Vietnam has progressively positioned blockchain as a strategic technology within its broader digital transformation agenda over the past decade. From early policy orientations to more recent legislative developments, the regulatory approach has gradually shifted from high-level recognition to more concrete legal integration. Against this backdrop, a new draft decree regulating activities relating to product and goods identification, authentication, and traceability (the “Draft Decree”) marks a notable turning point.
Rather than merely referencing blockchain as a policy priority, the Draft Decree incorporates blockchain directly into a nationwide regulatory system, positioning it as part of the underlying infrastructure for data governance and public administration in relation to the management, verification, and traceability of product-related data.
Evolution of Vietnam’s Blockchain Legal Framework: The Draft Decree in Context
Vietnam’s blockchain legal framework has developed in several distinct phases. The first phase, beginning around 2019, was characterized by high-level policy recognition in several resolutions of the Party Central Committee. Particularly, blockchain was identified as part of the broader category of digital technologies critical to industrial modernization and participation in the Fourth Industrial Revolution. These resolutions did not regulate blockchain directly, but established its strategic importance at the national level.
The second phase (2023 to 2025) saw the introduction of national strategies and technology policies that more explicitly recognized blockchain as a priority technology. Those policies collectively signaled a clear policy commitment to developing blockchain infrastructure and applications. However, these instruments remained largely at a policy-level and did not establish binding regulatory frameworks.
The third phase (from 2025) involves the gradual integration of blockchain into sectoral legislation. Laws such as the Law on Digital Technology Industry (2025), the Law on Personal Data Protection (2025), and the Law on Science, Technology, and Innovation (2025) have introduced concepts such as digital assets, crypto assets, and even specific provisions relating to blockchain (e.g., personal data protection in blockchain systems). At the same time, regulatory frameworks for international financial centers and different sandbox regimes have begun to create controlled environments for blockchain-based business models.
Within this evolving landscape, the Draft Decree represents a transition to a potential new phase: the operationalization of blockchain within a concrete regulatory system. Unlike previous instruments, it does not merely recognize or encourage blockchain. Instead, it embeds the use of blockchain within a national infrastructure for product identification, authentication, and traceability. In this sense, the Draft Decree occupies a unique position within Vietnam’s legal framework, serving as one of the first instruments to translate blockchain policy into enforceable regulatory architecture.
Blockchain Architecture for Product Identification, Authentication, and Traceability
On its face, the Draft Decree is a sector-specific instrument aimed at standardizing identification, authentication, and traceability requirements for products and goods. However, it reflects a broader regulatory objective: the establishment of a blockchain-based national digital infrastructure for the identification, authentication, and traceability of product-related data. The Draft Decree places these functions within an integrated ecosystem comprising a national platform, a national database, and data-sharing mechanisms.
A key structural feature is the introduction of a two-layer system. The National Blockchain Platform functions as the infrastructure layer responsible for recording, verifying, and ensuring the integrity of product data, while the National Platform for Identification, Authentication, and Traceability operates as the application layer built on top of that infrastructure. The latter manages operational processes such as product identification, certification, and lifecycle tracking, while relying on the blockchain layer to ensure trust and verifiability of data.
This layered architecture is significant because it positions blockchain as a foundational “trust layer” rather than a peripheral technology. Moreover, the National Blockchain Platform is designed as a shared infrastructure capable of supporting multiple systems requiring data authentication, suggesting that traceability is only the first use case in a broader national strategy for blockchain deployment. As such, the Draft Decree goes beyond regulating traceability and instead establishes the technological and regulatory groundwork for future blockchain-based systems.
UID, DID, and Blockchain-Based Verification
The Draft Decree introduces a structured traceability mechanism based on two distinct but interrelated identifiers. Each product is assigned a unique identifier (UID), which serves as the anchor linking all data generated throughout its lifecycle. The UID can be understood as the product’s “digital passport”, consolidating information such as origin, certifications, and supply chain events into a single reference point.
At the same time, each participating entity is assigned a decentralized identifier (DID), created on the National Blockchain Platform and linked to its electronic identity. The DID functions as a blockchain-based identity, enabling entities to digitally sign data, issue certificates, and participate in verification processes.
The use of both UID and DID reflects a deliberate separation between the product and the actor. The UID identifies the object being tracked, while the DID identifies the entity responsible for generating or verifying data. This dual-identifier system enables both traceability and accountability since every piece of data can be linked not only to a product, but also to a verifiable identity. Within this framework, blockchain acts as the infrastructure layer that records data immutably, links it to verified identities, and enables verification through cryptographic mechanisms.
Legal Recognition of Blockchain-Based Data and Integration with Existing Frameworks
The Draft Decree recognizes the legal validity of digital data where such data is properly created and authenticated in accordance with prescribed procedures. Digital certificates associated with products are accorded the same validity as originals, and data authenticated through the system may, in certain circumstances, be treated as equivalent to source data stored in national or specialized databases.
This recognition is particularly important because it bridges blockchain-based systems with existing legal frameworks. It aligns with the Law on Electronic Transactions and regulations on digital signatures and trust services, which recognize electronically authenticated data, while also supporting the implementation of traceability requirements under the Law on Product and Goods Quality. At the same time, the Draft Decree integrates with the broader data governance regime under the Law on Data, including national databases and data-sharing mechanisms, thereby ensuring interoperability across systems.
In this sense, the Draft Decree brings together multiple legal regimes, from product quality, electronic transactions, to data protection, by integrating them into a single, blockchain-enabled system.
Outlook
Taken as a whole, the Draft Decree signals a shift from policy-level recognition of blockchain to its practical implementation. The focus on product identification, authentication, and traceability as the first use case reflects both immediate regulatory needs and the suitability of blockchain for managing data generated across multiple parties and stages in the supply chain.
More importantly, the architecture introduced by the Draft Decree has broader implications beyond traceability. The combination of DID, UID, digital certificates, and blockchain-based verification mechanisms creates a modular framework that could be extended to other sectors, including digital identity, asset registries, financial services, and public administration, to name a few. This suggests that the Draft Decree is not merely a sector-specific regulation, but a foundational step toward a broader blockchain-enabled regulatory ecosystem.
For businesses, this development presents both opportunities and constraints. While it opens up demand for enterprise blockchain solutions, digital identity infrastructure, and data authentication services, it also signals a regulatory preference for state-led, permissioned blockchain models integrated with national infrastructure. As a result, it seems that at this phase, blockchain businesses operating in Vietnam may need to align with government systems and compliance frameworks, rather than relying on fully decentralized or permissionless models.
