Vietnam AI Law represents a turning point in how artificial intelligence is governed in the country, introducing a structured, risk-based regime that directly affects both domestic and foreign businesses deploying AI in the Vietnamese market. As the new framework moves from legislative approval toward implementation, organizations that rely on AI will need to reassess their models, governance structures, and market strategies in light of these binding requirements.
This article examines the core features of Vietnam’s new AI regime, the policy rationale behind it, its impact on businesses and individuals, and the practical compliance measures that organizations should be putting in place now to prepare for enforcement and long-term regulatory scrutiny.
Regulatory Landscape
Core legal instrument and scope: The new Law on Artificial Intelligence establishes a comprehensive framework governing the research, development, provision, deployment, and state management of AI systems in Vietnam, applying to Vietnamese and foreign organizations and individuals engaged in AI-related activities within the country. It consolidates and replaces earlier AI provisions scattered in the Law on Digital Technology Industry, creating a single, unified baseline for AI governance and eliminating overlapping requirements.
Risk-based classification model: The legislation adopts a four-tier risk structure encompassing unacceptable, high, medium, and low risk AI systems. Unacceptable-risk systems, such as those that manipulate cognition or deploy large-scale facial recognition without lawful grounds, are prohibited. High-risk applications in sectors including finance, healthcare, education, transport, and justice are subject to strict pre-market controls, mandatory conformity assessments, and registration in a National AI Database. Medium-risk systems that interact with users or generate content must ensure transparency and clear labeling, while low-risk systems rely largely on self-regulation under general principles and post-market supervision.
Foundational principles and rights protection: The law embeds human-centrism, safety, transparency, accountability, and national digital sovereignty as guiding principles. It requires that AI serve humans rather than replace them in critical decisions, mandates meaningful human oversight, and provides avenues for individuals harmed by AI systems to seek redress under existing civil and product liability rules. This focus on human rights, national security, and social stability positions AI governance as part of a broader digital sovereignty agenda.
Regulators and governance structure: Oversight is centralized under the Government with the Ministry of Science and Technology acting as lead coordinating authority, supported by an inter-ministerial National Committee or Commission on Artificial Intelligence. This body will steer strategy, appraise major AI programs, and coordinate sector regulators. A National Artificial Intelligence Development Fund and a National AI Database will underpin monitoring, incentives, and registration. Official information and guidance are expected to be published on government portals such as the Ministry of Science and Technology’s website at most.gov.vn and the Government’s portal at chinhphu.vn.
Transparency, labeling, and content authenticity: Providers must ensure users are clearly informed when interacting with AI systems except in limited cases prescribed by law. Audio, image, and video content generated by AI must carry machine-readable markers distinguishing it from authentic, non-synthetic material, a measure designed to counter deepfakes and information manipulation. These obligations will require technical solutions integrated into model outputs and distribution pipelines.
Penalties and sanctions framework: The law introduces administrative fines that can reach substantial monetary levels for organizations, including percentage-of-revenue penalties for serious violations, alongside potential suspension or bans on AI operations. Depending on severity and consequences, entities and individuals may also face civil liability and, in some cases, criminal exposure for violations such as deploying prohibited AI systems or ignoring mandatory safeguards for high-risk applications.
Why This Happened
Strategic digital sovereignty and competitiveness: Vietnam’s AI legislation is driven by a desire to cement its position as a regional innovation hub while reducing dependence on foreign technologies. Policymakers see AI as critical infrastructure and aim to secure national control over data, computing, and algorithmic capabilities, aligning with broader digital economy and industrial policies.
Global regulatory convergence and lessons: The framework reflects influences from the EU AI Act and other leading regimes, with risk-based categorization, prohibited practices, and strong transparency obligations. At the same time, it is tailored to Vietnam’s security, cultural, and development priorities, emphasizing social order, national security, and human dignity alongside innovation.
Escalating risks and governance gaps: Rapid expansion of AI use in finance, healthcare, public services, and social media has heightened concerns about deepfakes, bias, privacy breaches, and systemic vulnerabilities. Existing sectoral and digital laws were seen as fragmented and insufficient; the new AI regime responds by filling those gaps with horizontal, technology-specific rules and harmonized oversight.
Timing and enforcement readiness: The phased timeline for the AI law’s effect allows time to establish the National AI Database, issue implementing decrees, and prepare regulators and businesses for the rollout of full obligations, particularly for high-risk systems, signaling a deliberate but firm shift from soft guidance to binding, enforceable rules.
Impact on Businesses and Individuals
Rewiring risk management and governance: Organizations that develop, provide, or deploy AI in Vietnam must now integrate AI-specific governance into their enterprise risk frameworks. Boards, executives, and technical leaders will need to understand their regulatory role (developer, provider, deployer) and the associated duties across the AI lifecycle, from design and training to deployment and decommissioning.
Operational and financial implications: For high-risk AI systems, new conformity assessments, technical documentation, and registration processes introduce additional costs, timelines, and operational constraints. Medium-risk systems face more modest but still meaningful obligations for transparency, user notices, and logging. Low-risk AI remains comparatively flexible but subject to monitoring and potential reclassification as risks evolve.
Heightened liability and enforcement exposure: Companies face administrative fines, revenue-based penalties, and reputational damage for non-compliance, especially if they deploy prohibited systems or neglect risk management duties. Individuals harmed by AI systems have clearer grounds to claim compensation, increasing litigation and insurance considerations. For foreign providers, failure to appoint an effective local representative can result in enforcement difficulties and market-access challenges.
Consequences for individuals and society: Users gain greater clarity about when they are dealing with AI and better protection against manipulative or privacy-intrusive technologies. At the same time, individuals involved in AI projects—from data scientists to product managers—bear more explicit professional responsibility, as governance structures assign accountability for compliance decisions and incident handling.
Sector-specific disruption and opportunity: Industries that rely heavily on automated decision-making, such as financial services, healthcare, recruitment, and education, will experience the strongest regulatory impact. Yet they may also benefit from enhanced trust, clearer rules of the game, and potential access to state-supported infrastructure and funding under the AI development fund and voucher schemes.
- High-risk deployments: Firms operating in sensitive sectors must treat AI implementations similarly to regulated products, factoring regulatory approvals, audits, and ongoing supervision into project planning and budgeting.
- Medium-risk user-facing tools: Chatbots, recommendation engines, and content generators must be redesigned where necessary to ensure user awareness, explainability, and traceability of outputs.
- Cross-border arrangements: Multinational groups must align Vietnam-facing AI operations with global AI governance programs while adapting to local requirements on data, sovereignty, and local representation.
Enforcement Direction, Industry Signals, and Market Response
The early enforcement posture is likely to emphasize systemic risks such as prohibited AI uses, safety failures in high-risk sectors, and non-compliance with transparency obligations for widely used AI interfaces. Regulators are expected to adopt a phased, guidance-oriented approach initially, but with a clear willingness to use suspensions and revenue-based penalties for serious or repeated violations. Industry reactions already reflect a shift toward formal AI governance programs, investments in compliance tooling, and the appointment of dedicated AI risk officers or committees in large organizations.
Market participants anticipate closer scrutiny of biometric technologies, scoring systems, and automated decision tools in finance, healthcare, and public services, prompting many to revisit model design, data governance, and human-in-the-loop safeguards. At the same time, the law’s innovation incentives, sandbox mechanisms, and AI voucher schemes are expected to attract investment in compliant AI products and local infrastructure, driving a gradual maturation of the Vietnamese AI ecosystem.
Compliance Expectations
Role-based responsibility: Organizations must correctly identify whether they act as AI developers, providers, or deployers in each system and understand that multiple roles may coexist; this classification drives their obligations under the law.
Risk classification and documentation: Businesses are expected to self-classify AI systems according to the four-tier model, prepare risk classification dossiers for medium- and high-risk systems, and notify the Ministry of Science and Technology through the national AI portal before deployment where required.
High-risk system obligations: Providers of high-risk AI must implement continuous risk management, robust data governance, technical documentation, human oversight, incident reporting processes, and registration in the National AI Database before operational use.
Foreign provider obligations and local presence: Non-Vietnamese entities offering AI services into Vietnam must appoint a legally responsible local representative and, for certain high-risk categories, may need a commercial presence or authorized representative capable of handling conformity assessments and regulatory engagement.
- Governance and policies: Establish or update internal AI policies aligned with Vietnam’s principles on human-centricity, safety, transparency, and national sovereignty.
- Controls and monitoring: Implement technical and organizational measures to monitor AI performance, manage incidents, and cooperate with regulatory inspections.
- Training and accountability: Ensure that leadership and key staff understand their AI law responsibilities, with clear lines of accountability and escalation channels.
Practical Requirements
Organizations now need to translate legal requirements into operational controls that can withstand regulatory review and evolving technology risks, balancing innovation with demonstrable compliance. Preparing for Vietnam’s AI regime is not a one-time project but a continuous governance commitment that must be integrated into enterprise-wide risk management, IT, and compliance frameworks.
- Map AI systems and roles: Conduct a comprehensive inventory of AI use cases affecting Vietnam, categorize them by risk level, and determine whether the organization is acting as developer, provider, or deployer in each instance.
- Embed risk assessments early: Integrate AI impact and risk assessments into product development lifecycles, covering data sources, model choices, use contexts, and potential harms to users and society, with particular attention to high-risk applications.
- Design for transparency and oversight: Implement mechanisms that clearly inform users when they interact with AI, label AI-generated content, provide meaningful explanations for consequential outcomes, and maintain human-in-the-loop supervision where required.
- Strengthen data governance and security: Align AI data practices with Vietnam’s cybersecurity and personal data protection frameworks, including lawful data collection, purpose limitation, cross-border transfer controls where applicable, and robust technical security measures.
- Prepare for conformity assessment and registration: For high-risk systems, build internal capabilities or partnerships to navigate conformity assessments, compile technical documentation, and interface with regulators for National AI Database registration and subsequent inspections.
- Establish incident management processes: Define clear procedures for detecting, logging, and reporting AI incidents or malfunctions, including criteria for when to notify authorities and affected users, and mechanisms to roll back or suspend problematic systems.
- Coordinate with local representatives: Foreign providers should empower their Vietnamese representatives with sufficient authority, information, and resources to respond to regulatory requests, manage registrations, and coordinate remediation activities.
- Common mistakes to avoid: Underestimating the breadth of the AI definition, assuming global AI governance frameworks alone are sufficient, failing to re-evaluate risk levels when use cases change, neglecting user-facing transparency duties, or relying solely on vendors for compliance without internal oversight.
- Continuous improvement and review: Establish periodic reviews of AI systems’ risk classifications, performance, and compliance posture, taking into account updated guidance, evolving lists of high-risk use cases, and lessons from incidents or enforcement actions in Vietnam and abroad.
- Cross-functional governance: Create an internal AI committee or working group combining legal, compliance, IT, data science, security, and business units to ensure a holistic approach to Vietnam AI Law requirements and to coordinate responses to regulatory developments.
As Vietnam’s AI regime transitions from legislative framework to active enforcement, organizations that invest early in mapping their AI footprint, clarifying roles, and embedding risk-based controls will be better positioned to navigate future regulatory tightening. The trajectory points toward more detailed implementing rules, closer integration with data protection and cybersecurity requirements, and heightened scrutiny of cross-border AI services, meaning that proactive alignment today can significantly reduce future legal, operational, and reputational risk.
FAQ
1. Which businesses are covered by Vietnam’s AI Law?
Ans: The law applies to Vietnamese organizations and individuals, as well as foreign entities that develop, provide, or deploy AI systems affecting users or activities in Vietnam, regardless of where the technology is hosted or developed, unless the AI is used exclusively for defense, security, or intelligence purposes.
2. How should a company determine whether its AI system is high risk in Vietnam?
Ans: A company must analyze the sector and use case, focusing on whether the system is used in sensitive areas like finance, healthcare, education, justice, infrastructure, or public services, and assess potential impacts on safety, rights, and social order; if so, it will typically fall into the high-risk category and trigger stricter obligations.
3. What are the main obligations for providers of high-risk AI systems?
Ans: Providers of high-risk systems must carry out comprehensive risk management, implement data governance and security controls, maintain detailed technical documentation and logs, ensure meaningful human oversight, complete conformity assessments where required, and register their systems in the National AI Database before deployment in Vietnam.
4. What does the AI Law require from foreign AI providers offering services into Vietnam?
Ans: Foreign AI providers must appoint a legally responsible representative in Vietnam and, for certain high-risk systems, may need a local commercial presence or authorized representative; they remain responsible for meeting classification, registration, reporting, and cooperation duties and can face penalties or operational restrictions for non-compliance.
5. How can businesses prepare practically for the new AI regime?
Ans: Businesses should inventory all AI systems impacting Vietnam, classify them by risk level, assign clear internal roles, implement AI-specific policies and safeguards, design user transparency and oversight mechanisms, prepare for conformity assessments and incident reporting, and establish a cross-functional governance structure to monitor ongoing compliance.
6. Are there incentives or support mechanisms associated with Vietnam’s AI Law?
Ans: Yes, the framework includes measures such as a National AI Development Fund, sandbox testing regimes, and AI voucher programs that can provide financial support, infrastructure access, or preferential treatment for compliant AI projects, particularly those contributing to national strategic objectives and innovation priorities.