For companies and individuals doing business in Vietnam, a common question is whether electronic signatures (e-signatures) are legally recognized under Vietnamese law. This matter is governed by Law No. 20/2023/QH15 on Electronic Transactions issued on June 22, 2023 (ETL 2023) and its guiding legal documents such as Decree No. 23/2025/ND-CP dated February 21, 2025, and Circular 06/2024/TT-BTTTT dated July 1, 2024 (Circular 06). Recognition of Validity of E-signatures in Vietnam As a general principle, the ETL 2023 confirms that an e-signature cannot be denied legal validity solely due to its electronic form. The law categorizes e-signatures into three types: Type 1: Specialized e-signatures for organizations Type 2: Public digital signatures for individuals and organizations Type 3: Specialized digital signatures for government agencies Among these types, only secure specialized e-signatures (a secure e-signature of type 1) and digital signatures (type 2) are explicitly granted the same legal validity as handwritten (wet) signatures. This distinction is particularly important in legal disputes and for transactions with government agencies. (For more details, please refer to our previous article.) Domestic e-signatures A domestic organization can choose to use secure specialized e-signatures (type 1) and/or digital signatures (type 2) while a Vietnam-based individual can choose digital signatures (type 2) for their transactions—particularly for those involving government agencies and transactions of high value and complexity which require stronger legal protection. Specialized e-signatures (type 1) can be created by the organizations themselves, and additionally must be “secure” to be explicitly recognized as having the same legal validity as handwritten signatures. For clarity, “secure” specialized e-signatures are those certified (granted a safety certificate) by the Ministry of Science and Technology (MST). (This was formerly the responsibility of the Ministry of Information and Communications, which was merged with MST under Vietnam’s 2025 administrative restructuring.) Digital signatures (type 2) are

On June 27, 2025, Vietnam’s National Assembly adopted a Resolution on International Financial Centers in Vietnam (“IFC Resolution”), which is set to take effect September 1, 2025, putting forward major policy breakthroughs on multiple fronts. The IFC Resolution has the goal of turning Ho Chi Minh City and Da Nang into leading international financial centers with autonomy and tools to compete, thereby raising Vietnam’s position in the global financial network, in association with economic growth drivers. Below are some of the key points of the IFC Resolution, which has notable changes from previous drafts (see our articles on Vietnam’s Draft Resolution on Financial Centers: Implications for Fintech and Banking and Vietnam’s Emerging Regulatory Landscape for Blockchain and Cryptocurrency), including: The removal of the Central Supervisory Agency. The addition of a definition of international financial centers, which are specific geographic areas in Ho Chi Minh City and Da Nang with members entitled to special policies. The addition of a list of entities eligible for membership, and entitlement to the special policies. Major Policy Breakthroughs The IFC Resolution introduces specific policies in the following areas: Liberalization of foreign exchange control for members, including policies such as open foreign exchange use between members and exemption from foreign exchange control procedures for 100% foreign-owned members. Specialized licensing for members to establish and operate single-member limited liability banks and foreign bank branches with the ability to apply accounting standards, debt classification, risk provisions, and prudential ratios according to the owner’s policies. Creation of a capital market for innovative startups, including a crowdfunding mechanism or private placement mechanism through a licensed platform, and development of a green finance market with green certification. Creation of a regulatory sandbox for fintech technologies, products, services, and business models not yet prescribed by law, offering exemption from compliance with

Vietnam’s new Personal Data Protection Law (PDPL) was passed by the National Assembly on June 26, 2025, and will enter into force on January 1, 2026. The PDPL introduces several new concepts, exemptions, and obligations in comparison with the current Decree No. 13/2023/ND-CP on personal data protection (PDPD), while other contents remain essentially the same. The relationship between the PDPD and the PDPL has not been clearly addressed; however, it is expected that the government will issue a new decree providing necessary guidance on certain requirements under the PDPL, and the PDPD will remain in effect until it is replaced by this new decree. Some key points of the new PDPL include the following: Personal data will be further defined by lists of basic personal data and sensitive personal data to be issued by the government. The consent-centric approach of the PDPD remains in place, along with additional exemptions for certain data processing activities. The requirements for the data processing impact assessment (DPIA) and transfer impact assessment (TIA) remain unchanged. However, there are new exemptions for the TIA, including for the processing and storing in the cloud of employee data, and when the data subject is the person sending its own data outside of Vietnam. Consent obtained under the PDPD remains valid under the PDPL. DPIAs and TIAs submitted under the PDPD are valid under the PDPL but may need to be updated to be in line with the requirements of the PDPL. Administrative fines depend on the type of violation. The fine for sale and purchase of personal data will be 10 times the revenue from the sale or VND 3 billion (about USD 115,000), whichever is higher. The fine for cross-border transfer violations is 5% of the violator’s revenue of the preceding year or VND 3 billion,

As from July 1, 2025, as part of its ongoing efforts to digitalize and streamline the delivery of public services, the Vietnamese government will officially conduct administrative procedures, both online and offline, only via electronic identity (“e-ID”) accounts on the VNeID platform. In particular: Online administrative procedures carried out via the National Public Service Portal or via information systems for administrative procedures at the ministerial or provincial level are required to be implemented by using e-ID accounts only. When receiving dossiers, authorities will be required to check and verify the e-IDs of companies or individuals responsible for conducting administrative procedures. Further, it is worth noting that to complete the registration of an e-ID account for a company, the legal representative of the company must hold a level-2 e-ID account. Compliance Considerations Vietnam’s first regulation of e-ID accounts for individuals and organizations was issued in Decree No. 59/2022/ND-CP dated September 5, 2022, on electronic authentication and identification. This decree was subsequently replaced by Decree No. 69/2024/ND-CP dated June 25, 2024, which governs the same matters. Registration and operation of e-ID accounts are centralized through VNeID, a digital ID app developed by the National Population Data Center under the Ministry of Public Security of Vietnam. Although the registration of e-ID accounts for companies is not explicitly mandated by law, the absence of an e-ID account may hinder companies from completing administrative procedures, including licensing and reporting obligations. Such non-compliance could consequently result in administrative penalties. To mitigate unexpected non-compliance and administrative fines due to the lack of an e-ID account, companies should be well prepared for and implement the registration of a company e-ID account as soon as possible.