On July 27, 2026, the State Bank of Vietnam (SBV) released a draft decree proposing amendments to Decree No. 52/2024/ND-CP dated May 15, 2024, on non-cash payments (Decree 52). The draft decree would amend 17 of Decree 52’s 38 articles, with several key changes directly affecting providers of intermediary payment service (IPS). The key proposed changes affecting IPS providers are outlined below. Streamlining IPS Licensing Procedures A central objective of the draft decree is to simplify regulatory procedures for IPS providers. Notably, it would significantly reduce IPS licensing documentation requirements by removing the need to submit enterprise registration certificates, investment registration certificates, and documents evidencing the qualifications of the legal representative and general director. Instead, the SBV would retrieve this information directly from national business registration and other specialized databases, requesting additional documents only where the relevant information cannot be verified electronically or is incomplete. The draft decree also removes the current limit of two rounds for dossier supplementation and shortens processing timelines for several IPS licensing procedures such as issuance, amendment, and reissuance of IPS licenses. The processing time for new IPS license applications would be thereby reduced from 90 to 60 working days. In addition, several continuing IPS business conditions would be removed. For example, IPS providers would no longer be required to maintain certain representations relating to corporate restructuring or the legality of contributed capital. Likewise, the IPS project plan (đề án) would become a one-time application document rather than an ongoing licensing condition. If retained in the final decree, this change could provide IPS providers with significantly greater flexibility to implement post-licensing technology upgrades, system integrations, and corporate restructuring transactions without needing to revisit the originally approved project plan. The draft decree also removes the requirement for the SBV to consult the Ministry of Public

The drug registration process in Vietnam will be simplified, particularly for foreign applicants, following the recent issuance by Vietnam’s Ministry of Health (MOH) of a new circular that is expected to reduce administrative hurdles. Circular No. 32/2026/TT-BYT on the registration of drugs and medicinal ingredients (Circular 32) was issued on July 29, 2026, and will take effect on October 1, 2026, replacing Circular No. 12/2025/TT-BYT. Key provisions of the new circular are discussed below. Five-Year Data Exclusivity and Five-Month Public Disclosure Framework Circular 32 updates data protection guidelines by explicitly referencing Article 128 of the amended Intellectual Property Law, which sets out that new drugs supported by clinical trial data submitted for the first time will be granted a five-year data exclusivity period from the date of the initial marketing authorization (MA) approval. Subsequent applications that rely on the originator’s protected data will not be eligible for approval from the date of submission of the originator’s registration dossier until five years after the first MA is granted. Furthermore, in accordance with the new regulations, the regulatory authority must publicly disclose information on subsequent applications five months before the granting of MA, providing originator companies with an opportunity to exercise and enforce their intellectual property rights. Simplified Requirements for Foreign Legal Documents Circular 32 expands the circumstances under which legal documents issued by foreign authorities are exempt from consular legalization and authenticity verification requirements. Specifically, such documents may be exempt if the Drug Administration of Vietnam (DAV) is able to verify their authenticity directly through official electronic means, including written confirmation or email correspondence sent directly to the MOH by the competent foreign authority, or publicly accessible English-language databases maintained by recognized foreign regulatory authorities. In addition, the new circular permits the submission of electronic notarized copies of legal documents

Tilleke & Gibbins has contributed the Vietnam chapter to Fintech 2027, a global guide published by Lexology Panoramic that provides comparative insights into the legal and regulatory frameworks governing fintech businesses across multiple jurisdictions. The Vietnam chapter offers a comprehensive overview of the country’s rapidly evolving fintech landscape, examining both the regulatory environment and practical considerations for businesses operating in or entering the Vietnamese market. Topics covered include: Fintech landscape and initiatives: General innovation climate; government and regulatory support Financial regulation: Regulatory bodies; regulated activities; consumer lending; secondary market loan trading; collective investment schemes; alternative investment funds; peer-to-peer and marketplace lending; crowdfunding; invoice trading; payment services; open banking; robo-advice; insurance products; credit references Cross-border regulation: Passporting; requirement for a local presence Sales and marketing: Restrictions on the promotion and marketing of financial products and services Cryptoassets and tokens: Distributed ledger technology; cryptoassets; token issuance Artificial intelligence: Regulatory framework governing AI systems and AI-enabled financial services Change of control: Notification and consent requirements for regulated businesses Financial crime: Anti-bribery and anti-money laundering procedures; regulatory guidance Data protection and cybersecurity: Data protection obligations; cybersecurity requirements applicable to fintech businesses Outsourcing and cloud computing: Outsourcing of material functions; use of cloud computing in the financial services industry Intellectual property rights: IP protection for software; employee- and contractor-created IP; joint ownership; trade secrets; branding; remedies for infringement Competition: Competition law issues affecting fintech businesses Tax: Incentives for innovation and investment; developments affecting tax and compliance obligations Immigration: Immigration options for recruiting skilled foreign personnel; special measures available through Vietnam’s international financial centers The chapter also examines a number of significant recent developments shaping Vietnam’s fintech sector, including the introduction of the country’s first comprehensive regulatory framework for cryptoassets, the adoption of a dedicated law on artificial intelligence, implementation of the banking regulatory sandbox,

Vietnam’s new E-Commerce Law, which took effect on 1 July 2026 along with its implementing Decree No. 248/2026/ND-CP (Decree 248), marks a significant development in the country’s approach to online intellectual property (IP) enforcement, reflecting a clear shift from a reactive model of intermediary liability to one that expects platforms to play a more active role in preventing infringement. From notice-and-takedown to platform responsibility The most significant change introduced by the E-Commerce Law is the transformation of the legal role of e-commerce platforms. The existing safe harbor provisions under the IP Law and the copyright notice-and-takedown regime established by Decree 17/2023/ND-CP (Decree 17) largely required intermediaries to act only after receiving notice of infringement. Once infringing content had been removed, the platform’s legal obligation was generally considered fulfilled. The new legislation adopts a fundamentally different approach. Article 17 of the E-Commerce Law requires intermediary platforms to screen information relating to goods and services before publication in order to prevent listings involving counterfeit or IP-infringing goods, and goods of unknown origin. Rather than relying exclusively on complaints from rights holders, platforms are now expected to implement preventive measures before infringing listings become publicly available. Decree 248 further requires platforms to update keyword filters based on recommendations issued by competent authorities. These filtering mechanisms are intended to prevent prohibited listings from appearing on the platform and represent a further move away from a purely complaint-driven enforcement model. The legislation also introduces Vietnam’s first statutory stay-down obligation. Under the E-Commerce Law and Decree 248, major digital platforms must maintain automated systems capable of reviewing, warning against, and removing unlawful listings while also implementing measures to prevent repeat violations, defined under Decree 248 as conduct that has previously been identified and handled by the platform, but continues to recur. This obligation addresses one