Vietnam has introduced an official list of high-risk AI systems, triggering more stringent compliance obligations for developers, suppliers, and deployers operating in the country. On June 30, 2026, the prime minister issued Decision No. 33/2026/QD-TTg (Decision 33), which establishes the List of High-Risk AI Systems under the Law on Artificial Intelligence (AI Law) and Decree No. 142/2026/ND-CP (Decree 142). Decision 33 takes effect on August 15, 2026. Decision 33 is significant because only AI systems included on the list will be subject to the heightened compliance obligations applicable to high-risk AI systems under the AI Law and Decree 142. These include, among others, local presence requirements for foreign providers, mandatory conformity assessment before deployment, comprehensive risk management and data quality documentation, and strict liability for damages even when the provider is fully compliant. Decision 33 also specifies the applicable conformity assessment pathway for each listed system, indicating whether the system must undergo mandatory third-party conformity certification before being placed into use, or whether the provider may self-assess conformity or voluntarily engage a registered or recognized conformity assessment body. Which AI Systems Are Covered? Decision 33 identifies high-risk AI systems across six sectors—the key attributes of which are summarized below. Education: AI systems used for automated assessment, learner ranking, behavioral monitoring, or generating educational content from uncontrolled data sources. Ethnic affairs and religion: AI systems used to automatically score, classify, or rank applications for government ethnic policies; approve or reject regulatory applications; suspend benefits on suspicion of fraud; allocate budgets; or infer and classify individuals by ethnicity or religion for administrative purposes. Healthcare: AI-assisted surgical systems and autonomous AI-powered surgical robots. Banking: AI systems that autonomously conduct electronic banking transactions or make credit approval decisions. Judicial proceedings: Certain large-scale biometric identification systems used in public-interest civil proceedings. Transport: Thirty-one categories

Vietnam’s AI regulatory framework has reached an important milestone. While the Law on Artificial Intelligence No. 134/2025/QH15 (AI Law) established the foundation for AI governance, many practical compliance requirements were left to implementing regulations. On April 30, 2026, the government issued Decree No. 142/2026/ND-CP (Decree 142), which took effect on May 1, 2026, and provides the first detailed guidance on the implementation of the AI Law. Although an official list of high-risk AI systems is still pending from the prime minister, Decree 142 provides valuable insight into how Vietnam’s risk-based AI regulatory framework will operate in practice. Risk Classification Framework The AI Law adopts a risk-based approach under which AI systems are classified as high-risk, medium-risk, or low-risk. Decree 142 builds on this framework by providing detailed guidance on how these classifications are determined. High-risk AI systems are determined based on factors such as (i) their potential impact on life, health, property, human rights, public interests, or national security; (ii) the sector in which they are deployed; and (iii) the scale of affected users or integration with critical infrastructure. The latest draft list of high-risk AI systems appears to follow these same principles. Medium-risk AI systems generally include systems that may mislead, influence, or manipulate users, particularly where users may not realize they are interacting with AI or AI-generated content. The focus is therefore on transparency and authenticity risks rather than broader societal or safety concerns. Low-risk AI systems are those that do not meet the criteria for either high-risk or medium-risk classification. Importantly, Decree 142 seeks to avoid over-classification. Certain systems may fall outside the high-risk or medium-risk regimes, including internal-use systems, office-support tools, technical editing applications, certain back-end processing systems, and AI systems used in artistic, gaming, cinematic, or other creative contexts. Providers must also review and

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

Vietnam’s emerging governance framework for artificial intelligence (AI) is developing through a multi-layered structure comprising three components: Policy instruments setting national priorities for AI development; Regulatory framework governing development, provision, deployment and use of AI; and Technical standards and voluntary guidelines. Policy level. At policy level, the foundation for a strategic framework for AI development and governance was laid in 2021 by the National Strategy for Research, Development and Application of AI until 2030, aimed at strengthening the national AI ecosystem and positioning Vietnam as a regional AI innovation hub. Subsequently, resolution No.57-NQ/TW (2024) identified AI as a key driver of science, technology, innovation and national digital transformation. AI was also designated as a strategic technology under decision No.1131/QD-TTg (2025) listing priority technologies across sectors. Regulatory framework. At the legislative level, the new Law on Artificial Intelligence took effect on 1 March 2026, establishing the core regulatory framework governing development, provision, deployment and use of AI systems. Controlled testing for emerging AI technologies is implemented under the Law on Science, Technology and Innovation. The AI Law is expected to be further operationalised through implementing instruments, most notably a draft decree guiding the AI Law, and draft decision of the prime minister identifying high-risk AI systems (both published in February 2026). A decision establishing priority datasets for AI development is also anticipated. Compliance obligations may also arise under sectoral regulatory regimes, including data protection, cybersecurity, banking, consumer protection, e-commerce and intellectual property, particularly where AI systems are used in automated decision-making or data-driven services. Technical standards and non-binding guidelines. Vietnam’s AI governance framework is also supported by technical standards and voluntary guidelines. A key instrument is decision No.1290/QD-BKHCN (2024), providing guidelines for responsible research and development of AI systems, and represents Vietnam’s first national AI ethics code. The Ministry of Science and Technology