Vietnam TRC Still Valid but Work Permit Expired or Passport Changed: What to Do

A Vietnam Temporary Residence Card (TRC) can carry an expiry date months in the future and still be unenforceable. Two events break the link the card depends on: the underlying work permit expires, or the passport on file is replaced. The card looks unchanged. The legal basis behind it does not.

This guide separates the two situations. The first is a foreign worker whose work permit has expired while the TRC still shows time on it. The second is a foreign worker who has a new passport, by renewal, damage, or a runout of pages, but a TRC linked to the old passport number. The paperwork is different. The risks are different. So is the recovery path.

For the wider picture of how work permits, LD2 visas, and TRCs fit together, see our guide to long-term stay options in Vietnam.

Scenario 1: Work permit expired, TRC still in date

1. Notify your employer in writing the day the gap is identified.
2. Stop all work. There is no grace period under Decree 12/2022/ND-CP.
3. Employer returns the expired work permit to the provincial Department of Home Affairs (DOHA) within 15 days, as required under Decree 219/2025.
4. Employer files a fresh work permit application using the integrated Form No. 03 dossier.
5. Refresh the criminal record certificate and health certificate if either has aged out.
6. With the new work permit in hand, the employer sponsors a new TRC application and you collect the card in person.

Scenario 2: Passport changed, TRC linked to the old one

1. Collect the new passport from your embassy or consulate in Vietnam.
2. Take both passports and your valid TRC to the provincial Immigration Management Office that issued the TRC.
3. Apply to transfer the residence record from the old passport to the new one. Pay the official transfer fee, currently USD 5 for transferring visa/TRC or temporary-residence validity from the old passport to the new passport.
4. Allow up to 5 working days for processing.
5. Ask your employer to file a work permit re-grant under Decree 219, since the permit also records the old passport number.

> This guide reflects work permit and immigration practice as understood in May 2026. Confirm current requirements with the Vietnam Immigration Department (Cục Quản lý xuất nhập cảnh) and the relevant Provincial Department of Home Affairs before acting.

Two Documents, One Passport Linking Them

A Temporary Residence Card (TRC) authorises your residence in Vietnam for a set period. It is issued by the Vietnam Immigration Department under the Ministry of Public Security. A labour TRC (symbol LD2) is issued to foreign workers who hold a valid work permit, with a maximum validity of two years.

A work permit authorises your employment for one specific employer in a specific role. Under Decree 219/2025/ND-CP, effective 7 August 2025, work permits are issued by the Provincial People's Committee. The PPC delegates the work to the provincial Department of Home Affairs (DOHA), which replaced the former DOLISA in the 2025 government restructuring.

The two documents are linked once at the point of application, then run on separate clocks managed by separate authorities. Both record your passport number. When either the work permit lapses or the passport is replaced, the records no longer match the card. The card itself does not change.

To live and work legally in Vietnam, a foreign national needs three current documents at the same time: a valid passport, a valid work permit, and a valid TRC (or visa). One does not substitute for another.

Why These Mismatches Happen

Why a work permit expires before the TRC

TRC validity is set when the card is issued, based on the work permit valid at that moment. The two documents are not synchronised after that. The most common cause of drift: the work permit was extended for a shorter period than expected at renewal, while the TRC stayed on its original two-year track. Another cause is passport-driven. A TRC must expire at least 30 days before the passport, so a short passport caps the card while the permit can still run longer.

The result is two documents with different end dates, issued by different agencies, tracked by neither unless the employer or the worker actively watches the calendar.

Why a passport changes while the TRC is still valid

Labour TRCs run up to two years. Passports run five to ten. But passports get replaced for non-expiry reasons: blank pages run out, the book is damaged, or another country's six-month-validity rule forces an early renewal.

When the embassy or consulate issues a new passport in Vietnam, the old one is cancelled (often visibly, by punching). The TRC, still physically intact, references a passport number that no longer exists in any active database. Vietnamese border officers check the passport number on the TRC against the passport presented at the gate. A mismatch creates problems on re-entry even when every other document is current.

Scenario 1: Work Permit Has Expired, TRC Still in Date

What the law says

Working without a valid work permit is treated as working without one at all. Vietnamese labour law sets no grace period: the day after expiry, the worker is unauthorised to work.

Under Clause 3, Article 32 of Decree 12/2022/ND-CP, foreign workers found working without a valid permit face:

• A fine of VND 15,000,000 to 25,000,000 (about USD 600 to 1,000), and
• Mandatory deportation as a supplementary penalty.

The TRC's printed expiry date provides no protection from these penalties.

The employer is exposed separately. Under the same decree, fines for hiring foreign workers without valid permits scale by the number of unlicensed workers:

• 1 to 10 workers: VND 30,000,000 to 45,000,000
• 11 to 20 workers: VND 45,000,000 to 60,000,000
• 21 or more workers: VND 60,000,000 to 75,000,000

For organisations, the fine doubles.

What you can and cannot do

While the work permit is expired but the TRC remains in date, you are in a grey area. In practice:

You can usually:

• Stay in Vietnam, since the TRC may still be accepted day to day for residence purposes, though its legal foundation is compromised
• Exit Vietnam, since the TRC is typically accepted at departure, though re-entry carries real risk if the underlying permit has been formally cancelled
• Handle personal and paperwork tasks that do not involve employment

You cannot:

• Continue working for your employer in any paid capacity
• Take new paid work without first holding a valid work permit
• Represent the employer in any role that counts as active employment

Bank access can be restricted. Under Circular 17/2024/TT-NHNN, Vietnamese banks check the residency status of foreign account holders. Expat forums consistently report that once a work permit lapses, some banks flag the account, hold larger outgoing transfers, or ask for updated documents before releasing funds. The pattern is not universal across banks, but it is widely reported. Contacting your bank with evidence that a new permit application is in progress can prevent the disruption from compounding. For the wider account-opening and document-check issue, see our guide to Vietnam banking for foreigners.

Management roles can blur the line between employment and incidental activity. If you hold a director or legal representative position, ask a local employment lawyer which actions remain permitted while the permit is being refiled.

Scenario 2: New Passport, TRC Linked to the Old One

If you are still in Vietnam

The simpler path. The new passport must have been issued by your embassy or consulate in Vietnam, and you must not have left the country since receiving it. With both conditions met, you can apply to transfer the residence record from the old passport to the new one.

Take both passports and your valid TRC to the provincial Immigration Management Office (phòng quản lý xuất nhập cảnh) where the TRC was issued. The official immigration fee schedule under Circular 28/2026/TT-BTC (effective 1 April 2026, replacing Circular 25/2021/TT-BTC) includes a transfer fee for moving residence validity from one passport to another. The Ministry of Public Security e-services page lists this transfer fee as USD 5. Official processing is up to 5 working days.

Community and practitioner sources consistently report three conditions for the transfer to be accepted:

• The TRC must still be in validity
• The new passport must have been issued in Vietnam (not abroad)
• You must not have exited Vietnam between receiving the new passport and requesting the transfer

These conditions are not laid out in a single official source, but they appear repeatedly across expat forums, practitioner guides, and first-hand accounts. When all three are met, the transfer is handled as a routine record update, not a new TRC application. Some agents quote VND 4,000,000 or more, which applies to a full new TRC application, not to this transfer.

If you have already left Vietnam or renewed your passport abroad

Community sources consistently say the transfer option closes once you exit Vietnam. Returning on a new passport with the old TRC inside the cancelled passport is not a reliable entry route.

Some travellers report that immigration officers at the airport will accept both passports together, clip the corner of the old TRC, and stamp a short entry (typically 30 to 45 days) into the new passport. The practice is inconsistent. Others report being refused entry or hitting problems later when trying to convert that short stamp into a proper visa or TRC.

One recent account from Nha Trang traces the risk. A foreigner entered on a new passport with the old TRC, received a clipped TRC and a one-month stamp, then could not get a new TRC processed locally despite three visits. At departure, the immigration officer questioned the arrangement and only released the traveller after discussion. The next step was to re-enter on an e-visa and start the TRC process from scratch.

The reliable path: enter Vietnam on a new visa. Your employer can sponsor a DN1 business visa, or you can apply for an e-visa before travelling. Once inside Vietnam on a valid visa in the new passport, the employer files for a new TRC. This is a full application, not a transfer. The standard TRC fee under Circular 28/2026/TT-BTC (USD 145 for a card valid up to two years) and the full document set apply.

What happens to your work permit

A passport change also affects the work permit, since the permit records the old passport number. Under Decree 219/2025, this is a re-grant case, not a new application. The permit is still valid; only the identifying details have changed.

The employer files a re-grant dossier reflecting the new passport number using the forms published with Decree 219. In Ho Chi Minh City, the government fee for this re-grant is VND 0 under provincial Resolution 07/2024/NQ-HDND. Filing is online through dichvucong.gov.vn with a 3 to 5 working day turnaround from receipt of a complete re-grant dossier. Other provinces set their own rates, so confirm before filing.

If the employer skips this step, you hold a valid permit that references a passport you no longer use, which recreates the same database mismatch the TRC transfer was meant to fix. Handle the work permit re-grant and the TRC transfer as one coordinated process, not in sequence.

Step-by-Step: New Work Permit and New TRC After an Expiry

This section applies only to Scenario 1, where the work permit has already expired. For a passport change with a still-valid permit, follow Scenario 2 above.

Step 1: Notify your employer immediately

A foreign employee cannot apply for their own work permit. The employer drives the filing. Raise the expiry in writing the day it is identified. The paper trail matters if a labour dispute follows.

Under Decree 219/2025, a work permit extension can only be filed while the permit is still valid, between 10 and 45 days before expiry. Once the permit has expired, the extension window has closed. Re-grant under Decree 219 covers permits that are still valid but with changed details. An already-expired permit means the route is a fresh work permit application.

Decree 219 also requires the employer to return the expired permit to the provincial Department of Home Affairs within 15 days of expiry. This is a compliance requirement, not optional. The revocation and the new application run in parallel.

If your employment is ending rather than continuing, confirm the close-out steps with both HR and immigration before you travel. Under Decree 219, the employer must recover the work permit and submit it to the issuing authority within 15 days after the permit ceases to be effective, with a report on the revocation. The TRC cancellation or replacement step should be confirmed with the provincial Immigration Management Office, because it is handled under the immigration file rather than the work permit file.

Step 2: Apply for a new work permit

Because the previous permit has already expired, this is a new application, not a renewal. Under Decree 219:

• The employer submits a single integrated dossier on Form No. 03, which combines the demand justification with the work permit application. This replaced the two-step process under Decree 152.
• Standard processing is 10 working days from receipt of a complete dossier.
• A written refusal, if issued, must come within 3 working days.
• Submission goes to the provincial Department of Home Affairs in the province where the employee will work.
• An online joint route through dichvucong.gov.vn lets a Vietnam-issued criminal record certificate be processed alongside the permit.

Two documents carry validity windows that catch people out after a gap:

• Vietnam criminal record certificate for foreigners: valid within 6 months of the application date. The one from the original work permit file is almost certainly expired.
• Health fitness certificate: valid within 12 months, issued by an authorised Vietnamese or foreign health facility.

For foreign-issued criminal record certificates, allow time for consular legalisation and Vietnamese translation. This is the step that most often delays the file.

Work permits are not transferable between employers. If the role or company has changed, the new application must reflect that. If the new role uses a different title, category, or qualification basis from the old permit, ask HR to check the Vietnam work visa degree and experience mismatch guide before filing. A fresh application can fail if the degree, experience letters, job title, and Decree 219 category do not line up.

Work permit fees are paid by the employer and vary by province. Work permit re-grant fees are set locally and should be confirmed with the relevant provincial Department of Home Affairs before filing. Do not rely on older Ho Chi Minh City fee (VND 0) schedules unless the current public-service portal or a current provincial resolution confirms the same amount..

Step 3: Apply for a new TRC

Once the new work permit is in hand, the employer files a new TRC application. An expired TRC cannot be renewed. A fresh application is required. Even if the existing TRC has not reached its printed expiry, do not wait for it to lapse before filing.

In Ho Chi Minh City and Hanoi, TRC applications are filed online through the Ministry of Public Security e-portal (e-services.mps.gov.vn) or the National Public Service Portal, with hard copies delivered afterwards. The employer's authorised representative uses a company digital signature to submit.

Required documents:

• Sponsorship letter from the employing company (Form NA6)
• TRC application form NA8, with a fresh passport-size photo (2 by 3 cm, white background, taken within 6 months)
• New work permit (original)
• Original passport with at least 13 months of validity remaining
• Current or expired TRC for reference at submission

Supporting documents:

• Certified copy of the company's business registration certificate
• Certificate of seal registration or equivalent verification

Translation and legalisation: foreign-language documents must be consularly legalised and translated into Vietnamese unless exempted under a treaty.

Processing time and fees: standard processing is up to 5 working days from receipt of a complete dossier. The state fee under Circular 28/2026/TT-BTC is USD 145 for a card valid up to two years. The new TRC's duration cannot exceed the validity of the new work permit, and must expire at least 30 days before the passport.

You attend the immigration office in person to collect the card. The employer's representative cannot collect on your behalf.

Practical Notes From the Ground

The Decree 219 framing matters when filing. Some HR teams still describe an expired-permit refile as a "renewal." Under Decree 219, extension is only possible before expiry, and re-grant is only for valid permits with changed details. An expired permit means a fresh application. The legal framing affects the dossier and the employer's compliance record.

If your former employer holds your physical TRC, act immediately. This pattern is documented: the employment relationship ends, but the company keeps the card. You cannot present the TRC at border control without it. If you cannot retrieve the card, report the situation to the Vietnam Immigration Department and ask whether an exit visa can be issued while the matter is resolved. Do not attempt international travel without either the TRC or an exit visa.

An exit visa can buy a legal departure window. If you find yourself in country with no valid permit and no clear route forward, the Vietnam Immigration Department can issue an exit visa allowing a defined departure window (commonly 15 days). It does not authorise re-entry. Processing normally runs 5 to 7 working days and is usually handled with employer assistance.

Plan bank access before the document gap. If your employment is ending, update your bank with the new passport/TRC or move essential funds before the work permit or TRC is cancelled or expires. Banks may restrict transactions when the documents in the account file are no longer valid. Community reports also mention tax-refund and social-insurance payments arriving after a TRC expires, which can create access problems if the account is already limited.

Employer-side delay is the most common cause of avoidable gaps. This pattern is consistent across expat communities. The employer is the applicant, and HR processes inside Vietnamese companies are not always tuned to foreign-document timelines. A written notice naming the expiry date sharpens the urgency and protects you if a dispute arises.

> Confirm current fees, document requirements, and processing timelines directly with the relevant Provincial Department of Home Affairs and the Vietnam Immigration Department before submitting. Under Decree 219/2025, the work permit authority sits with the Provincial People's Committee, delegated to the Department of Home Affairs (formerly DOLISA) after the Ministry of Labour, Invalids and Social Affairs (MOLISA) became the Ministry of Home Affairs (MOHA) in the 2025 government restructuring.

Key Sources

• Vietnam Immigration Department, xuatnhapcanh.gov.vn
• Ministry of Public Security Public Services Portal, e-services.mps.gov.vn
• National Public Service Portal, dichvucong.gov.vn
• Decree 219/2025/ND-CP (effective 7 August 2025), replacing Decree 152/2020 and Decree 70/2023
• Circular 28/2026/TT-BTC (effective 1 April 2026), entry, exit, transit, and residence fees, replacing Circular 25/2021/TT-BTC
• Ministry of Home Affairs (moha.gov.vn), formerly the Ministry of Labour, Invalids and Social Affairs