"Legal Considerations for AI System Implementation in Vietnam — In Light of the Enforcement of the Law on Artificial Intelligence and Its Implementing Decree ": Vietnam Practice Team

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Legal Considerations for AI System Implementation in Vietnam — In Light of the Enforcement of the Law on Artificial Intelligence and Its Implementing Decree

1. Introduction

In recent years, Artificial Intelligence (“AI”) has rapidly expanded on a global scale and has been increasingly integrated into various aspects of business operations. AI is currently utilized across a broad range of functions, including customer support, internal knowledge management and retrieval, generation of documents such as contracts and internal communications, creation of images, audio, and video content, data analysis and forecasting, marketing support, and software development assistance.

Against this backdrop, Vietnam enacted the Law on Artificial Intelligence (No. 134/2025/QH15, hereinafter referred to as the “Vietnam AI Law”), which came into effect on March 1, 2026. Subsequently, Decree No. 142/2026/ND-CP (“Decree No.142”), which provides detailed guidance for the implementation of the Vietnam AI Law, came into effect on May 1, 2026.

As a result, Japanese companies operating in Vietnam that implement AI systems in their business operations are now required to establish internal frameworks addressing matters such as the management of risks associated with AI use and the development of rules governing employees’ use of AI systems.

This article therefore outlines the key legal considerations for Japanese companies operating in Vietnam when implementing AI systems in their business operations as the deployers or users.

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[Agenda]

1. Introduction

2. Scope of Application of the Vietnam AI Law

3. Risk-Based Approach

4. Obligations of Deployers and Users

5. Transitional Measures

6. Conclusion — Key Considerations for Japanese Companies Operating in Vietnam—

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