An Overview of the Legal Framework of Vietnamese AI Law

Introduction

As of 2026, the integration of Artificial Intelligence within Japanese enterprises has matured from experimental tools into "standard infrastructure", with adoption rates for business operations reaching nearly 70%. With domestic AI infrastructure investment surging into the hundreds of billions of yen, Japanese firms have moved beyond the Proof of Concept (PoC) stage towards full-scale, enterprise-wide implementation.

Simultaneously, Vietnam has undergone a profound transformation. Shifting away from its traditional reputation as a mere "offshore development hub", Vietnam has emerged as one of Southeast Asia’s premiers "AI growth markets". In early 2026, its AI adoption rate surpassed the global average, necessitating a robust legal foundation. This has culminated in the enactment of the Law on Artificial Intelligence 2025 (Law No. 134/2025/QH15) (the “AI Law”).

The defining feature of this legislation is its departure from the "soft law" approach favoured in Japan. Instead, Vietnam has implemented a binding "risk-based" regulatory framework. Under this system, AI applications categorised as "high-risk" are subject to mandatory conformity evaluations and rigorous technical documentation requirements. Furthermore, the law establishes AI as a key momentum for national growth and a new production method.

This article features the current AI business landscapes in both nations and provides a detailed analysis of how this landmark law—effective from March 2026 —impacts Japanese investors seeking to deploy AI systems or provide cross-border services within the Vietnamese market.

This article is the product of a collaborative effort between two law firms committed to supporting the growth of the Japan–Vietnam business relationship in the age of artificial intelligence, including:

• ASIA LEGAL  is a premier business and commercial law firm at the forefront of Vietnam’s rapidly evolving legal landscape, with extensive expertise in Mergers & Acquisitions (M&A), Capital Markets, Foreign Investment, Energy, Real Estate, and Dispute Resolution. Beyond traditional practice areas, Asia Legal is one of the industry leaders in the emerging domains of Intellectual Property, Technology – Media -Telecommunications (TMT) and Personal Data Protection. The article was authored on ASIA LEGAL's side by Vinh Luu, Hieu Nguyen, and Phong Tran.
• ZeLo  is a Japanese law firm advising clients across generative AI, mobility, crypto assets, M&A, finance, dispute resolution, and other areas of corporate legal practice. The article was authored on ZeLo's side by Kenta Muroi.

This joint publication stands as a testament to the friendship and collaborative relationship between ASIA LEGAL and ZeLo. It is offered in the hope that it will contribute to the sound and appropriate development of AI-related business between Japan and Vietnam, and to the continued growth of both nations' AI industries in the years ahead.

Visit ASIA LEGAL's Website

Vietnam’s Emerging AI Regulatory Framework

Position of the AI Law in the Vietnamese Legal System

The AI Law, which came into force on 1st March 2026, serves as a specialized legal framework regulating the research, development, provision, deployment, and use of AI systems in Vietnam.

It functions as a legal backbone within the national digital transformation strategy, maintaining close integration with other foundational laws, including but not limited to the Law on Telecommunications 2023, the Law on Protection of Consumer Rights 2023, the Law on Data 2024, the Law on Digital Technology Industry 2025, the Law on Personal Data Protection 2025, the Law on Intellectual Property 2025 and the Law on Cybersecurity 2025.

By establishing AI as a distinct object of specialised regulations, the State aims to drive AI as a key momentum for national growth and a new production method to enhance national productivity.

The Law on Telecommunications 2023 and AI Law

First, the Law on Telecommunications 2023 serves as the foundational framework for the digital economy by regulating telecommunications services, data centres, cloud computing services, and emerging forms of digital infrastructure.

Given that modern AI systems rely on the collection, storage, and processing of vast volumes of data, these infrastructures constitute the essential material foundation for the research, development, and deployment of AI technologies.

However, the Law on Telecommunications 2023 primarily governs the infrastructure used for the transmission and storage of information and does not address the risks arising from the operation of AI algorithms on such infrastructure. In other words, while the Law on Telecommunications 2023 establishes the “digital highways” through which data can circulate, it does not provide governance rules for the “vehicles” operating on those highways, including AI systems.

The Law on Data 2024 and AI Law

In addition, the Law on Data 2024 marks a significant shift in legislative thinking by formally recognising data as a form of asset. This approach is particularly noteworthy because data is no longer viewed merely as information serving public administration purposes but is instead recognised as a resource capable of being exploited, valued, and exchanged in economic transactions. Similar to tangible assets, data may become the subject of transfer, sharing, leasing, licensing, and other forms of commercialisation as prescribed by law. This development reflects an increasingly clear recognition of data as a new factor of production in the digital economy.

Nevertheless, recognising data as an asset addresses only the legal status of data and its ability to circulate within the economy. The true value of data lies not in its ownership, but in the capacity to analyse, process, and transform it into knowledge, predictions, decisions, or value-added products and services. It is precisely at this stage that AI emerges as the most important tool for data exploitation.

If the Law on Data 2024 facilitates the creation and circulation of data as an asset, an AI Law would regulate the technology capable of exploiting that asset on an unprecedented scale. The relationship between the two laws is therefore one of continuity and complementarity.

The Law on Digital Technology Industry 2025 and AI Law

This relationship becomes even more apparent when an AI Law is considered in conjunction with the Law on Digital Technology Industry 2025. The latter seeks to promote the development of Vietnamese digital technology products, services, and enterprises, with AI being identified as one of the strategic technologies capable of driving innovation and enhancing national competitiveness.

A relatively coherent legislative logic can therefore be observed within Vietnam’s legal framework: the Law on Data 2024 establishes data as an asset; the Law on Digital Technology Industry 2025 creates mechanisms for exploiting and commercialising such digital assets through digital technology products and services; and AI constitutes one of the most important technologies for transforming data into economic value.

However, as AI increasingly becomes a digital technology product and service with profound implications for businesses, public authorities, and individuals, the development-oriented provisions of the Law on Digital Technology Industry 2025 are insufficient to address the challenges that arise.

Questions such as who should bear responsibility for AI-assisted decisions, how algorithmic bias should be controlled, how the socio-economic risk level of AI systems should be assessed, and what transparency obligations should apply to generative AI models all fall beyond the scope of the Law on Digital Technology Industry 2025. These issues represent precisely the regulatory gap that an AI Law is intended to fill.

The Law on Personal Data Protection 2025 and AI Law

Furthermore, the use of AI for data exploitation necessarily requires compliance with the principles established under the Law on Personal Data Protection 2025. In the digital environment, AI systems may access large volumes of both non-personal data and personal data. Such capabilities significantly increase the risk of infringements upon privacy rights, particularly where personal data is used for AI training purposes or processed for purposes beyond those originally consented to by the data subject.

Consequently, an AI Law cannot operate in isolation but must be built upon and function consistently with the core principles of personal data protection law, including lawfulness, transparency, purpose limitation, data minimization, and accountability in data processing activities.

The Law on Intellectual Property 2025 and AI Law

Beyond personal data, AI systems may also process materials protected by intellectual property law, including copyrighted works, trademarks, industrial designs, patents, and databases.

Under the current legal approach, AI is generally regarded as a tool operated or controlled by human actors rather than an independent legal subject. Accordingly, where copyrighted or other protected materials may be unlawfully collected, inputted, or used for AI training and operation, liability should primarily rest with the relevant human actors involved, such as developers, deployers, publishers, or users, depending on their respective roles and conduct.

In this respect, existing intellectual property law already provides a sufficient framework for determining infringement and allocating responsibility, while an AI Law would mainly serve to clarify and reinforce the application of such principles in the AI context.

Viewed holistically, an AI Law would not replace existing legislation. Rather, it would serve as a connecting and complementary framework that strengthens and completes the legal architecture of Vietnam’s digital economy in its next stage of development.

In the upcoming episode, we are bringing you the risk-based regulatory framework of AI Law.

About ASIA LEGAL

ASIA LEGAL is a premier business and commercial law firm at the forefront of Vietnam’s rapidly evolving legal landscape. The firm has extensive expertise in mergers and acquisitions (M&A), capital markets, foreign investment, energy, real estate, and dispute resolution.

Beyond its traditional practice areas, ASIA LEGAL is also recognised as a leader in emerging fields such as intellectual property, technology, media and telecommunications (TMT), and personal data protection.

About ZeLo

ZeLo is a Japanese law firm providing legal services to support Japanese companies expanding overseas and foreign businesses entering the Japanese market. In addition to cross-border matters, the firm advises clients on a wide range of corporate legal issues, including generative AI, mobility, crypto assets, M&A, finance, and dispute resolution.

If you have any questions regarding the matters discussed in this article or require legal support, please feel free to contact us.