7 Changes in Trade Union Fee Contributions from May 16, 2026 That Businesses Need to Know

Date: 2026.06.09

7 Changes in Trade Union Fee Contributions from May 16, 2026 That Businesses Should Note

From May 16, 2026, Decree No. 105/2026/ND-CP officially takes effect, adding several new regulations related to trade union fee contributions. These changes directly affect enterprises, cooperatives, cooperative unions, and certain public service units, especially regarding payment deadlines, late payment, non-payment, exemption, reduction, and temporary suspension of trade union fee contributions.

Compared with Decree No. 191/2013/ND-CP, Decree No. 105/2026/ND-CP provides more specific and detailed regulations on the obligation to contribute trade union fees, while also adding support mechanisms for businesses facing difficulties. Below are 7 important changes in trade union fee contributions from May 16, 2026 that businesses should pay attention to.

1. Payment deadline for trade union fees clarified as no later than the last day of the following month

One of the notable new points under Article 4 of Decree No. 105/2026/ND-CP is that the deadline for paying trade union fees is clearly specified.

Under the new regulation, if an enterprise pays trade union fees on a monthly basis, the payment deadline is no later than the last day of the following month. If the enterprise pays once every 3 months, the deadline is the last day of the month immediately following the contribution cycle.

For enterprises operating in agriculture, forestry, fishery, salt production, and paying salaries according to production or business cycles, they may still choose to pay trade union fees monthly or once every 3 months, provided that they register with the trade union organization.

Previously, Decree No. 191/2013/ND-CP only stipulated that enterprises must pay trade union fees once a month at the same time as compulsory social insurance contributions, but did not clearly specify the final deadline for completing the payment obligation.

2. Late payment and non-payment of trade union fees are clearly defined for the first time

Article 6 of Decree No. 105/2026/ND-CP adds specific regulations on late payment and non-payment of trade union fees.

Accordingly, late payment of trade union fees refers to cases where an enterprise has not paid or has not fully paid trade union fees after the prescribed deadline.

Notably, the new Decree also clearly identifies cases considered as non-payment of trade union fees, including:

This is an important new point because Decree No. 191/2013/ND-CP previously did not contain specific regulations distinguishing late payment from non-payment of trade union fees.

3. Exemption mechanism added for dissolved or bankrupt enterprises

Decree No. 105/2026/ND-CP adds Chapter IV, which regulates exemption, reduction, and temporary suspension of trade union fee contributions. In particular, Article 11 provides that enterprises, cooperatives, and cooperative unions undergoing dissolution or bankruptcy may be considered for exemption from unpaid trade union fees.

In the case of dissolution, exemption from trade union fees may be considered when the trade union participates in the enterprise’s debt settlement plan.

In the case of bankruptcy, exemption may be considered when the trade union submits a request for application of bankruptcy procedures.

Compared with the previous regulation, this is a completely new provision. Decree No. 191/2013/ND-CP did not provide any regulation on exemption from trade union fee contributions for enterprises undergoing dissolution or bankruptcy.

4. Businesses facing difficulties may receive up to a 20% reduction in trade union fee contributions

Under Article 12 of Decree No. 105/2026/ND-CP, enterprises facing special difficulties may be considered for a reduction of up to 20% in trade union fee contributions after the temporary suspension period has ended.

The conditions for reducing trade union fee contributions are determined based on the rate of workforce reduction, specifically:

– A reduction of at least 30% of employees, or at least 30 employees, for units with fewer than 200 employees;

– A reduction of at least 50 employees for units with 200 to 1,000 employees;

– A reduction of at least 100 employees for units with more than 1,000 employees.

The reduction period must not exceed 6 months.

This is also a noteworthy new point because Decree No. 191/2013/ND-CP did not previously provide a mechanism for reducing trade union fee contributions for businesses facing difficulties.

5. Temporary suspension of trade union fee contributions for up to 12 months

Another important change is that Article 13 of Decree No. 105/2026/ND-CP adds a mechanism allowing enterprises facing difficulties to temporarily suspend trade union fee contributions.

Enterprises may be considered for temporary suspension if they face difficulties due to restructuring, technology changes, economic crisis, natural disasters, fire, epidemics, or crop failure.

Specifically, enterprises may be considered for temporary suspension in the following cases:

– They must suspend production or business operations for 30 days or more, and at least 50% of employees subject to compulsory social insurance must temporarily stop working; or

– They suffer damage exceeding 50% of the total asset value due to natural disasters, fire, epidemics, or crop failure.

The maximum temporary suspension period for trade union fee contributions is 12 months.

Previously, Decree No. 191/2013/ND-CP did not contain any regulation on temporary suspension of trade union fee contributions in cases where enterprises face difficulties.

6. New regulation on allocation of trade union fees to employee organizations at enterprises

Decree No. 105/2026/ND-CP adds Chapter V on the management and use of trade union fees by employee organizations at enterprises under the 2019 Labor Code.

Under the new regulation, employee organizations at enterprises that are granted registration under Article 172 of the 2019 Labor Code will be allocated the portion of trade union fees intended for the grassroots level. The allocation is based on the proportion of members of such organizations participating in compulsory social insurance.

In addition, employee organizations at enterprises must periodically notify the amount actually paid by the enterprise. If they fail to submit the notification on time without a legitimate reason, the allocation of trade union fees to such organizations may be temporarily suspended.

This is a new regulation compared with Decree No. 191/2013/ND-CP, which previously did not regulate employee organizations at enterprises or the mechanism for allocating trade union fees to such organizations.

7. Expanded regulations on funding sources for trade union fee contributions by financially autonomous public service units

Under Article 5 of Decree No. 105/2026/ND-CP, the funding sources for trade union fee contributions by financially autonomous public service units are specified in greater detail.

Specifically:

Public service units that partially cover their regular expenditures may use the state budget, service revenue, and other lawful revenue sources to pay trade union fees;
Public service units that cover both regular expenditures and investment expenditures, or that cover regular expenditures themselves, shall pay trade union fees from revenue generated from service activities and other revenue sources.

Previously, Decree No. 191/2013/ND-CP only provided general regulations on funding sources for trade union fee contributions by units whose regular operating expenses were fully or partially covered by the state budget. The new regulation classifies funding sources more clearly according to each unit’s level of financial autonomy.

Conclusion

From May 16, 2026, trade union fee contributions will be subject to several important new changes under Decree No. 105/2026/ND-CP. Enterprises should pay particular attention to the new regulations on payment deadlines, late payment, non-payment, exemption, reduction, temporary suspension, and allocation of trade union fees to employee organizations at enterprises.

Understanding these changes will help enterprises proactively review their trade union fee contribution obligations, reduce compliance risks, and prepare appropriate solutions when facing difficulties in production or business operations.