Legal Alert: Vietnam's Law on E-Commerce — What Platform Operators Need to Know
By Michael Lee, Kate (Huong) Nguyen
On December 10, 2025, the National Assembly passed the Law on E-Commerce No. 122/2025/QH15 (the "EC Law"), effective July 1, 2026. This alert focuses on the provisions of most direct relevance to platform operators, sellers, and businesses engaged in cross-border e-commerce with Vietnam.
Scope of Application
The EC Law applies to both domestic and foreign entities engaged in e-commerce activities in Vietnam. "E-commerce activity" is defined broadly as any commercial activity conducted partially or entirely in an electronic environment — wider than the previous Decree 52, which was limited to specific technical channels such as the internet or mobile networks.
Four Types of E-Commerce Platform
The EC Law formally classifies e-commerce platforms as follows:
- Direct EC platform — sells the operator's own goods or services (e.g., a brand's own app or website);
- Intermediary EC platform — allows other parties to register and sell (e.g., marketplaces, auction platforms);
- Social network with e-commerce functions — a social network integrating online communication, ordering, or livestream sales;
- Integrated EC platform — a platform that hosts other EC platforms within it.
All operators share core disclosure, reporting, and enforcement obligations, but additional requirements apply depending on the platform type.
Livestream Sales — Obligations for All Parties
Platform operators must verify livestreamer identities, disclose livestream regulations, establish complaint mechanisms, provide tools for safety warnings, and store all livestream image and audio data for at least one year.
Sellers must supply livestreamers with documentary evidence of licensing and product compliance before the livestream, and where advertising approval is required, submit that approval to both the platform and the livestreamer in advance.
Livestreamers must comply with platform rules, decline to participate where required documentation is not provided, and adhere to the boundaries set by any approved advertising content.
All three parties must suspend livestream activities and remove unlawful content upon request from competent authorities.
Cross-Border Platform Requirements
Foreign e-commerce platforms meeting any of the following criteria are subject to enhanced regulatory requirements:
- Use Vietnamese as a display language;
- Use a ".vn" domain name; or
- Reach a prescribed transaction threshold with Vietnamese buyers.
Such platforms must register with the authorities and either appoint a local authorised entity or establish a legal entity in Vietnam, depending on whether the platform has online ordering functionality. Where a treaty exemption applies to the legal entity requirement, a security deposit at an approved bank must be placed instead.
Grace Period
E-commerce websites and applications that were notified or registered before the EC Law's effective date are granted a grace period to continue operating under their existing registrations until June 30, 2027.
Next Steps
Businesses engaged in e-commerce in Vietnam — particularly foreign platform operators — should urgently assess whether the cross-border requirements apply to them and take steps to establish the necessary local presence ahead of July 1, 2026. Implementing regulations from the Government are expected in the coming months and should be monitored closely.
For further guidance, please contact Diep Hoang or Michael Lee.