You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

July 6, 2026

Lexology Panoramic: Data Protection & Privacy 2027 – Vietnam

Tilleke & Gibbins has contributed the Vietnam chapter to Data Protection & Privacy 2027, a global guide published by Lexology Panoramic that provides comparative insights into data protection and privacy regimes across multiple jurisdictions.

The Vietnam chapter offers a comprehensive overview of the country’s data protection framework, addressing both regulatory structure and practical compliance considerations for businesses operating in or engaging with Vietnam. Topics covered include:

  • Law and the regulatory authority: Legislative framework; data protection authority; cooperation with other data protection authorities; breaches of data protection law; judicial review of data protection authority orders
  • Scope: Exempt sectors and institutions; interception of communications and surveillance laws; other laws; personal information formats; extraterritoriality; covered uses of personal information
  • Legitimate processing of personal information: Lawful bases for processing; grounds for legitimate processing; types of personal information
  • Data handling responsibilities of owners of personal information: Transparency; exemptions from transparency obligations; data accuracy; data minimization; data retention; purpose limitation; automated decision-making
  • Security: Security obligations; notification of data breaches; internal controls
  • Accountability: Data protection officer requirements; record-keeping; risk assessment; design of personal information processing systems
  • Registration and notification: Registration requirements; other transparency duties
  • Sharing and cross-border transfers of personal information: Sharing with processors and service providers; restrictions on third-party disclosures; cross-border transfers; further transfers; localization requirements
  • Rights of individuals: Right of access; other statutory rights; compensation
  • Enforcement: Enforcement mechanisms; exemptions, derogations, and restrictions; further exemptions and restrictions
  • Specific data processing: Cookies and similar technologies; electronic communications marketing; targeted advertising; sensitive personal information; profiling; cloud services

The chapter concludes with an update on key legal and regulatory developments over the past year and emerging trends in Vietnam’s data protection landscape.

The full Vietnam chapter is available as a PDF through the button below.

Readers can also gain 30 days of complementary access to the full Data Protection & Privacy 2027 guide and the rest of Lexology Panoramic’s varied offerings through this link.

RELATED INSIGHTS​ 

January 21, 2026
On January 16, 2026, Thailand’s Electronic Transactions Committee released for public comment a draft notification that would require social media platforms operating in Thailand to implement identity verification for all user accounts and advertisers, with enhanced scrutiny for high-risk advertising activities. If finalized in its current form, the Notification on Measures to Prevent Technology Crime for Social Media Service Providers would take effect 180 days after publication in the Government Gazette, fundamentally changing how platforms verify users and monetize advertising services. The public comment period is open through February 2, 2026. Mandatory User and Advertiser Identity Verification The draft establishes a universal requirement that all social media service providers implement identity verification measures for every user account. The draft imposes stricter verification obligations for advertisers than for general users. Before publishing any advertisement, platforms must verify the advertiser’s identity at a level sufficient to identify the advertiser, unless the advertiser has previously completed verification. Risk-Based Advertisement Verification The identification requirements for advertisers will be more stringent in the following cases: The advertiser has a history of user complaints or has previously violated the platform’s terms of service. The advertisement involves finance, investment, loans, sensitive personal data, or content flagged as potentially involving cybercrime. The advertisement specifically targets vulnerable groups, such as the elderly or other at-risk demographics. In such cases, platforms must conduct identity verification using government-issued identification documents and must confirm the accuracy, authenticity, and currency of these documents with the issuing government agencies. Alternatively, platforms may verify identity through an eligible digital identity verification and authentication system provider. Information Retention Platforms must retain specific information for each advertiser, including the name of the individual or juristic person and any representatives, government-issued identification documents such as ID cards, passports, or certificates of incorporation, and reachable contact information including
January 21, 2026
Spurred by global geopolitics and Canada’s Indo-Pacific Strategy, which aims to forge deeper ties with ASEAN, Canadian companies have been showing growing interest in Thailand and Southeast Asia in recent years. To understand the opportunities offered by the region, we sat down with Andrew Stoutley, a Toronto native and the chief operating officer of Tilleke & Gibbins, a leading Southeast Asian regional law firm with over 130 years of history in Thailand. Q: Why are Canadian companies looking at Thailand and Southeast Asia right now? A: Two reasons stand out. First, diversification has moved up the agenda. Many Canadian companies want options outside North America due to tariff volatility and policy uncertainty in the United States, as well as questions around the next Canada–United States–Mexico Agreement mandatory joint review. At the same time, the shift of global production from China to Southeast Asia is accelerating, driven by rising costs, geopolitics, and the need to avoid overreliance on a single market. As a result, Canadian companies are looking for a second production base or a regional hub, and Thailand and its neighbors are natural choices given their manufacturing depth, location, and established supply chains. Second, Canada’s own efforts in the region are gaining traction. The Indo-Pacific Strategy has led to more on-the-ground support, including larger trade missions, upgraded diplomatic posts, and new financing options. Export Development Canada (EDC) now has a presence in Bangkok, giving Canadian companies a direct line to financing and insurance in Thailand. There’s also steady progress on trade frameworks like the recently signed Canada–Indonesia Comprehensive Economic Partnership Agreement (which will come into effect pending domestic procedures), ongoing negotiations of a Canada–ASEAN FTA, and the exciting announcement about the launch of negotiations of a Canada–Thailand FTA. Together, these developments have the potential to make it much easier
January 13, 2026
On January 9, 2026, Thailand’s Securities and Exchange Commission (SEC) filed a criminal complaint with the Economic Crime Suppression Division (ECD) against five individuals for unauthorized operation of a digital-asset dealer business under the Emergency Decree on Digital Asset Businesses B.E. 2561 (2018). This precedent-setting case signals that the regulator is willing to pursue crypto enforcement against natural persons even in the absence of a licensed platform entity. Background and Implications The case follows the SEC’s October 2025 public warning about the use of iris-scanning technology in exchange for certain digital tokens. In its warning, the SEC cautioned that exchanging or trading these specific tokens with unlicensed service providers exposes users to heightened fraud, scam, and money laundering risks. Unlike prior regulatory enforcement matters, which involved platform-level administrative fines for operational or compliance failures, this case targets misconduct by individuals who may not be professional traders but openly advertised their willingness to buy these tokens from the public, opened individual over-the-counter (OTC) trade channels for these tokens, and facilitated off-exchange transactions in a manner resembling ordinary commercial dealing. This enforcement action establishes a clear precedent that natural persons engaging in public-facing digital-asset dealing may face criminal liability under Thai law, even without operating through a corporate or licensed platform structure. Outlook The alleged offenders may not settle this crime by payment of fines. Following the SEC’s referral, the ECD will undertake further investigation, after which prosecutors may review the case and proceed to court. The SEC has stated that it will cooperate fully with enforcement agencies throughout the criminal enforcement process.
January 9, 2026
Vietnam has taken a decisive step into the global artificial intelligence regulatory landscape with the promulgation of the Law on Artificial Intelligence No. 134/2025/QH15 (AI Law), adopted on December 10, 2025, and effective from March 1, 2026. As one of the earliest comprehensive, standalone AI statutes in Southeast Asia, the AI Law signals Vietnam’s ambition to position itself as both an innovation-friendly and governance-conscious AI market. In doing so, the legislature has also streamlined Vietnam’s AI regulatory architecture. The AI Law repeals most AI-related provisions previously embedded in the Law on Digital Technology Industry No. 71/2025/QH15, consolidating AI governance under a single, unified legal framework. This structural move underscores an intent to provide greater regulatory clarity and coherence for businesses operating across the AI value chain. Against this backdrop, the key question for AI developers, providers, deployers, and governance teams is how the new risk-based framework will shape compliance expectations, operational decisions, and governance design in practice. This article examines the new AI Law through that practical lens, focusing on what it means for AI businesses operating in or into Vietnam. Scope of Application The AI Law applies broadly to Vietnamese organizations and individuals, as well as foreign entities that participate in AI-related activities within Vietnam. The law expressly excludes AI activities conducted solely for national defense, security, and cryptography purposes. A defining feature of the AI Law is that it regulates by role, not by industry. It distinguishes between: Developers, who design, build, train, test, or fine-tune AI models and have direct control over the technical methods, training data, or model parameters; Providers, who place AI systems on the market or put them into use under their own names; Deployers, who use AI systems under their control in professional, commercial, or service-provision activities; Users, who interact with AI