RO licence revocation triggers

In plain termsA representative office (RO) licence dies from misuse and from neglect. Decree 07/2016 plus practice: revenue activity, scope breach, inactivity, false filings, and skipped closure. Revocation is worse than a planned close because you lose the orderly tax–bank sequence.

Start here — three checks

Audit the last 12 months of RO activity against the permitted list
If the office has been idle, decide close-now vs resume-with-proof. Drift is a trigger.
If you already invoiced or signed sales, treat revocation risk as live — convert or close, do not wait

Decision map

Signal	Lock now	If skipped
Revenue or customer contracts in the RO’s name	Stop the activity. Choose conversion or closure this month.	Inspectors revoke first; you negotiate later from a weaker seat.
No real operation, licence still on the wall	Idle licences get questioned. Start the 30-day closure or resume documented liaison.	Inactivity becomes the revocation story.
Chief of RO left Vietnam with no replacement	Appoint and file a new chief. An RO without a chief is a defective presence.	The licence is a shell with no responsible person.
Address on the licence is not the address you use	Amend or close. Ghost addresses are a classic trigger.	A visit finds an empty or unrelated premises.
Parent company itself dissolved or changed identity	Update the Vietnam file or close. The RO cannot outlive a coherent parent.	The licence names a person that no longer exists.

Scenario triage

Scenario	Looks safe	Real risk
Sales KPIs inside an RO that “mostly does liaison”	Most activity is still meetings.	One invoice stream is enough. Mixed use still reads as commercial.
Licence renewed on paper, office unused for a year	Renewal proved everything is fine.	Renewal is not an activity audit. Inactivity can still surface.
Second unofficial desk in another province	Just a colleague with a laptop.	You may have created a second RO without a licence, on top of the one-per-province rule.

Common wrong movesWhere people lose time on this exact question.

Waiting for an official warning before stopping sales.
Keeping a licence “in case we come back” with no chief and no rent.
Fighting revocation with a branding deck instead of a closure or conversion file.

If this fails, do this nextRecovery order — not a generic legal memo.

Stop the triggering activity the same week.
If the licence should end, enter the notice and tax–labour–bank sequence while you still can.
If the model is sales, start a company. Do not try to “cure” revocation by promising better liaison.

Published gapWhat we do not invent on this page.

Triggers are clear in kind (scope, inactivity, falsehood). We do not publish a province-by-province scoreboard of how many idle months equal revocation. If the office is fake or commercial, act.

Revenue-prohibited riskThe most common scope breach.One RO per provinceA setup constraint that also creates extra-office risk.Orderly closure sequenceLeave through the front door if you still can.

Common questions

What can get a Vietnam representative office licence revoked?

Operating beyond liaison (especially revenue), prolonged inactivity, false filings, no responsible chief, or a premises that does not exist. Planned closure is cleaner than waiting for revoke.

Is inactivity enough to lose the licence?

It is a known practice trigger. A licence with no office, no chief, and no work is not a cheap option. Close it or use it.

Can we keep the licence after a sales breach if we stop selling?

Stopping is mandatory. Whether the licence survives is an authority decision. Do not assume self-correction erases the file.