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

August 1, 2025

Myanmar Cybersecurity Law Takes Effect

Subscribe to Updates

On July 30, 2025, Myanmar’s Cybersecurity Law No. 1/2025 came into effect with the State Administration Council’s issuance of Notification 113/2025. The law, which was enacted on January 1, 2025, aims to regulate various aspects of digital security and online activities.

Below are some key provisions, implications, and penalties under the Cybersecurity Law.

  • Extraterritorial penalties. The law contains an important provision that authorizes penalties against Myanmar citizens who are found guilty of violations, even if these occur outside the country’s borders.
  • VPN definition and regulation. Virtual private networks (VPNs) are defined by this law as specific systems that function as backup networks by using technological means in order to ensure the safety of linking networks to each other. This definition sets the framework for subsequent regulations and penalties associated with VPN usage. The law does not restrict individuals or entities from using VPNs; it regulates VPN service providers.
  • Penalties for unapproved VPN services. Establishing a VPN or providing VPN services without approval from the designated ministry (to be appointed later by the government) can result in significant penalties. For individuals, the punishment may be imprisonment for 1–6 months, a fine of MMK 1–10 million (approx. USD 476–4,760), or both, with the proceeds of the violation being confiscated. If the violator is a company or organization, the minimum fine will be MMK 10 million, and the proceeds will be confiscated.
  • Government oversight. The ministry designated by the government is authorized to investigate and take control of cybersecurity services and digital platform services for national defense and security purposes, or upon request from a government department or organization in accordance with respective laws.
  • Licensing requirements. The Cybersecurity Law introduces two types of licenses, valid for a period of 3–10 years, for (1) cybersecurity services and (2) digital platform providers. Digital platforms with over 100,000 users are required to apply for the latter license. Noncompliance with this requirement will be subject to a fine of at least MMK 100 million (approx. USD 47,600), and any proceeds resulting from the violation will be confiscated.
  • Penalties for unsolicited communications. Individuals who transmit unwanted and unsolicited messages, emails, or data via a network will be subject to imprisonment for 1–2 years, a fine of MMK 5–20 million (approx. USD 2,380–9,530), or both.
  • Penalties for cyber misuse. Engaging in cyber misuse—including the alteration, deletion, or sale of computer programs or data, as well as the unauthorized control and execution of computer systems, programs, or electronic data—will be subject to imprisonment from 6 months to 3 years, a fine of MMK 1–20 million (approx. USD 476–9,530), or both.
  • Penalties for online theft or mischief. Committing or inciting others to commit online theft or mischief using cyber resources will be subject to imprisonment for 2–7 years and the possibility of additional fines.
  • Penalties for unapproved online gambling. Operating an online gambling system without proper authorization may result in imprisonment for 6 months to 1 year, a fine of MMK 5–20 million (approx. USD 2,380–9,530), or both, with the proceeds from such activities being confiscated. If the offender is a corporation or organization, the minimum fine is MMK 20 million, and the illicit proceeds will also be confiscated. The law does not address how online gambling platforms can obtain official approval.

Myanmar’s Cybersecurity Law represents a significant step in the country’s regulation and oversight of digital security and online activities. Businesses, digital platform providers, cybersecurity service providers, and VPN providers need to understand these requirements and ensure compliance to prevent substantial penalties.

Nonetheless, given that services such as VPNs are very widely used, it remains to be seen how these new far-reaching regulations will actually be enforced.

 

This article was prepared with the assistance of Tilleke & Gibbins intern Ian Michael Yam.

Related Professionals

Industries

Technology

Location

RELATED INSIGHTS​ 

October 8, 2024
Thailand’s Electronic Transactions Development Agency (ETDA) issued guidelines for managing advertisements on digital platform services (DPSs) earlier this year. These guidelines aim to prevent fraud, illegal product or service offerings, and inducements to commit illegal acts, and are likely to provide a basis for greater regulation of this issue in the future. Key obligations for DPS business operators under the guidelines are detailed below. Advertiser Screening and Data Collection Verification and collection: Business operators must establish processes for verifying and collecting advertiser data. This includes steps, methods, and required information for advertiser registration. Identity verification: Business operators should follow identity verification requirements for advertiser registration. This may include using identity verification results from other identity providers or conducting their own identity verification processes with a minimum identity assurance level (IAL) of IAL2. Data storage: Advertiser data must be stored in a machine-readable format. Business operators must maintain records for watchlists, blacklists, and whitelists. Prepublication Advertisement Review Review process: Business operators should review advertisements before publication. This review should consider factors such as prohibited or restricted advertisements, required permissions, and avoiding sensitive user data. Postpublication Monitoring Advertisement monitoring: Business operators must monitor published advertisements using automated systems, staff, or contracted personnel. Criteria for prioritizing reviews should be established. Reporting channels: Business operators must provide channels for users to report illegal or inappropriate advertisements. Reports must be promptly addressed, prioritizing cases involving intellectual property owners or multiple credible reports. Advertiser account monitoring: Business operators must monitor advertiser accounts. This includes considering factors such as the number of reports/flags received and compliance with service agreements and community standards. For more information on this initiative from the ETDA, or on any aspect related to Thailand’s regulations for DPSs, please contact Athistha (Nop) Chitranukroh at [email protected], Thammapas Chanpanich at [email protected], Pornpan Wichawut at [email protected],
Read More
October 2, 2024
The first draft of Vietnam’s new Personal Data Protection Law (“Draft PDPL”) was released for public consultation on September 24, 2024, and is open for comments until November 24, 2024. (See further details here.) It is expected that the draft will be presented to the National Assembly before the end of 2024 and will be submitted for adoption in May 2025, with a tentative entry into force on January 1, 2026. As the Draft PDPL incorporates most of the provisions of Decree No. 13/2023/ND-CP on Personal Data Protection (“PDPD”), which has been the primary legal instrument on personal data protection since it took effect on July 1, 2023, it is likely that it will supersede the PDPD when it takes effect. [Please contact our Vietnam data protection team to request a detailed comparison of the Draft PDPL to the PDPD.] Noting that there might be further changes to the draft once the public consultation period closes, the Draft PDPL proposes new specific requirements for a number of services. Some highlights of the current version include the following: Marketing services: Although marketing services are already regulated under the PDPD, the Draft PDPL now recognizes that the use of personal data for marketing must comply with anti-spam regulations. The current draft does not clarify whether organizations are exempted from the consent requirement for the purpose of the initial call or message under the anti-spam regime. Marketing service providers are not allowed to outsource the services to another organization to perform or support the implementation of marketing business, which may prevent the sharing of personal data. Behavioral advertising: Behavioral advertising (targeted personalized advertising based on a user’s activity or personal data) requires the consent of the data subject in a modifiable manner that allows the data subject to refuse to share data
Read More
September 24, 2024
On September 24, 2024, the government of Vietnam issued the first draft of a new Law on Personal Data Protection (“Draft PDPL”). As foreshadowed in our previous legal update, the Ministry of Public Security has been very active in developing this draft law. With this draft, they promise to continue their considerable efforts to establish a robust personal data protection culture in Vietnam, as the Draft PDPL indicates a tentative entry into force on January 1, 2026. With a tentative adoption by the National Assembly in May 2025, the Draft PDPL does not include any transition period, save for micro-enterprises, SMEs, and startups, which are only exempted from appointing a data protection department in their first two years of existence, while the timeline to comply with other obligations under the PDPL remains the same as for other enterprises. The Draft PDPL includes 68 articles, divided into seven chapters, making it more extensive than last year’s Decree No. 13/2023/ND-CP on Personal Data Protection (“PDPD”), and expressly addresses personal data protection in many fields, including marketing services, behavioral advertising, big-data processing, AI, cloud computing, labor monitoring and recruitment, financial and credit information, health and insurance, and others. It remains unclear how the PDPL will interact with the PDPD (whether it will replace its predecessor or coexist with it), although the Draft PDPL provides that it will prevail over any laws that have provisions on personal data protection that differ from the provisions of the PDPL. Among the important new developments of the Draft PDPL when compared to the PDPD, we note: Consent remains the main legal basis for processing, with limited exceptions (still not including “legitimate interest”). However, consent for cross-border transfer is further regulated under the Draft PDPL, including for intra-group sharing. Data processing impact assessment dossiers for controllers and
Read More
September 24, 2024
In recent years, Thailand has witnessed significant developments in its personal finance sector, particularly in alternative lending options. This article explores two key concepts in the Thai financial landscape: nano finance and personal loans. These alternative lending models, regulated by the Bank of Thailand (BOT), aim to provide more accessible financial services to individuals and small entrepreneurs who might have limited access to traditional funding sources. Nano Finance: Empowering Small Entrepreneurs The nano finance scheme under the BOT’s supervision is designed to provide funding to small entrepreneurs who might have limited access to traditional financial resources. One of the key features of this scheme is the ability of licensed nano finance providers to use alternative data in assessing loan applicants’ ability to repay (information-based lending). To implement this approach, nano finance providers must have an internal policy on credit approval that supports: Identifying scope and processes for utilizing alternative factors or technologies in determining debt repayment capacity, credit line limits for each loan applicant and total credit limits, and acceptable debt repayment targets; Having resources and personnel with sufficient knowledge, capability, experience, and expertise to operate efficiently and effectively, as well as clear checks and balances; Establishing guidelines for selecting and analyzing factors or financial models to evaluate or predict loan applicants’ ability and willingness to repay; Having an internal sandbox to test key success factors of the selected factors or models; and Having a process for monitoring and reviewing the application of the selected factors or models in assessing debt repayment capability. This approach allows nano finance providers to make more informed lending decisions based on a broader range of data, potentially increasing access to finance for small entrepreneurs who may not have traditional credit histories or collateral. Personal Loans The personal loan scheme under BOT supervision aims
Read More