On December 31, 2025, the government of Vietnam promulgated Decree No. 356/2025/ND-CP detailing and guiding the implementation of the new Personal Data Protection Law (PDPL) that was issued in June 2025. The new decree, like the PDPL, entered into force on January 1, 2026, with the previous Decree No. 13/2023/ND-CP on personal data protection ceasing effect on the same day. Some key points of the new decree include the following: Comprehensive lists of basic and sensitive personal data are provided, which will require companies to review again their existing documents and data type classification to ensure compliance. New timelines are established for responding to specific data subject requests. These timelines are more reasonable and longer than the previous 72-hour requirements. Additional consent guidelines are provided, prohibiting default consent or ambiguous instructions that confuse data subjects about giving or withholding consent. Mandatory content for data transfer agreements/clauses in particular cases is provided. This covers, among other things, (i) the legal basis for the transfer of personal data; (ii) responsibilities for personal data protection during the transfer and processing of personal data; (iii) responsibilities for ensuring the exercise of the rights of personal data subjects; and (iv) responsibilities for coordination and compliance of the parties in cases where violations of personal data protection regulations are detected. The qualifications and responsibilities of data protection officers (DPOs) and data protection departments include, among others, having been trained and fostered in legal knowledge and professional skills regarding personal data protection. There are no specific provisions governing the qualifications or requirements for organizations that provide data protection training or education. New mandatory templates and requirements are provided in relation to data processing impact assessment and data transfer impact assessment, and for cases in which companies need to re-submit assessments to the regulator. Stricter requirements are

Tilleke & Gibbins has updated the Cambodia, Myanmar, Thailand, and Vietnam chapters in Multilaw’s Global Data Protection Guide, which collects expert advice from Multilaw member firms in 90 jurisdictions around the world (including a Laos chapter, which is also authored by Tilleke & Gibbins). The guide provides answers to key issues concerning the fast-developing data protection and privacy laws around the world, and helps data protection officers and in-house counsel understand how the regulatory regime for data protection can affect their organizations in various jurisdictions. Each section of the guide identifies the main laws that govern data protection in that jurisdiction, and gives a detailed overview of the legal principles in place as well as the enforcement authorities responsible for overseeing compliance. The guide also covers issues related to data subject rights, data protection officers, impact assessments, data breach notification requirements, and cross border data transfers. The use of personal data in marketing is also considered, with specific information on electronic marketing rules, cookies, and marketing to businesses and consumers. Multilaw, of which Tilleke & Gibbins is a longtime member, is a global network of carefully selected independent law firms able to provide expert legal advice in complex environments around the globe. The full guide is available for free on the Multilaw website.

Tilleke & Gibbins has contributed the Vietnam chapter to the latest edition of the Global FinTech Guide published by Multilaw. The guide provides a comprehensive overview of the legal and regulatory framework governing financial technology across major jurisdictions around the world. Compiled by experienced practitioners from Multilaw member firms, the Global FinTech Guide examines how technological innovation is transforming financial services and how regulators are adapting to developments such as digital payments, virtual assets, and online financial platforms. The publication offers comparative insights into regulatory regimes and presents detailed, jurisdiction-specific analysis for companies, investors, and entrepreneurs active in the FinTech sector. The Vietnam chapter, prepared by lawyers in Tilleke & Gibbins’ technology, media, and telecommunications team, surveys the key legal and regulatory developments shaping the country’s FinTech ecosystem. It covers the following areas: Payment services Asset and portfolio management Financial advisory and broking services (including robo-advisory and auto-trading) Trading platforms, social trading platforms, and signal following Crowdfunding, crowdinvesting, and crowdlending Distributed ledger technology (DLT) and cryptocurrencies Loan services, factoring, loan broking, and finetrading Identification Online banking services Initial coin offerings (ICOs) and token sales Insurtech Regtech and compliance management Know-your-customer (KYC) requirements Tilleke & Gibbins also contributed the Thailand chapter to the Global FinTech Guide. The full guide is available on the Multilaw website.

On September 15, 2025, Vietnam’s Ministry of Science and Technology announced that the country will issue an updated version of its National AI Strategy (first issued in 2021) and its first-ever AI Law by the end of this year. The ministry emphasized that the AI strategy is not just a legal framework, but a commitment to embracing AI to drive Vietnam into a new era. The AI adoption plan is set as a priority of the country, and marks a significant step in shaping Vietnam’s AI governance and innovation landscape. Highlights of the plan include the following: Strategic vision. Vietnam’s ambition is to leverage AI for economic growth, social development, and global competitiveness, under the guiding principle “AI for humans – safe, autonomous, cooperative, inclusive, and sustainable.” AI as national infrastructure. The updated strategy positions AI as core national infrastructure, comparable to electricity or the internet, aiming to provide every citizen with a “personal digital assistant.” Core principles for AI legislation. The AI Law will be built around the following six core principles: Risk-based regulation Transparency and accountability Human-centric development Domestic AI autonomy AI as a driver of sustainable growth Digital sovereignty, with data, infrastructure, and AI technology being three strategic pillars Ethics and openness. A National AI Ethics Code will accompany the upcoming law, aligned with international standards but tailored to the Vietnamese context. The government emphasizes open standards and open-source development. Market development and incentives. The government plans to expand domestic AI adoption, particularly in public services and key industries. The National Technology Innovation Fund (NATIF) will allocate at least 40% of its budget to AI projects, prioritizing SMEs through vouchers for locally developed AI solutions. Background on AI Law Development Regulations on AI are found in various Vietnamese laws and regulations, notably the recently adopted Law