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​ 

June 2, 2023
In Southeast Asia, artificial intelligence (AI) products and services are being leveraged across industries such as finance, healthcare, retail, agriculture, and manufacturing. Governments across the region are recognizing the benefits of harnessing AI and the positive impact of AI technology on economic development. As the rise in AI deployment creates opportunities for economic growth in Southeast Asia, regulatory and digital governance efforts should focus on ethical, inclusivity, and cybersecurity concerns to help ensure that the widespread use of AI technology in the region is sustainable. Two jurisdictions in the region that have already made significant strides in developing initiatives surrounding AI are Singapore and Thailand. Singapore Due to its more advanced technological infrastructure, Singapore was one of the first countries in the region to address AI-related issues. Singapore has been aligning its data protection policies and regulations with the changing digital landscape since 2012—the year Singapore passed its Personal Data Protection Act. In 2019, Singapore unveiled its National AI Strategy to increase the use of AI technologies and deploy “scalable, impactful AI solutions in key verticals by 2030.” The goal is to align talent, regulation, and business growth to ensure AI applications serve society. Singapore’s approach is to facilitate innovation while safeguarding consumer interests, as it strives to become one of the regional leaders in the field of AI. In terms of Singapore’s regulatory landscape, Singapore’s Personal Data Protection Commission (PDPC) oversees data and AI, including AI developers and AI-using companies, which consist of backroom operations, front-end usage companies, and distributors of equipment with AI features. The Singapore Academy of Law (SAL) oversees all laws applicable to AI systems and decides on issues that impact the AI industry. Singapore has joined various bilateral and regional trade arrangements to facilitate research, development, and collaboration in support of its growing digital
Read More
May 24, 2023
The draft Royal Decree on Artificial Intelligence System Service Business, which was introduced by the Office of the National Digital Economy and Society Commission earlier for public comment in October last year, focuses on potential risks from artificial intelligence (AI) systems to public health, safety, and freedoms. The framework emphasizes the importance of risk assessment, reporting requirements, and the establishment of specific measures and criteria deemed necessary to minimize AI risks. AI Systems Defined by the Decree Under the draft royal decree, an AI system is defined as a machine-based system that can make predictions, recommendations, or decisions that affect real or virtual environments pursuant to the objectives set by humans. The definition clarifies that artificial intelligence systems are designed to operate at different levels of autonomy, including: machine learning AI; logic-based and knowledge-based AI; statistical AI; Bayesian estimation AI; and search and optimization AI. Risk-based Approach The draft AI royal decree takes a risk-based approach to regulation and specifically identifies prohibited or high-risk AI services that could cause harm or engage in unethical practices to ensure that AI systems do not pose major risks to public health, safety, or freedoms. The extent of regulatory scrutiny applied to an AI system corresponds to the level of risk presented by the AI system. For example, AI systems that pose unacceptable risks are generally prohibited, AI systems considered to be high-risk are subject to a conformity assessment, and AI systems considered to be limited-risk are subject to transparency requirements. Compliance with specified criteria and procedures to minimize potential risks of each AI service would be further outlined in subregulations. Prohibited AI Systems The draft AI royal decree prohibits AI systems that: employ subliminal techniques to covertly influence human behavior (below the threshold of conscious awareness); utilize social scoring; access sensitive personal
Read More
May 17, 2023
In Myanmar, a Union Tax Law is enacted each year to announce the rates of tax set out in the Income Tax Law 1974, the Commercial Tax Law 1990, and the Special Goods Tax Law 2016. The Union Tax Law 2023 (UTL 2023) came into force on April 1, 2023. It sets the rates of special goods tax (SGT), income tax (IT), and commercial tax (CT) for the period of April 1, 2023, to March 31, 2024, and exempts certain goods and services from these taxes. The key changes implemented by the UTL 2023 are summarized below. Special Goods Tax The UTL 2023 exempts battery electric vehicles (BEVs) from SGT. At the same time, it increases the rate of SGT on imported liquor. Previously, the rate of SGT ranged from 190 MMK per liter to 60 percent of the per-liter price of imported liquor in the previous fiscal year. The UTL 2023 raises the minimum rate to 209 MMK per liter while leaving the upper rate unchanged. Commercial Tax and Customs Tariffs BEVs imported into Myanmar were made exempt from CT under the Law Amending the Union Tax Law 2022. The UTL 2023 extends the exemption until the end of the 2023–24 fiscal year, along with two- and three-wheeler BEVs, BEV batteries, and related parts for specific use in BEVs. The CT exemption for battery charging services for BEVs, also introduced in 2022, has similarly been extended. Following enactment of the UTL 2023, the Ministry of Planning and Finance (MOPF) issued Notification No. 31/2023, reducing to zero the customs tariffs on imported BEVs, including those imported completely built up (CBU), completely knocked down (CKD), or semi-knocked down (SKD). The tariffs on spare parts and materials for BEVs have also been reduced to zero. In addition to exempting BEVs from
Read More
May 15, 2023
Southeast Asia’s remarkable growth as a destination for foreign investment—including a 42 percent increase in 2021, according to a joint ASEAN-UNCTAD report—has brought with it innovation as well as the desire to protect that innovation. Investors are increasingly seeking to patent the proprietary technology that is a crucial component of so many businesses today, and a burning question for patent applicants is whether artificial intelligence (AI) technology and software are patentable in Southeast Asia. The short answer is that it depends, as the patent laws in Southeast Asia are not uniform. Is it Patentable? While AI tools tend to be newer, the older and more familiar question is whether computer software is patentable, and many jurisdictions do have specific rules on this issue. Pure software, or software characterized only by source code, may not be patentable, but it can be protected under copyright laws. AI-related software may involve complex algorithms, datasets, and training methodologies that can be challenging to disclose in a manner that satisfies the enablement requirement in practice. Algorithms, mathematical methods, and abstract ideas are often considered non-patentable subject matter in many jurisdictions. While software implementing AI may involve innovative algorithms, securing patents for algorithms alone can be challenging in some jurisdictions. Also, the patent laws of Indonesia, Myanmar, Thailand, and Vietnam specifically list computer programs as unpatentable subject matter. However, a possible workaround would be to describe the software as connected to a tangible medium. This method could overcome an unpatentable subject matter rejection during substantive examination. Furthermore, in Indonesia, a computer program can be patentable if its characteristics (i.e., instructions) have a technical effect and function to solve a tangible or intangible problem. The most liberal of Southeast Asia’s patent regimes—Singapore’s—even addresses AI innovations. The country has a special fast-track scheme for examining AI patent
Read More