On September 15, 2026, Vietnam’s Ministry of Finance (MOF) released for public consultation a draft circular on reporting and information disclosure in the pilot crypto asset market. The draft implements Resolution No. 05/2025/NQ-CP on the Pilot Implementation of the Crypto Asset Market in Vietnam and provides further detail on how licensed crypto asset service providers (“CASPs”) will be supervised once the market becomes operational. The draft indicates a data-intensive supervisory model, with licensed CASPs serving as the first line of market oversight. Public Disclosure Requirements The draft imposes detailed public disclosure requirements on CASPs, aimed primarily at market transparency. CASPs and crypto asset issuers must make disclosures in both Vietnamese and English, retain reported and disclosed information for at least 10 years, and keep information published on their websites accessible for at least five years. For CASPs, disclosure obligations arise both periodically and when specific events occur. A CASP must announce any crypto asset to be admitted to trading on its website at least seven days before trading begins and publish periodic financial statements. Certain extraordinary events and information requested by the MOF must generally be disclosed within 24 hours. CASPs must also provide ongoing market information. During trading hours, they must publish key trading data, including prices and volumes, daily highs and lows, average prices, the three best bid and offer levels, and transactions by foreign investors. By 9:00 a.m. each trading day, they must publish specified information on the previous day’s trading activity. Regulatory Reporting Requirements Separate from public disclosure, the draft requires CASPs to provide regulators with detailed information enabling ongoing supervision of their operations and the market. For market activity, CASPs must report decisions to admit or remove a crypto asset from trading within 24 hours, submit previous-day trading data to the State Securities Commission

On July 22, 2026, the government of Vietnam issued Decree No. 292/2026/ND-CP detailing the implementation of the Law on Foreign Trade Management (Decree 292). Decree 292 came into effect on September 5, 2026, replacing Decree No. 69/2018/NND-CP, and introduces several important changes to Vietnam’s foreign trade regime. Of particular relevance is the addition to the list of goods prohibited from importation of “products and goods extracted, produced, or manufactured wholly or partly through forced labor by enterprises, countries, or territories in accordance with relevant international treaties to which the Socialist Republic of Vietnam is a party.” This new prohibition introduces forced-labor considerations into Vietnam’s import compliance framework and may have practical implications for how businesses manage related risks across their operations and supply chains. Implementation of the New Prohibition According to Decree 292, the minister or head of the relevant ministerial-level agency is responsible for publishing the detailed list and corresponding harmonized system (HS) codes for each category of goods prohibited from export or import under its purview. Goods involving forced labor fall under the purview of the Ministry of Home Affairs. However, as of the date of this article, no corresponding list has been published specifying the goods to which the forced-labor prohibition applies, leaving businesses without official guidance on how the prohibition will be applied or enforced in practice. Nevertheless, this absence does not suspend the prohibition’s application. As Decree 292 has already taken effect, goods involving forced labor remain subject to the general legal framework applicable to goods prohibited from importation. In particular, Decree 169/2026/ND-CP provides for administrative penalties for the importation or transportation of prohibited goods into Vietnam. Depending on the nature and circumstances of the violation, criminal liability may also arise under the Criminal Code. In practice, enforcement is likely to depend on the

Vietnam is implementing and developing a broad package of regulatory reforms that could reshape how IP, data, digital platforms, and product authenticity are regulated and enforced. Several of the key measures have been led by the Ministry of Public Security in its legislative and administrative capacity, as part of a broader government effort. The core reform package consists of four key legal instruments: proposed amendments to the Criminal Code, a proposed new Data Security Law, a draft Decree on Product Identification, Authentication and Traceability, and the newly enacted Decree No. 330/2026/ND-CP. These instruments include rules on criminal enforcement, data security, electronic identification, product identification and traceability, administrative violations, and cybersecurity sanctions. Combined, these measures will affect copyright enforcement, industrial property rights, trade secrets, AI training data, product provenance, online takedowns, valuation of counterfeit goods and electronic evidence. It is worth noting that, in addition to strengthening criminal penalties for IP crimes, Vietnam’s emerging regulatory framework increasingly treats infringement, data misuse, product authentication, and platform-enabled violations as interconnected regulatory and enforcement challenges. For rights holders and foreign investors, this could mean stronger tools against counterfeiting and online infringement, but also more compliance obligations around data, traceability, AI, platform controls and government-facing reporting. Expansion of Criminal IP Enforcement Proposed amendments to Article 225 of the Criminal Code would expand criminal copyright exposure beyond reproduction and distribution to cover large-scale commercial public performance and online communication of works, phonograms and video recordings. This is important because piracy is increasingly about streaming, unauthorized communication, and platform access models rather than physical copying. Aggravated copyright infringement could be subject to up to 10 years in prison for individuals and fines of up to VND 6 billion (about USD 228,300) for commercial legal entities. The amended Article 226 would expand criminal industrial property liability beyond

In August 2026, Vietnam’s Ministry of Industry and Trade released a draft decree to replace Decree No. 35/2020/ND-CP detailing certain articles of the Competition Law (Decree 35). The key changes under the draft decree and their implications for M&A transactions in Vietnam are summarized below. Definition of “Management Body” Decree 35 uses the term “management body” (bộ phận điều hành) as one of the criteria to determine the group of affiliated enterprises for the purpose of merger filing. However, there is no definition of the term, leaving enterprises without a basis on which to apply it consistently. The draft decree introduces a statutory definition of “management body,” being a person or group of persons who (i) own more than 50% of charter capital or voting shares; (ii) hold ownership or use rights over more than 50% of an enterprise’s assets; (iii) are an enterprise manager under enterprise law; or (iv) have decision-making power over the enterprise’s resolutions, daily business operations, or business and investment plans. This helps enterprises better assess the scope of merger filing. Determination of Relevant Product Market Under Decree 35, the relevant product market is defined solely by reference to goods and services interchangeable in characteristics, intended use, and price without accommodating digital or zero-price products. The draft decree expands the relevant product market to include “products” (sản phẩm) in addition to traditional “goods and services,” which captures digital information products, AI products, and other novel offerings. Additionally, it adds “other relevant competitive factors” such as quality of products, goods, and services for determining the relevant product market, supplementing the existing factors of characteristics, intended use, and price. This addresses cases where price substitutability is not meaningful for certain consumers or users, i.e., zero-price products. Determination of Relevant Geographic Market Under Decree 35, only physical geographic