Digital Signatures, Timestamps, And ID Codes In Electronic Labor Contracts

In the context of implementing electronic labor contracts in accordance with the provisions of Circular 08/2026, many enterprises may encounter difficulties as the new regulations impose a range of technical requirements on enterprises. Among these, digital signatures and timestamps are no longer optional tools but have become mandatory conditions for the system to issue an identification (ID) code when an enterprise opts to apply electronic labor contracts.

1. The role of digital signatures and seals

In the procedure of issuing identification (ID) codes and managing electronic labor contracts, digital signatures and timestamps play a critical role in ensuring the legality, integrity, and authenticity of the data. Specifically as follows:

Sealing and confirming the integrity of converted data:  For employment contracts converted from paper documents into an electronic format, the conversion log information must include a digital signature (a specialized digital signature or a public digital signature of the agency or organization performing the conversion) accompanied by a timestamp affixed to the file. This process serves to seal and verify the integrity of the file from the moment the conversion process is fully executed.

Supplementing the validity of previously executed contracts: For electronic labor contracts executed prior to July 1, 2026, digital signatures and timestamps are mandatory conditions for acceptance by the Platform. The eContract provider bears the responsibility of assisting employees and employers in reviewing and supplementing the digital signatures, as well as the timestamps affixed to the digital signatures of the executing parties, in order to qualify for data submission to the Platform to request an ID code.

Serving as mandatory criteria for the platform to inspect and approve ID code issuance: Upon receiving electronic labor contracts from eContract providers, the electronic employment contract Platform will conduct an automated inspection step prior to issuing an ID. Information regarding the timestamp affixed to the digital signature of the executing parties is among the core data that must be verified by the Platform (alongside identity authentication and data message certification information). In the event of an absence or failure to ensure the validity of such information, the Platform shall refuse to issue the ID code.

2. How are paper contracts converted to Electronic Formats Granted an ID Code?

The procedure for issuing an identification (ID) code for paper employment contracts converted into an electronic format is subject to strict tracking and verification requirements, specifically as follows:

Step 1: The eContract provider submits data and the “conversion log” to the Platform

The eContract provider is responsible for submitting the electronic employment contract along with related data to the electronic employment contract Platform. The most critical requirement for this type of contract is the mandatory submission of the conversion log information detailing the transition from a paper contract to an electronic contract.

The conversion log information must include:

• The name of the system or software performing the conversion.
• The full name and title of the individual, or the name of the organization performing the conversion.
• The date, month, year, and time the conversion was completed.
• The file format, file capacity (size), and the number of pages of the document.
• The digital signature (specialized or public) of the agency/organization performing the conversion, accompanied by a timestamp affixed to the file to seal and confirm the integrity of the data from the completion of the conversion.
• Confirmation from the system that the content of the converted copy has been inspected and entirely matches the original paper copy.

Step 2: The Platform receives, inspects, and issues the ID

Upon receipt of the data, the electronic employment contract Platform will inspect the information and automatically issue an ID within 24 hours from the time of receipt.

However, if a contract converted from a paper document is submitted without fully satisfying the aforementioned regulations (e.g., a missing conversion log or an invalid digital signature), the Platform shall refuse to issue the ID and automatically transmit a notification clearly stating the reason to the eContract provider’s system.

Step 3: Identification of specific ID codes

To facilitate categorization in management, upon successful ID issuance, electronic labor contracts converted from paper documents will be assigned the character “B” at the first position in the identification code sequence (subsequently followed by 12 numerical characters).

3. How will electronic labor contracts executed prior to July 1, 2026, be handled?

For electronic labor contracts executed prior to July 1, 2026, regulations concerning the review and supplementation of information are strictly enforced to ensure validity and synchronization during system management. Specifically as follows:

• Responsibility for review assistance: Electronic contract service providers (eContract) bear the responsibility of assisting employers and employees in conducting a review of the executed contracts.
• Mandatory content for supplementation: The review process aims to supplement vital technical and legal elements to the contracts on the eContract system, including: digital signatures, timestamps affixed to the digital signatures of the executing parties, and the data message certification of the eContract Provider.
• Procedure for submitting data for ID issuance: Only after the respective parties complete the review and fully supplement the aforementioned components is the eContract provider responsible for submitting the electronic employment contract and related data to the electronic employment contract Platform to request the issuance of an identification (ID) code.
• Identification characteristics: Upon successful ID issuance, the identification code of these contracts executed prior to July 1, 2026, will be assigned the letter “C” as the first character.
• Sanctions for non-compliance: In the event a contract executed prior to July 1, 2026, is submitted to the Platform but fails to ensure the review and supplementation of the aforementioned information (or if the identity authentication information is inaccurate), the Platform will automatically refuse to issue the ID and transmit a notification clearly stating the reason to the eContract provider’s system.
• Reporting responsibilities: The volume of contracts executed prior to July 1, 2026, that have been reviewed, supplemented, and submitted to the Platform constitutes a mandatory criterion that must be incorporated into the periodic or ad-hoc Service Provision Status Report that the eContract provider submits to the Ministry of Home Affairs.

The implementation of identification (ID) codes combined with digital signatures and timestamps pursuant to Circular 08/2026 unambiguously reflects the comprehensive digitalization trend of regulatory bodies. All data concerning Electronic labor contracts at present—ranging from newly signed contracts (code A), converted paper copies (code B), to older contracts (code C)—are automatically tracked and strictly governed within a 24-hour timeframe. This mechanism requires enterprises to move beyond a purely formalistic compliance approach. To prepare for the effective date of July 1, 2026, human resources and legal departments must proactively collaborate with eContract providers to perfect their digital signature systems, synchronize data structures, and standardize the conversion logging process. Early preparation of technical infrastructure is therefore essential to minimize the risk of ID issuance rejection and ensure legal continuity for the enterprise’s HR documentation system.

Time of writing: May 21, 2026

The article contains general information which is of reference value. In case you want to receive legal opinions on issues you need clarification on, please get in touch with our Lawyer  at  info@cdlaf.vn

You can refer for more information:

• Guidance on Issuing Identification Codes for Electronic Labor Contracts under Circular 08/2026/TT-BNV
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