As Vietnam continues its government restructuring, including the merging of several key ministries, the country is signaling that mergers of provinces could be next. Conclusion 126-KL/TW of the Politburo and Secretariat, issued on February 14, 2025, sets out several tasks for continuing to streamline the political system in 2025, notably including, among others, the following: Elimination of intermediate administrative levels, and mergers of provincial units: The Government Party Committee is tasked with researching and planning for the elimination of intermediate administrative levels (district levels); reorganizing the commune level with structures, functions, duties, powers, and responsibilities aligned with the new organizational model; and proposing the merging of some provincial administrative units. A report to the Politburo is required by Q3 2025. Reorganization of police structure: The Central Public Security Party Committee is tasked with leading and coordinating the implementation of a three-tier police organization, eliminating the district-level police. Judicial system reforms: The Central Party Committees of the Supreme People’s Court and the Supreme People’s Procuracy are tasked with researching and advising on the organizational model for courts and procuracies, and proposing amendments and supplements to relevant party mechanisms and state laws, with the aim of eliminating the district level. A report to the Politburo is required by Q2 2025. Implications of Merging Provinces The merging of provinces could bring positive impacts as well as new challenges. The expected benefits include: Administrative efficiency and cost saving: Reducing the number of administrative units could lead to more efficient governance and decision-making processes, as well as lower administrative costs due to fewer government offices and personnel. Economic development: Larger administrative areas can benefit from better allocation of resources and infrastructure development. Larger provinces may also attract more investment due to increased economic potential and market size. Improved service delivery: Public services could improve

Vietnam’s Decree No. 147/2024/ND-CP on the management, provision, and use of internet services and online information (Decree 147) was issued on November 9, 2024, and came into effect on December 25, 2024. Decree 147 represents a more stringently regulated digital landscape in Vietnam, creating challenges not only for offshore service providers offering cross-border services but also for onshore providers. As these new regulations impose stricter requirements, particularly in areas like content control, user authentication, data storage, and service license/notification, companies will need to adapt quickly to maintain compliance and minimize legal risks. The following are some of the key topics covered by Decree 147. [Note: Shortly after the issuance of Decree 147, Vietnam began a government restructuring process, with the aim of streamlining the government by consolidating and eliminating various ministries and agencies. Thus, the decree’s references to authorities such as the Authority of Broadcasting and Electronic Information (ABEI) and the Ministry of Information and Communications (MIC) are subject to change.] 1. Cross-Border Information Provision Cross-border information provision is defined broadly as the provision by overseas organizations and individuals of information and online information content services for service users in Vietnam to access or use. This wide-ranging definition encompasses various types of cross-border services, including social network services, online game services, and app store services. However, cross-border provision of online game services remains prohibited under Decree 147 (see further details below). Offshore providers of services on a cross-border basis who lease data storage in Vietnam or meet a threshold of 100,000 or more total visits per month from Vietnam for six consecutive months (“regulated cross-border providers”) must adhere to stricter requirements. Specifically, they are required to, among other requirements: Notify the relevant authority of their contact information, including the location of the main server providing the service, within 60

Thailand’s draft Emergency Decree on Technology Crimes Suppression, which we covered in a client alert in January 2025 primarily addressed to telecom operators and financial institutions, is expected to have significant implications for a wide range of business operators.  The draft emergency decree has already been approved by the cabinet but may undergo further developments as it continues in the legislative process. In this article, we will highlight the material impacts of the draft emergency decree on overseas and local fintech operators. Expanded Definition of “Technology Crimes” The definition of “technology crimes” now includes the following acts of forgery or alteration: Forging or altering the identity of individuals and biometric characteristics by utilizing computer or communication systems or other electronic means to commit offenses. Forging or altering symbols, trademarks, or seals of groups (e.g., foundations, community enterprises) or juristic persons, including acts by juristic persons using individuals or juristic persons as nominal directors or shareholders, regardless of whether such individuals or legal juristic persons reside in Thailand. Forging or altering digital or online platforms, regardless of the platform’s location or legal status. Individuals who conspire, utilize, assist, or support the commission of these offenses will face the same penalties as the principal offender. Business Operator Definition The scope of “business operators” is now expanded to cover various fintech and digital asset operators beyond those under the Payment Systems Act (PSA). The draft emergency decree now includes the following operators, whether they are legally authorized or not: Business operators under the PSA and business operators who operate “as if” they are payment system operators Business operators under the Royal Decree on Digital Asset Businesses or business operators who operate “as if” they are digital asset business operators. Foreign exchange business operators. Disclosure and Exchange of Information Business operators must disclose

On January 24, 2025, the prime minister of Vietnam issued Decision No. 232/QD-TTg, approving the proposal for establishment and development of a carbon market in Vietnam. The decision establishes a compliance mechanism for greenhouse gas (GHG) emitters and creates opportunities for investors interested in carbon trading in Vietnam. Market Development Roadmap Decision 232 establishes a phased approach to developing Vietnam’s carbon market, with the following ambitious milestones: Before June 2025 (preparation period): The legal framework for trading of emissions quotas and carbon credits and a carbon-credit offset exchange mechanism will be developed, along with the necessary infrastructure for organization and operation of the carbon-credit market. From June 2025 to the end of December 2028 (pilot period): A pilot domestic carbon exchange will be launched, with continued legal refinements. From 2029 (official launch period): The carbon market will be fully operational. Carbon Market Structure and Trading Mechanisms Vietnam’s carbon market will function as a centralized, government-regulated exchange, trading two main assets: GHG emissions quotas (allowances) allocated to regulated emitters, which can be traded or auctioned; and Carbon credits generated from domestic and international projects that are certified for trading. The carbon credits generated from international projects include those originating from international exchange or offset-crediting mechanisms such as the Clean Development Mechanism (CDM), the Joint Credit Mechanism (JCM), and Article 6 of the Paris Agreement. The National Registration System for GHG emissions quotas and carbon credits will be primarily developed and operated by the Ministry of Natural Resources and Environment. Transactions of GHG emissions quotas and carbon credits will occur on the domestic carbon exchange, managed by the Hanoi Stock Exchange, and will follow a centralized process where verified quotas and credits receive unique domestic codes for trading and participants must have depository accounts. The Vietnam Securities Depository and Clearing Corporation