On 10 December 2025, the National Assembly of Vietnam passed Law No. 134/2025/QH15 on Artificial Intelligence (the “AI Law“). Taking effect on 1 March 2026, this landmark legislation makes Vietnam one of the first countries in Southeast Asia to establish a comprehensive, risk-based regulatory framework for the research, development, provision, deployment, and use of AI systems. The AI Law applies to both domestic and foreign entities, introducing stringent compliance obligations for high-risk applications while establishing incentives, funding, and sandbox mechanisms to foster innovation.
Key highlights:
- Risk-Based Classification System
Mirroring global regulatory trends such as the EU AI Act, the AI Law categorizes AI systems into three risk tiers based on their potential impact on human rights, safety, security, and public interests:
High-Risk AI Systems: Systems that pose significant potential harm to life, health, national security, or lawful rights. These are subject to strict regulatory controls, including mandatory pre-market conformity assessments (for specific systems to be listed by the Prime Minister), ongoing risk management, human oversight mechanisms, and registration via the national AI portal.
Medium-Risk AI Systems: Systems carrying risks such as user confusion or minor market disruptions. These require monitoring via reports, sample audits, and transparency disclosures to users.
Low-Risk AI Systems: Systems with minimal impact. These face minimal regulatory oversight but are monitored for incidents and encouraged to adhere to voluntary best-practice guidelines.
- Extraterritorial Reach and Local Presence Requirements
The AI Law captures foreign organizations participating in AI-related activities in Vietnam. Notably, foreign providers of High-Risk AI systems that are subject to pre-market conformity assessments must establish a commercial presence or appoint an authorized representative in Vietnam. Providers of other High-Risk systems must, at a minimum, maintain a lawful local contact point.
- Transparency and Content Labeling
To combat misinformation and deepfakes, the AI Law imposes strict transparency rules across the digital landscape:
- Users must be clearly informed when they are interacting with an automated AI system.
- Audio, image, and video content generated by AI must be conspicuously marked or labeled in a machine-readable format to ensure users can identify its artificial origin.
- Deployers must clearly notify users if AI-generated content poses a risk of confusion regarding the authenticity of real events or characters.
- Prohibited AI Practices
The AI Law strictly bans the use of AI for unlawful purposes, including:
- Using fabricated elements or simulating real persons/events to intentionally and systematically deceive or manipulate human perception and behavior.
- Exploiting vulnerable groups.
- Circumventing safety controls or human oversight mechanisms.
- Violating intellectual property, cybersecurity, or personal data protection laws.
- Incident Reporting
All stakeholders share responsibility for system safety. In the event of a serious incident (defined as events causing or risking significant damage to life, property, cybersecurity, or critical systems), entities must immediately implement technical fixes, suspend operations if necessary, and report the incident through the newly established National Single-Window AI Portal overseen by the Ministry of Science and Technology (MOST).
- Grace Period for Existing Systems
While the law officially enters into force on 1 March 2026, transitional relief is available for AI systems already in operation before this date:
- 18-Month Grace Period: For AI systems deployed in the fields of finance, healthcare, and education (full compliance required by 1 September 2027).
- 12-Month Grace Period: For AI systems operating in all other sectors (full compliance required by 1 March 2027).
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Please do not hesitate to contact Dr. Oliver Massmann under [email protected] if you have any questions or want to know more details on the above. Dr. Oliver Massmann is the General Director of Duane Morris Vietnam LLC.