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July 6, 2026

Vietnam Introduces Sectoral List of High-Risk AI Systems

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Vietnam has introduced an official list of high-risk AI systems, triggering more stringent compliance obligations for developers, suppliers, and deployers operating in the country. On June 30, 2026, the prime minister issued Decision No. 33/2026/QD-TTg (Decision 33), which establishes the List of High-Risk AI Systems under the Law on Artificial Intelligence (AI Law) and Decree No. 142/2026/ND-CP (Decree 142). Decision 33 takes effect on August 15, 2026.

Decision 33 is significant because only AI systems included on the list will be subject to the heightened compliance obligations applicable to high-risk AI systems under the AI Law and Decree 142. These include, among others, local presence requirements for foreign providers, mandatory conformity assessment before deployment, comprehensive risk management and data quality documentation, and strict liability for damages even when the provider is fully compliant. Decision 33 also specifies the applicable conformity assessment pathway for each listed system, indicating whether the system must undergo mandatory third-party conformity certification before being placed into use, or whether the provider may self-assess conformity or voluntarily engage a registered or recognized conformity assessment body.

Which AI Systems Are Covered?

Decision 33 identifies high-risk AI systems across six sectors—the key attributes of which are summarized below.

  • Education: AI systems used for automated assessment, learner ranking, behavioral monitoring, or generating educational content from uncontrolled data sources.
  • Ethnic affairs and religion: AI systems used to automatically score, classify, or rank applications for government ethnic policies; approve or reject regulatory applications; suspend benefits on suspicion of fraud; allocate budgets; or infer and classify individuals by ethnicity or religion for administrative purposes.
  • Healthcare: AI-assisted surgical systems and autonomous AI-powered surgical robots.
  • Banking: AI systems that autonomously conduct electronic banking transactions or make credit approval decisions.
  • Judicial proceedings: Certain large-scale biometric identification systems used in public-interest civil proceedings.
  • Transport: Thirty-one categories of AI systems, including highly autonomous driving systems, AI-based traffic signaling and dispatch, and AI systems controlling critical transport infrastructure.

Many listed systems fall within the high-risk category only where AI outputs are used as the sole basis for decisions without meaningful human review, reflecting Vietnam’s risk-based approach to AI regulation.

Compliance Timeline

In general, AI systems—both those existing before Decision 33’s effective date and those deployed in the six months after the decision takes effect—must meet compliance obligations by March 1, 2027. However, AI systems in healthcare, education, and finance that are already in operation before August 15, 2026, are granted an additional transitional period, with a compliance deadline of September 1, 2027.

Outlook

Organizations developing, supplying, or deploying AI systems in Vietnam should review their existing and planned systems to determine whether they fall within the List of High-Risk AI Systems under Decision 33. Operators of listed AI systems should assess the resulting compliance obligations under the AI Law and Decree 142. Organizations should also use the transitional periods provided under Decision 33 to develop and implement compliance plans where necessary.

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