreign lecturers in special teaching areas as mentioned above,
the recruitment of English teachers has been difficult due to scarcity of supply in
the Vietnamese market. In reality, very few English teachers possess Bachelor
degrees in linguistics or English language teaching (as required by Decree 73).
Moreover, we need to recruit seasonal or part-time English teachers who are
currently teaching at some other foreign language centres, as long as they meet
our qualification requirements. Even though they have already obtained work
permits to teach at other centres, we must also submit another complete work
permit application package for obtaining another work permit for such sessional
or part-time English language teachers (as required by Decree 102). Such
regulations and administrative procedures have been very time consuming and
costly for our operations.
Recommendations
Our recommendations are as follows:
• Recruitment of English teachers who possess Bachelor degrees in any field of
study (not necessarily in linguistics or English language teaching), as long as
they are native English speakers; and
• Part-time or sessional English language teachers to use one work permit to
teach at multiple schools or language centres.

10. Education and Training Working Group – Position Paper Vietnam Business Forum: December 2015
Page 10 of 14
2.8 The lack of a legal framework on operation area of foreign-invested educational
institutions after obtaining the operating license and starting operations
Currently, there is only Decree 73/2012/ND-CP governing INVESTMENT but there is no
clear regulations in place at this time governing the OPERATIONS of schools. Therefore,
during the operations of educational institution, it is not clear of what regulation will be
applied.
With regard to the appointment and recognition of a school principal, different authorities
have different opinions. Some authorities have asked that the principal is required to be
registered and formally recognized while others advised that there is no need to for formal
recognition when it is autonomic decision of school.
Recommendation
• We recommend having transparency and clarity in the legal documents that regulate
the operation area of foreign-invested educational institutions. Furthermore, there
should be a clear classification between foreign-invested educational institutions and
100% Vietnamese institutions to avoid misunderstanding and wrong application.
Without the clarity, it will be difficult for state authorities to manage effectively the
area of foreign-invested educational institutions.
2.9 The limitation on the percentage of Vietnamese students. (Article 24)
The limited percentage 10%, 20% of Vietnamese students allowed to join international
schools as per provided in Article 24 of Decree No.73 are extremely unreasonable because
of some reasons:
o The demand of Vietnamese students to study in international schools is increasing
exponentially. If the Government does not allow them to join international schools in
Vietnam, they will go overseas to study. In fact, the number of Vietnamese students
going overseas to study is increasing annually with currently more than 110,000
students in 47 countries with the school fees between USD 30,000 to USD 40,000 per
year. Vietnam is exporting about USD 3 billion every year for education.
o Foreign investment in education is very limited especially in the second-tier cities and
provinces in Vietnam. This is because of the 10%/20% rule regarding the number of
Vietnamese students allowed to join international schools based on the number of
foreign enrolled students. If the foreign invested institutions have no foreign students,
then no Vietnamese students can enrol. The fact is almost all cities and provinces apart
from Hanoi and Ho Chi Minh where have a few foreigners come to work and live, it
seems having no foreign students for enrolment, it shall have no Vietnamese students
are allowed to study. As consequence, foreign investment in education is closed to
second-tier cities and provinces in Vietnam.
Recommendation
o The quality of the Vietnamese education system needs to improve and to achieve this
the presence of foreign investment in education is very necessary. The Government
should end this limitation but add more conditions to ensure that Vietnamese students in
international schools to learn and retain their Vietnamese culture and traditions.

11. Education and Training Working Group – Position Paper Vietnam Business Forum: December 2015
Page 11 of 14
2.10 Hospitality education
We also respectfully request the Ministry to add new clauses to address the absence of a legal
framework to allow a university to operate a commercial restaurant or hotel as a practicum
facility where full time training takes place. This format of hospitality education enables students
to conveniently and smoothly learn theory, to practice with real customers, and to return to
theory afterwards. This format requires the learning environment to be the same as the practical
one, where real customers are served. There is a great need for teachers with experience in the
field and that students have the opportunity to practice in the field to become work-ready
graduates.

12. Education and Training Working Group – Position Paper Vietnam Business Forum: December 2015
Page 12 of 14
3. Technical and Vocational Education and Training (TVET)
In order to improve the Vietnamese economy and to take advantages of the opportunities from
membership of the AEC and TPP, Vietnam will need a high-skilled workforce. The Vietnamese
Government has put vocational skills training and boosting employment at the heart of its
development goals. Its plan is that by 2020, trained skilled workers will make up 55% of the
labour force. The Government also wants to tailor its vocational training more to the needs of the
business community, so it is promoting the expansion of vocational education and training
provision and improvements in the quality and needs-based focus of training. The Government
also wants to tailor its vocational training more to the needs of the business community, so it is
promoting the expansion of vocational education and training provision and improvements in the
quality and needs-based focus of training.
3.1 Meeting industry needs
In order to reduce the mismatch of skills demand and supply at the technician level,
Technical and Vocational Education and Training (TVET) institutions should make more
effort to improve training programs by carefully analysing the needs of industry. This will
ensure that graduates from TVET institutions have the skill sets required by industry both
now and in the future.
To accomplish this would require coordination between the MOET, MOLISA, TVET
institutions, Industry and also the involvement of initiatives funded by foreign
governments. The Vietnam Development Partnership Forum (VDPF) TVET sector
network organized by GDVT would also be able to provide support here in addition to
other areas of TVET activities.
Recommendation
It is recommended that the skills needs of Vietnamese industry be identified to provide the
TVET institutions with the market knowledge they need to develop appropriate curriculum for
the market. The colleges should be involved in identifying the needs of industry to meet local
demand and have autonomy to link more closely with industry.
3.2 Building the capacity of TVET Institutions
In addition to identify in the needs of industry the capacity of the TVET institutions needs
to be raised in order to provide them with the capability to meet the needs identified in 3.1
above. Areas including the following need to be addressed:
o Organization and Management
o Vocational Teachers and Teacher Development
o Quality Assurance and System Accreditation
o Curriculum development
o National Skills Standards and Certification
o Assessment and Certification

13. Education and Training Working Group – Position Paper Vietnam Business Forum: December 2015
Page 13 of 14
There are already a number of initiatives underway including the following:
o The Vietnamese Skills for Employment Project (VSEP) - Canada
o Vietnamese - German Programme Reform of TVET in Viet Nam
o Japan International Cooperation Agency (JICA)
o The Higher Engineering Education Alliance Program (HEEAP) - USA
Recommendation
• It is recommended that the Vietnamese Government liaise with the various initiatives
mention above and other initiatives to have a coordinated approach to the capacity build
of the TVET institutions. It would also help the various projects focus on their outcomes
while taking into account the outcomes of the other initiatives. It would also help reduce
overlap.
• The Vietnam Development Partnership Forum (VDPF) TVET could help with this
coordination work.
3.3 Attracting students into TVET institutions
One of the issues facing TVET institutions is the fact that high school students want to go
directly into University. In addition, it is now easier to enter University due to the lower
entry requirements. University degrees are held in high regard even though many graduates
with University certificates are unable to find relevant work.
The formulation of a single articulation system for Vietnamese education would also help
to make TVET more attractive. The reform of the TVET system needs a coordinated,
articulated approach so that students’ training is not dead-ended and they ‘system’ as a
coordinated whole will attract high-achieving students into careers with a future.
Recommendations
• In order to persuade more high school students to become interested in vocational
training programs, it is suggested that the Government should improve the paths that
vocational college graduates can use to transfer to university courses. It is
recommended that the Vietnamese Government continue working on a National
Qualifications Framework (NQF) so that students undertaking studies at TVET
institution can have this study officially recognised. This will also provide TVET
students with recognition for prior learning if they want to continue their studies at
University.
• Industry also needs to work with TVET institutions so that students graduating from
TVET institutions, with work ready skills are given recognition by industry for having
these skills.
• It is recommended that MOET and MOLISA work together to develop a single
articulation system for Vietnamese education.

14. Education and Training Working Group – Position Paper Vietnam Business Forum: December 2015
Page 14 of 14
4. Other Issues
4.1 Overseas/Online Learning
The Vietnamese regulatory environment makes it difficult for students to gain recognition
for overseas qualifications delivered in Vietnam part online (i.e. blended learning modes)
even though these qualifications are issued by the overseas university as meeting all the
same quality assurance requirements as the same courses delivered by 100% face-to-face
mode.
In Australia, for example, where there is a robust quality assurance system in place, a
university must satisfy the national regulator TEQSA that blended courses leading to an
Australian qualification meet the course accreditation standards and are equivalent
wherever the qualification is delivered regardless of delivery mode. Online/blended
delivery is an emerging global trend and is a cost-effective, flexible and innovative way to
deliver quality education. It can help Vietnam improve access to quality education and
overcome challenges such as an imbalance in the level of development in different regions
of the country.
Recommendation
• The VBF would like to see greater flexibility in the regulation to allow the Vietnamese
Government assess applications for course accreditation from Foreign education
providers to deliver courses with an online component and to recognise the
qualifications of students undertaking such courses.
5. Conclusion
The Vietnamese economy continues to grow and this is of benefit to the citizens of Vietnam.
With membership of the TPP and AEC Vietnam has a great opportunity to grow it economy and
become an even more prosperous nation. To achieve this Vietnam needs a highly competent
workforce with the knowledge and skills to drive growth in the economy.
Quality education and training is required to provide the skilled workforce to maintain this
growth. We have focused on two main areas in this paper that will help Vietnam to raise the
quality of its education. Through effective legislation and a robust TVET system Vietnam will
continue to prosper and take advantage of the many opportunities coming its way.
As mentioned in our introduction this would require the combined efforts of relevant
stakeholders working closely together to find effective solutions. The Education and Training
Working Group, through the VBF, will continue with its commitment to assist Vietnam in
achieving it economic potential.
We look forward to seeing progress in the above areas and again would like to thank the VBF for
inviting us to contribute to this important forum.