Tilleke & Gibbins has contributed the Vietnam chapter to Fintech 2027, a global guide published by Lexology Panoramic that provides comparative insights into the legal and regulatory frameworks governing fintech businesses across multiple jurisdictions. The Vietnam chapter offers a comprehensive overview of the country’s rapidly evolving fintech landscape, examining both the regulatory environment and practical considerations for businesses operating in or entering the Vietnamese market. Topics covered include: Fintech landscape and initiatives: General innovation climate; government and regulatory support Financial regulation: Regulatory bodies; regulated activities; consumer lending; secondary market loan trading; collective investment schemes; alternative investment funds; peer-to-peer and marketplace lending; crowdfunding; invoice trading; payment services; open banking; robo-advice; insurance products; credit references Cross-border regulation: Passporting; requirement for a local presence Sales and marketing: Restrictions on the promotion and marketing of financial products and services Cryptoassets and tokens: Distributed ledger technology; cryptoassets; token issuance Artificial intelligence: Regulatory framework governing AI systems and AI-enabled financial services Change of control: Notification and consent requirements for regulated businesses Financial crime: Anti-bribery and anti-money laundering procedures; regulatory guidance Data protection and cybersecurity: Data protection obligations; cybersecurity requirements applicable to fintech businesses Outsourcing and cloud computing: Outsourcing of material functions; use of cloud computing in the financial services industry Intellectual property rights: IP protection for software; employee- and contractor-created IP; joint ownership; trade secrets; branding; remedies for infringement Competition: Competition law issues affecting fintech businesses Tax: Incentives for innovation and investment; developments affecting tax and compliance obligations Immigration: Immigration options for recruiting skilled foreign personnel; special measures available through Vietnam’s international financial centers The chapter also examines a number of significant recent developments shaping Vietnam’s fintech sector, including the introduction of the country’s first comprehensive regulatory framework for cryptoassets, the adoption of a dedicated law on artificial intelligence, implementation of the banking regulatory sandbox,

On July 23, 2026, the Bank of Thailand (BOT) released for public comment its draft Notification on Digital Channel Security, which would significantly expand the scope and stringency of Thailand’s existing mobile banking security framework. If finalized in its current form, the draft notification would extend mandatory security requirements to credit card providers and credit providers, cover internet banking in addition to mobile applications, phase out SMS one-time passwords (OTPs) for transaction authentication, and introduce biometric verification requirements for high-value transactions. The public comment period is open through August 24, 2026. Background The BOT’s existing Mobile Banking Security Notification, issued in 2024, sets minimum security standards for financial institutions, specialized financial institutions (SFIs), and e-money providers, significantly reducing “money-draining app” fraud. However, fraudsters have since shifted to nonbank providers and internet banking channels, prompting the BOT to propose broader security requirements. Expanded Scope of Regulated Entities and Channels The existing Mobile Banking Security Notification covers only financial institutions, SFIs, and e-money providers offering mobile banking services. The draft expands coverage in two key areas: entities and channels. On the entity side, it adds credit card providers and credit providers that offer fund transfers to third parties at other financial service providers or that provide cash withdrawal services to individual retail customers. On the channel side, it broadens coverage to include internet banking in addition to mobile banking. Strengthened Customer Authentication The draft introduces enhanced authentication requirements in three areas: Service enrollment and device changes. Providers must implement rigorous identity verification, notify customers of enrollment results through out-of-band communication channels, and adopt risk-mitigation measures such as cooling-off periods and temporary transaction limits. Transaction-level authentication. Providers must use two-factor authentication for fund transfers, cardless ATM withdrawals, and transaction limit increases. Secure authentication factors. Key requirements include the following: “What-you-know” factors must

Data protection officers (DPOs) have become a fixture of Thailand’s privacy compliance landscape since the Personal Data Protection Act B.E. 2562 (2019) (PDPA) took full effect and the Office of the Personal Data Protection Committee (PDPC) began requiring certain organizations to appoint them. On July 7, 2026, the Office of the PDPC presented draft guidance on DPOs as part of a public consultation on a series of draft personal data protection manuals and recommendations. The draft offers the clearest indication yet of how the regulator expects the DPO role to work in practice, addressing recurring implementation issues under the PDPA—including when an organization must appoint a DPO, how the DPO should operate independently, how to manage conflicts of interest, and how data subjects and regulators should be able to contact the DPO. Because it remains in draft, organizations have an opportunity to weigh the practical implications now before the guidance is finalized. When a DPO Must Be Appointed The draft guidance clarifies the triggers for mandatory DPO appointment, including: Regular and systematic monitoring of personal data or systems on a large scale, such as tracking, analyzing, or predicting behavior, attitudes, or individual characteristics. Core activities involving large-scale processing of sensitive personal data, such as health data, biometric data, or criminal records. Certain foreign-organization representative arrangements. Public-sector coverage under relevant notifications identifying government entities that must appoint a DPO. Processing involving 100,000 or more data subjects may be considered large-scale. The guidance also contemplates voluntary DPO appointment for organizations that wish to raise their privacy governance standards, and such organizations should still comply with the standards applicable to DPOs under the law. Independence and Reporting Lines The draft guidance identifies lack of DPO independence as a core risk because an ineffective or constrained DPO may be unable to raise deficiencies

Vietnam’s new E-Commerce Law, which took effect on 1 July 2026 along with its implementing Decree No. 248/2026/ND-CP (Decree 248), marks a significant development in the country’s approach to online intellectual property (IP) enforcement, reflecting a clear shift from a reactive model of intermediary liability to one that expects platforms to play a more active role in preventing infringement. From notice-and-takedown to platform responsibility The most significant change introduced by the E-Commerce Law is the transformation of the legal role of e-commerce platforms. The existing safe harbor provisions under the IP Law and the copyright notice-and-takedown regime established by Decree 17/2023/ND-CP (Decree 17) largely required intermediaries to act only after receiving notice of infringement. Once infringing content had been removed, the platform’s legal obligation was generally considered fulfilled. The new legislation adopts a fundamentally different approach. Article 17 of the E-Commerce Law requires intermediary platforms to screen information relating to goods and services before publication in order to prevent listings involving counterfeit or IP-infringing goods, and goods of unknown origin. Rather than relying exclusively on complaints from rights holders, platforms are now expected to implement preventive measures before infringing listings become publicly available. Decree 248 further requires platforms to update keyword filters based on recommendations issued by competent authorities. These filtering mechanisms are intended to prevent prohibited listings from appearing on the platform and represent a further move away from a purely complaint-driven enforcement model. The legislation also introduces Vietnam’s first statutory stay-down obligation. Under the E-Commerce Law and Decree 248, major digital platforms must maintain automated systems capable of reviewing, warning against, and removing unlawful listings while also implementing measures to prevent repeat violations, defined under Decree 248 as conduct that has previously been identified and handled by the platform, but continues to recur. This obligation addresses one