Legal Update: From Innovation to Regulation: Vietnam’s New AI Compliance Regime

Vietnam has introduced its first comprehensive legal framework for artificial intelligence with the adoption of the Law on Artificial Intelligence No. 134/2025/QH15 (the “AI Law”), effective from 1 March 2026, and its first implementing regulation, Decree No. 142/2026/ND-CP (“Decree 142”), effective from 1 May 2026.

Together, these regulations create a new compliance framework for businesses that develop, import, deploy, or use AI systems in Vietnam.

Risk-based classification 

The AI Law follows a risk-based approach and classifies AI systems into three categories:

High-risk AI systems are systems that may significantly affect life, health, individual rights, public interests, national interests, or national security.

Medium-risk AI systems are systems that may influence or mislead users because they are unable to recognize that they are interacting with AI or AI-generated content.

Low-risk AI systems are all other AI systems that do not fall within the high-risk or medium-risk categories.

The classification of an AI system determines the compliance obligations that apply.

Key Compliance Obligations 

Decree 142 allocates responsibilities among different stakeholders:

• Providers bear the primary compliance obligations.
• Deployers must monitor AI systems, maintain oversight, and report incidents.
• Importers must ensure that foreign AI systems comply with Vietnamese requirements.

Providers of medium-risk and high-risk AI systems must notify the Ministry of Science and Technology of their risk classification. Serious malfunctions and violations affecting users’ rights must also be reported promptly.

Enforcement and Sanctions

Violations may result in administrative penalties or, in serious cases, criminal liability. Businesses and individuals that cause damage through non-compliance may also be required to compensate affected parties under Vietnamese civil law.

What Businesses Should Do Now

The new framework marks a shift from Vietnam’s largely unregulated AI environment to a structured compliance regime.

Businesses should start preparing by:

• Identifying and mapping AI systems used within the organization;
• Assessing the applicable risk classification;
• Reviewing contracts to allocate compliance responsibilities;
• Updating internal policies on data protection, human resources, customer disclosures, and incident management; and
• Conducting gap assessments before the regulations become fully effective.

Conclusion

Vietnam’s AI Law and Decree 142 are designed to support AI innovation while introducing clear regulatory safeguards. Businesses that act early to assess their AI activities and implement appropriate compliance measures will be better positioned to manage risks and adapt to Vietnam’s evolving AI landscape.