A new decree in Vietnam brings significant implementation clarity to the country’s existing extended producer responsibility (EPR) legal framework. An EPR mechanism was first codified in Vietnam in the 2020 Law on Environmental Protection amid ongoing challenges surrounding the collection and treatment of product and packaging waste. The mechanism was progressively detailed through Decree No. 08/2022/ND‑CP and its successive amendments, but the regulatory framework remained insufficiently developed, notably in terms of support mechanisms for waste collection, recycling, and treatment. The newly launched regulations in Decree No. 110/2026/ND-CP (Decree 110), issued on April 1, 2026, and taking effect on May 25, 2026, stipulate fully and clearly the responsibility of manufacturers and importers to recycle products and packaging and to treat waste. Some key provisions of Decree 110 for manufacturers, importers, and related stakeholders are presented below. Subjects of EPR The Law on Environmental Protection assigns responsibility to manufacturers and importers for product and packaging recycling (under Article 54) or waste collection and treatment (under Article 55), depending on the type of products and packaging they produce or import. Decree 110 elaborates on these EPR provisions by specifying the responsible entities and listing out the types of products and packaging subject to recycling and waste treatment responsibilities. Decree 110 clarifies the responsible entities in special cases, such as when products under the same brand are made by multiple manufacturers, when there is a contract manufacturing or entrusted import relationship, and when the manufacturer or importer is part of a corporate group. Notably, exemptions may be applied in some scenarios, such as for manufacturers and importers of products and packaging exclusively for export, temporary import and re-export, or research and testing purposes, as well as for entities with annual revenue from related products not exceeding VND 30 billion. Recycling Responsibilities Decree 110

On March 31, 2026, Vietnam’s government issued Decree 102/2026/ND-CP (Decree 102), which amends Decree 75/2019/ND-CP on administrative sanctions for competition law violations (Decree 75). Effective from May 20, 2026, the new decree introduces a number of significant changes aimed at strengthening enforcement, revising penalty structures, and broadening the range of remedial measures, primarily for violations related to economic concentration. Revised Penalties for Economic Concentration Violations Decree 102 significantly revises the penalties for violations related to economic concentration. Failure to notify an economic concentration; implementing an economic concentration before clearance Under the new framework, Articles 14 and 15 of Decree 75 have been amended to impose a range of monetary fines, rather than relying solely on percentage‑based penalties as under the previous regime, for violations involving the failure to notify an economic concentration or the implementation of an economic concentration prior to clearance. The fines range from VND 500 million to VND 1 billion for each enterprise participating in a concentration with combined assets, revenues, or purchase value below VND 3,000 billion in the preceding fiscal year, capped at 5% of the violating enterprise’s total turnover in the relevant market. For concentrations meeting or exceeding the VND 3,000 billion threshold across those same metrics, the fines increase to VND 1 billion to VND 2 billion per enterprise, also subject to the 5% cap. These differentiated thresholds allow penalties to better reflect the size of the transaction and its potential competitive impact. Non-compliance with conditional approvals Enterprises that do not implement or only partially implement the conditions specified in a conditional economic concentration approval decision face fines ranging from 1% to 3% of total turnover in the relevant market during the fiscal year preceding the violation. Decree 102 also adds a new remedial measure requiring enterprises to fully implement all conditions

Following Thailand’s recent expansion of the “major shareholder” definition for securities and digital asset businesses, the Securities and Exchange Commission (SEC) launched a public hearing on April 7, 2026, on expanding the major shareholder definition further to cover funding sources behind share acquisitions in licensed securities and digital asset business operators. The public hearing will remain open for 15 days from the launch date, after which the proposed expansion is expected to take effect promptly so that operators can comply with both the earlier and additional requirements within the 180-day transitional period under the earlier regulations. Funding Sources Captured Under Control-Based Test Under the draft rules, persons who fund direct or indirect major shareholders’ acquisition of shares in a licensed operator would be deemed “controlling persons” and subject to SEC approval as major shareholders. This extends beyond traditional lenders to include guarantors, counterparties to derivatives or structured products, and any arrangement that results in a person being, directly or indirectly, a source of funding to a major shareholder. The SEC proposes to exempt three categories of funding arrangements from approval: Loans from Thai licensed financial institutions or BCBS (Basel Committee on Banking Supervision)-jurisdiction foreign banks; Margin loans for securities trading under Thai securities law; and Repurchase agreements under Thai securities law. Exemptions for Funding Sources of Government-Linked Entities The consultation proposes to stop look-through beyond the level of certain government-linked shareholders, including, without limitation, ministries, departments, bureaus, public organizations, independent agencies, and certain state enterprises. The SEC reasons that these entities’ mandates, duties, and funding sources are already subject to government oversight and audit, presenting minimal ownership-structure risk. Practical Implications Licensed securities and digital asset business operators should begin mapping their funding chains under the expanded definition in preparation for filing approval applications for any newly captured funding providers

Thailand’s Securities and Exchange Commission (SEC) has established a comprehensive governance framework for the use of artificial intelligence and machine learning (AI/ML) in the capital markets. The framework provides guidance to capital market business operators on understanding the risks associated with AI/ML implementation and adopting appropriate practices to build public confidence in Thailand’s capital markets. While the guidelines are principle-based rather than prescriptive, they reflect the SEC’s expectations for responsible AI/ML governance and are likely to inform supervisory activities and industry standards going forward. Scope The framework applies to capital market business operators supervised by the SEC. This includes, for example, securities and derivatives firms, asset management companies, mutual fund and private fund managers, investment advisors and investment consultants (including robo-advisory service providers), derivatives intermediaries, and other licensed intermediaries and market operators in the Thai capital markets that deploy AI/ML in their operations. Core Principles of the Guidelines The framework is presented as a best-practice manual rather than prescriptive regulation, providing guidance that regulated entities may apply to their AI/ML governance and risk management as appropriate. While currently nonbinding, the guidelines signal the SEC’s expectations for the sector, particularly in relation to other binding SEC regulations such as those covering IT risk management and market conduct. The guidelines name four core principles for AI/ML deployment: Fairness: Design and develop AI/ML with consideration for fairness, equality, and social diversity to prevent discrimination against individuals or groups. Legal and ethical compliance: Ensure AI/ML use aligns with applicable laws, ethical standards, and organizational values and policies. Accountability: Establish clear responsibility—both internally and externally—for AI/ML activities and outcomes. Transparency: Provide adequate disclosure to users about AI/ML use, including explainability of decisions and traceability of activities. AI/ML Best Practices The guidelines prescribe best practices across four stages of the AI/ML lifecycle, as described below.