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 25, 2026

Vietnam Issues Cybersecurity and Personal Data Protection Sanctions Decree

Subscribe to Updates

Vietnam has enacted a new decree establishing administrative penalties for violations in the fields of cybersecurity and personal data protection. Decree No. 330/2026/NĐ-CP (Decree 330), issued and effective from August 19, 2026, provides a detailed sanctions framework for noncompliance with the Law on Personal Data Protection (including its implementing regulations under Decree 356/2025/ND-CP) and the Law on Cybersecurity, together with their guiding decrees.

The issuance of Decree 330 signals that the practical grace period previously perceived by many businesses may be drawing to a close, with active regulatory enforcement in these areas expected to commence in earnest.

Scope and Key Provisions

Decree 330 has extraterritorial effect and applies to both onshore and offshore companies. For offshore companies, it applies to those that (1) provide telecommunications, internet, online-content, information-technology, cybersecurity, or cross-border services and (2) are involved in or related to the processing of personal data of Vietnamese citizens and certain other people of Vietnamese origin.

Decree 330’s key provisions cover the following areas:

  • Administrative penalties for violations relating to the protection of national security and public order in cyberspace, including the dissemination of unlawful, false, or unverified information.
  • Sanctions for cyberattacks, unauthorized access, introduction of harmful code or programs, and failure to cooperate with specialized cybersecurity forces.
  • Sanctions for personal data protection violations, such as consent, cross-border data transfers, impact assessments, breach notification, and data-subject rights, among others—with maximum fines of up to 5% of an organization’s preceding-year revenue for cross-border transfer violations, or up to VND 3 billion for other data-protection breaches.

Personal Data Protection Penalties

The key sanctions for personal data protection violations are as follows:

  • Consent violations: Fines of up to VND 70 million (approx. USD 2,642), plus potential additional sanctions and remedial measures including irreversible deletion of personal data collected without consent and confiscation of illegal profits.
  • Data breach notification violations: Fines of up to VND 80 million (approx. USD 3,019), with potential remedial measures including mandatory breach notification and implementation of prevention and remedial measures as directed by the regulator.
  • Data processing impact assessment (DPIA) violations: Fines of up to VND 100 million (approx. USD 3,774), with potential remedial measures including mandatory DPIA submission and suspension of personal data processing until the filing obligation is successfully completed.
  • Cross-border transfer impact assessment (TIA) violations: Fines of up to 5% of preceding-year revenues or up to VND 3 billion (approx. USD 113,208), with potential additional sanctions and remedial measures including mandatory TIA submission and suspension of cross-border personal data transfers until the filing obligation is successfully completed.
  • Data protection officer and department appointment violations: Fines of up to VND 30 million (approx. USD 1,132), with potential remedial measures including mandatory appointment of a qualified person and mandatory issuance of policies and documents relating to personal data protection responsibilities.

Transitional Provisions

Decree 330 includes a transitional clause including a provision that where a cybersecurity or personal data protection violation was committed before Decree 330 took effect but is only discovered, or remains under review or resolution, after that date, the sanctions regime in force at the time of the violation will generally apply. However, where Decree 330 imposes no liability or lighter liability for the same conduct, companies may invoke the more favorable provisions.

Outlook and Recommendations

Decree 330 taking effect immediately upon its issuance is a signal that the regulator intends to commence active enforcement. For context, the Vietnam Competition Commission has recently been very active in enforcing consumer protection regulations against major companies, including privacy-related provisions such as requirements to obtain proper consent for the collection and use of personal data. With Decree 330 now in effect, the Ministry of Public Security (the authority responsible for data protection and cybersecurity) has full power to impose penalties for noncompliance with the Law on Personal Data Protection and the Law on Cybersecurity, notably including requirements relating to data protection impact assessments, cross-border data transfer impact assessments, data localization, data protection officers (DPOs) and forms and mechanisms for obtaining consent.

This is particularly significant given that businesses have had over three years to prepare—from the issuance of Decree No. 13/2023/NĐ-CP on personal data protection, which took effect on July 1, 2023, through to the enactment of the Law on Personal Data Protection effective January 1, 2026. Companies should reassess their compliance status and ensure they are prepared to demonstrate compliance when requested by the relevant authorities.

Related Professionals

Industries

Technology

Location

RELATED INSIGHTS​ 

June 13, 2025
In today’s digital age, cyberattacks have become a real threat to organizations worldwide. These attacks can range from phishing and malware to ransomware and distributed denial of service (DDoS) attacks. As the frequency and sophistication of these attacks increase, so does the importance of cybersecurity compliance. In the corporate world, compliance refers to the process of ensuring that a company and its employees adhere to all relevant laws, regulations, standards, and ethical practices—but it should not stop there. Compliance should also encompass asset recovery and disciplinary measures, which can both help organizations address incidents effectively and promote good governance. Cyberattacks are malicious attempts to access or damage a computer system or network, often carried out for financial gain, for political activism, or simply to cause disruption. For instance, a successful attack might involve an attacker creating an email address that closely resembles a legitimate one, perhaps by changing only one or two characters. That email address is then inserted into an existing conversation thread, making it appear as if the user with this email address was already part of the discussion. This tactic can easily deceive a recipient into believing the email was sent from a trusted source, thereby leading them to click on malicious links, provide sensitive information, or even make payments in accordance with the attacker’s request or instructions. Phishing attacks like these are particularly dangerous and can have a serious impact on the ongoing business of a corporation because they exploit the trust and familiarity established in the original email chain. Effective Mitigation Approaches Mechanisms for addressing the aftermath of a crisis provide important recourse to affected organizations, but effective compliance mechanisms can minimize the risk of such crises ever occurring. Companies should therefore prioritize preventative measures and implementation of effective crisis management schemes. Various legal
Read More
May 28, 2025
Tilleke & Gibbins attorneys in Vietnam have contributed the 2025 edition of Doing Business in Vietnam, a comprehensive Q&A-style resource from Thomson Reuters Practical Law that provides essential insights for companies navigating business operations in Vietnam. The guide presents a detailed overview of the country’s legal framework and regulatory environment, reflecting recent updates in Vietnamese legislation and practice. This annually updated guide offers key information on the following areas: Legal system: Structure of the Vietnamese judiciary and the role of codified law. Foreign investment: Conditions for market access, licensing requirements, foreign ownership restrictions, and investment incentives. Business vehicles: Formation and operation of legal entities, including limited liability companies, joint-stock companies, and representative offices. Employment: Employment contracts, social insurance, labor rights, and procedures for hiring foreign nationals. Tax: Overview of corporate income tax, personal income tax, value-added tax, and other tax obligations. Intellectual property: Procedures for protecting and enforcing patents, trademarks, copyrights, and other IP rights. Data protection: Compliance requirements under Vietnam’s data privacy laws, including the Personal Data Protection Decree. Competition law: Antitrust rules and regulatory oversight under the Law on Competition. Anti-bribery and corruption: Legal framework and enforcement practices aimed at curbing corrupt activities. E-commerce and digital business: Regulations governing online platforms, digital content, and cross-border services. Marketing and advertising: Laws and guidelines on advertising standards and consumer protection. Product regulation and liability: Safety requirements, product liability issues, and roles of relevant authorities. Doing Business in Vietnam is part of Practical Law’s global series of legal guides designed to support international practitioners and businesses. To access the most recent edition of the Vietnam guide, visit the Practical Law website and sign up for a free trial.
Read More
May 28, 2025
Thailand’s Food and Drug Administration (FDA) has launched a strategic collaboration with leading e-commerce platforms Lazada and Shopee to strengthen regulatory oversight of health-related products sold online. This partnership is part of a broader initiative to enhance consumer protection, enforce compliance with Thai health regulations, and foster a safer digital marketplace for health products. As part of this initiative, the Thai FDA is urging all sellers—particularly cross-border vendors—to secure proper FDA registration for their products before market entry. The objective is to ensure that only legally authorized, safe, and quality-assured healthcare products are available to Thai consumers. In pursuit of this goal, the FDA has been working closely with Lazada and Shopee to implement proactive surveillance mechanisms aimed at identifying and removing noncompliant, substandard, or unregistered products. This collaboration has already yielded measurable results. Between September 2023 and 2024, Lazada supported regulatory enforcement by removing 9,454 noncompliant listings and delisting 30 vendors. In addition, 134 sellers were subjected to legal proceedings for regulatory violations. Shopee has taken a similarly rigorous stance, committing to the immediate removal of products found to be in breach of FDA regulations. The platform has also provided educational materials for merchants and implemented consumer complaint mechanisms to enhance accountability. Looking ahead, the Thai FDA plans to roll out a data integration system utilizing API technology, enabling seamless and secure exchange of regulatory data between the agency and e-commerce platforms. This system will be supported by comprehensive training for both Thai FDA officials and e-commerce staff, with a particular focus on the use of the Thai government’s Law Enforcement Request Portal, a secure communication channel for coordinating enforcement actions between government agencies and platform operators. Additionally, a joint product inspection framework is currently under development in partnership with Lazada and Shopee. This framework will incorporate strict
Read More
May 26, 2025
On May 21, 2025, the Trade Competition Commission of Thailand (TCCT) published a press release signaling heightened regulation of digital platforms in response to the influx of products from foreign countries being sold in Thailand via e-commerce platforms. In recent years, the rapid expansion of cross-border multi-sided e-commerce platforms has unlocked unprecedented growth, but it has also flooded Thailand’s digital marketplaces with low-cost imports sold by unregulated foreign vendors via these platforms, unfairly undercutting local merchants’ market share and exposing consumers to uneven product quality. According to the press release, the TCCT announced progress on drafting new guidelines on unfair trade practices, monopolistic conduct, and competition restraint by multi-sided e-commerce platforms at a recent meeting of the Management Committee for Addressing Issues of Foreign Goods and Businesses Violating Laws. This regulatory push is part of a broader governmental effort to tackle issues stemming from the foregoing that create uneven playing fields and undermine consumer welfare. The draft guidelines are designed to regulate platform operators and their complex and multidimensional trade relations that cause network effects and distort competition. The forthcoming guidelines, to be issued under the Trade Competition Act B.E. 2560 (2017), will undergo public consultation to ensure platform operators, the public, and other stakeholders will have an opportunity to provide input before they are finalized and enforced. The guidelines are seen as an important priority, with the minister of commerce urging swift implementation of the measures to achieve the government’s objectives. In addition to the legislative advancement, one of the TCCT commissioners has been appointed to advise a subcommittee on preventing nominee arrangements by foreign investors and a subcommittee dedicated to promoting Thai SMEs and eliminating poor-quality imports. The appointee will also support the nationwide task force against illegal foreign products in overseeing proactive field operations and comprehensive
Read More