Vietnam AI Landscape for CEOs

Law 134/2025/QH15 (AI Law).

Passed December 10, 2025. Effective March 1, 2026. Three-tier risk classification (high, medium, low). Mandatory pre-market conformity assessment for high-risk AI. National AI Database registration. Foreign provider local representative requirements. Full compliance guide.

Decree 142/2026/ND-CP.

First implementing decree. Issued April 30, 2026. Effective May 1, 2026. Three-tier risk classification method. 60-day transition period for existing systems (deadline June 30, 2026). 72-hour incident reporting for serious incidents. One-stop portal via MoST.

National AI Database.

Managed by MoST. All AI systems must self-classify and register. Portal not yet fully operational as of July 2026.

Sector-specific rules.

State Bank of Vietnam for banking, Ministry of Health for healthcare, Ministry of Public Security for national security applications.

National AI Development Fund.

Subsidises compute and access to national language models for compliant deployments. Companies engaging the regulatory framework early may qualify.

SME voucher programme.

Vouchers for Vietnamese SMEs adopting compliant AI. Reduces the cost of AI adoption for smaller businesses.

National AI language models.

Vietnam has invested in domestic language model development. Access is preferential for companies with local presence and compliant systems.

Compute infrastructure.

Vietnamese government is investing in AI compute capacity, both cloud and dedicated infrastructure for high-risk applications requiring domestic data processing.

Technology transfer and R&D incentives.

Foreign companies establishing R&D or AI development in Vietnam may qualify for preferential treatment.

Government agencies:

• Ministry of Science and Technology (MoST) - AI Law administration, National AI Database
• Ministry of Information and Communications - technology infrastructure and digital transformation
• State Bank of Vietnam - banking sector AI oversight

Enterprise players:

• FPT (largest domestic IT services group, growing AI practice)
• VNG (technology group, AI investments)
• Viettel (state-owned telco with AI infrastructure)
• Vingroup (VinFast, VinAI research)

Foreign presence:

• Google, Microsoft, Amazon with regional teams
• International consulting firms (McKinsey, BCG, EY) with Vietnam AI advisory practices
• India-based IT services firms scaling Vietnam operations

One. The local representative requirement is structural.

Foreign providers of high-risk AI systems must appoint an authorized local representative in Vietnam. This is different from having a Vietnamese subsidiary. It may require a new legal arrangement.

Two. Registration in the National AI Database is mandatory for high-risk systems.

Portal not yet fully operational as of July 2026. Companies should track its launch and register within the required 30 days when the classification list is published.

Three. Vietnamese personal data localisation matters.

Certain high-risk categories require Vietnamese personal data to be processed on infrastructure with legal presence in Vietnam. Verify whether your current AI stack meets this requirement.

Four. Grace periods are running.

General AI systems: grace period ends March 1, 2027. High-risk sectors (finance, healthcare, education): September 1, 2027. Do not wait for these deadlines.

Five. The National AI Development Fund is a genuine opportunity.

Compliant deployments may qualify for compute subsidies and preferential language model access. Model this into your total cost of AI in Vietnam.

Six. Local partnerships matter.

Vietnamese IT services firms and consulting practices offering AI compliance advisory are the practical way to navigate the framework. FPT, VNG, and larger consulting firms all offer this capability.

Decree 142/2026/ND-CP (May 2026).

First implementing decree established three-tier risk classification method and 72-hour incident reporting. Signal: enforcement infrastructure is being built out systematically.

US Chamber of Commerce letter (May 20, 2026).

US Chamber of Commerce and US-ASEAN Business Council filed letter raising concerns about certain restrictive provisions. Signal: framework is being actively contested by industry.

Regional headquarters implications (rolling 2026).

Singapore-headquartered companies with Vietnam operations are the most exposed to the local representative requirement. This is under-flagged in most regional risk reviews.

MoST classification list (expected Q3 2026).

Formal high-risk AI classification list from Prime Minister still pending. Once published, 30-day registration clock starts. Signal: monitor closely for triggers.

Can I use my Singapore subsidiary as my authorized local representative in Vietnam?

No. The representative must be a legal entity or natural person resident in Vietnam. This surprises many regional headquarters.

How does Vietnam's law differ from Singapore's Model AI Governance Framework?

Singapore's framework is voluntary and principles-based. Vietnam's law is mandatory and prescriptive. The two coexist but require different compliance approaches.

Are Vietnamese state-owned enterprises subject to the AI Law?

Yes. State-owned enterprises face the same tier-based obligations. However, national security applications have specific exemptions and sector-specific rules.

Can I access the National AI Development Fund as a foreign company?

Yes, provided you engage the regulatory framework and have qualifying operations in Vietnam. Specific eligibility depends on the fund's ongoing rules.

What is the biggest compliance mistake foreign companies make in Vietnam?

Assuming existing regional legal structures satisfy the local representative requirement. Many Singapore or Hong Kong-headquartered companies discover during implementation that they need a new Vietnam-specific arrangement.