On 30 April 2026, the Government of Vietnam issued Decree No. 142/2026/ND-CP detailing provisions and measures for implementing the Law on Artificial Intelligence. The Decree took effect on 1 May 2026. It applies to providers, developers, deployers, and users of AI systems operating in Vietnam, including foreign organisations and individuals engaged in AI-related activities in the country, regardless of where they are established.
The Decree establishes a three-tier risk classification: high-risk, medium-risk, and low-risk AI systems. Providers must complete a risk assessment and determine the applicable tier before placing an AI system into operation in Vietnam. The Ministry of Science and Technology is responsible for publishing technical classification criteria and labelling format guidance. AI-generated content must carry a clear label, with the specific display format left to deployers pending ministry guidance. Incident reporting requires a preliminary report within 72 hours of discovering a serious incident, and within five working days for other incidents.
Foreign companies providing, developing, or deploying AI systems to users in Vietnam fall within scope regardless of where the company is incorporated. Providers must complete risk assessments and satisfy the applicable tier requirements before deployment. Companies in financial services, healthcare, education, and media face immediate attention given the frequency of AI use cases in those sectors. Deployers of AI systems generating content for Vietnamese audiences must implement labelling now, because the obligation is already in force even while ministry format guidance remains pending.
Technical classification criteria from the Ministry of Science and Technology have not yet been published. Until that guidance is issued, providers must assess risk based on the Decree's general criteria, which may produce inconsistent results across the market. The labelling format guidance is also pending, creating a period of partial implementation where the labelling obligation exists but the prescribed format has not been specified. Companies should document their classification rationale now to demonstrate good-faith compliance ahead of the technical guidance.
Licentium advises technology companies on AI regulatory obligations across Southeast Asia and on cross-border AI deployment strategy. Our team and partner network are available to assist companies assessing whether their AI systems fall within Decree 142's scope and preparing for risk classification, incident response, and labelling obligations. Work we undertake includes AI regulatory compliance in Vietnam and ASEAN jurisdictions, risk classification assessments, incident response procedure design, and privacy and data law integration for AI systems.