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 7, 2022
Thailand’s Office of the Personal Data Protection Committee (PDPC) has opened a public hearing period on its draft notification regarding cross-border transfer of personal data. The public hearing is open through October 24. The notification, once issued, will supplement the principle of cross-border transfer of personal data outside of Thailand set out in the Personal Data Protection Act (PDPA). The notification sets out the following key matters: Definitions “Transfer of personal data” means any sending or transferring of personal data by a transferor of personal data, either by way of a physical transfer or a remote transfer through a computer system or an internet network to the recipient of the personal data. It does not include sending personal data through an intermediary by transiting between computer systems or internet networks, or any storing or retaining of personal data, either permanently or temporarily, by a cloud computing service provider, whereby the personal data transferor and the personal data recipient (1) are not making the order, (2) are not involved with any data selection or the content of the personal data sent and received through the computer systems or internet networks, or (3) have the purpose of entering into an agreement or any juristic act. “Binding corporate rules” means the agreed terms or policy on personal data protection made between the personal data transferor and the personal data recipient to establish appropriate measures for safeguarding personal data within a group of corporations or companies. “Standard contractual clauses” means the contractual terms made between the personal data transferor and the personal data recipient to establish appropriate measures for safeguarding personal data. “Code of conduct” means a code that sets out the obligations of a personal data transferor and a personal data recipient outside of Thailand. “Certification” means an undertaking in relation to
Read More
September 21, 2022
Thailand’s Personal Data Protection Committee (PDPC) has released separate guidelines for data controllers to follow in obtaining data subjects’ consent and notifying data subjects of required information (i.e., regarding collection, use, or disclosure of their personal data). By following the guidelines, data controllers can mitigate the risk of violating the Personal Data Protection Act B.E. 2562 (2019) (PDPA). The Guidelines on Obtaining Consent from the Data Subject according to the PDPA and the Guidelines on Notification of Purposes and Details upon the Collection of Personal Data from the Data Subject according to the PDPA were issued on September 7, 2022. Consent Guidelines The PDPC’s guidelines on obtaining consent list the requirements for consent to be considered valid. These requirements include stipulations on timing of requests, elements that need to be included in requests, and the nature of requests. For instance, consent must be obtained before or at the time of obtaining personal data, and data subjects must be informed of both the purposes and details of the personal data handling, among other specific requirements. In turn, there must be a clear affirmative act of the data subject in giving consent. Obtaining consent from minors is subject to more stringent requirements, and data controllers should implement appropriate identification and age-verification measures when collecting personal data about minors. The guidelines give two sets of requirements, depending on the age of the minor—between 10 and 20, and under 10. In general, with the older age group, parental consent is not required in all circumstances, while for the younger age group, parental consent is compulsory for giving consent on behalf of the minor. For a person deemed to be “incompetent” or “quasi-incompetent,” consent must always be given by the legal guardian. Notification Guidelines The guidelines on notifying data subjects when collecting personal data
Read More
September 16, 2022
Thailand’s Personal Data Protection Committee (PDPC) has issued a regulation establishing procedures for filing and processing data subjects’ complaints under the Personal Data Protection Act B.E. 2562 (2019) (PDPA). The Regulation Re: Complaint Filing, Rejection, Termination, Consideration, and the Period for the Consideration of the Complaint B.E. 2565 (2022) was issued in July 2022 and took effect on July 12, 2022. The PDPA entitles data subjects to file complaints against data controllers, data processors, and employees or service providers of either whose operations fail to comply with the PDPA. This article lays out the various requirements and procedures for the filing and processing of such a complaint. Complaint Submission The body designated by the PDPA to be responsible for handling complaints and imposing administrative penalties is called the “Expert Committee.” Data subjects who would like to make a complaint can submit it to the Expert Committee directly at the Office of PDPC, send it to the office by post, or submit the complaint electronically. The written or electronic complaint must use clear, plain, polite, and appropriate language, and must not give an impression of being directly or indirectly extorting or intimidating. The complaint must include at least the following information: Name, address, and telephone number or email address of the complainant (or an authorized representative), together with identification card, passport, or other official identification document (plus a power of attorney if submitted by a representative); Details and facts of the noncompliance with or violation of the PDPA; Details of resulting damages or impact; Supporting evidence (e.g., documentary evidence, physical evidence, witness statements); and Action desired of the offender. The complaint must include a statement certifying its veracity, and must be signed by the complainant or the authorized representative. Complaint Consideration When a complaint is submitted, the receiving official will
Read More
September 8, 2022
While much attention has been paid to the data localization requirements for foreign enterprises under Vietnam’s 2018 Cybersecurity Law (“CSL”) and the recently issued Decree 53 guiding its implementation, the corresponding requirements for domestic enterprises are often overlooked, despite being potentially more troublesome. Under Decree 53, “domestic enterprises” are defined to mean enterprises established or registered for establishment under Vietnamese law and having their head offices in Vietnam (Article 2.11), so this designation includes not only Vietnamese companies, but foreign-invested enterprises as well. Background Before analyzing the stipulations in Articles 26 and 27 of Decree 53 further guiding the data localization/storage requirements, it is worth restating the very problematic Article 26.3 of the CSL, which reads: “Domestic and foreign enterprises providing services on telecommunication networks or the internet or value-added services in cyberspace in Vietnam with activities of collecting, exploiting, analyzing, and/or* processing personal information data, data on the relationships of service users, or data generated by service users in Vietnam must store such data in Vietnam for the period prescribed by the government. Foreign enterprises mentioned in this clause must open branches or representative offices in Vietnam.” [* Note: The Vietnamese text simply uses a comma here, without specifying whether this should be “and” or “or,” leading to additional problems in interpretation.] Because of this very broad and ambiguous wording, Article 26.3 of the CSL required further guidance from the government and remained unenforced for more than three years after the CSL took effect on January 1, 2019. Decree 53 guiding the implementation of the CSL was finally issued on August 15, 2022, and provides additional clarity on this matter. But does Decree 53 provide sufficient guidelines for implementation with regard to domestic enterprises? Scope of Application With regard to foreign enterprises, although there remains some ambiguity, Decree
Read More