Vietnam: Decree No. 90/2026/ND-CP on Healthcare Administrative Penalties

On 30 March 2026, the Government of Vietnam issued Decree No. 90/2026/ND-CP governing administrative sanctions in the healthcare sector, replacing previous regulations, notably Decree 117/2020/ND-CP.

The Decree has taken effect since 15 May 2026.

For medical devices, Articles 71 to 80 establish administrative violations and penalties covering key activities across the entire product lifecycle.

Read the full decree here: Decree No. 90/2026/ND-CP on Healthcare Administrative Penalties in Vietnamese

Purpose of the Decree

To establish updated administrative sanctions in the healthcare sector in Vietnam.

To introduce a stricter penalty framework for violations related to medical devices and other healthcare activities.

Scope of Application

For medical devices, the Decree applies to key activities across the product lifecycle, including:

  • Classification of medical devices
  • Manufacturing activities
  • Registration and market authorization
  • Trading and distribution
  • Importation
  • Declaration of materials containing narcotics/precursors
  • Technical consultancy services
  • Product information, including labeling and Instructions for Use (IFU)
  • Management and use at healthcare facilities
  • Inspection and inspection-related activities

Key Highlights

Articles 71 to 80 set out administrative violations and penalties for medical device-related activities in Vietnam.

The Decree introduces a comprehensive and stricter penalty framework, with fines ranging from VND 500,000 to VND 100 million, depending on the nature and severity of the violation.

In addition to monetary penalties, supplementary sanctions may apply, including:

  • Suspension of licenses or practicing certificates for 1 to 24 months
  • Suspension of business operations for 1 to 24 months
  • Confiscation of non-compliant products and related materials

Regulatory Focus Areas

The updated framework indicates increased enforcement focus on critical regulatory areas such as:

  • Classification accuracy
  • Registration compliance
  • Labeling requirements, including Vietnamese IFU
  • Post-market surveillance (PMS)

Implications to Clients

To mitigate regulatory risks, clients are advised to:

  • Review and validate all product classifications and registration status
  • Ensure full compliance of labeling and IFU with local Vietnamese requirements
  • Strengthen quality management and documentation systems
  • Implement or enhance post-market surveillance (PMS) procedures
  • Conduct internal compliance audits in preparation for potential regulatory inspections

Effective Date

15 May 2026

For Inquiries

For inquiries or support regarding medical device regulatory requirements in Vietnam, please contact sales@andamanmed.com.

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