In brief
Effective 1 July 2026, Decree No. 174/2026/ND-CP (“Decree 174”) strengthens the enforcement of existing regulatory requirements across Vietnam's digital economy, including the online gaming, social network, telecommunications, cloud computing, data center, broadcasting and television sectors. The Decree does not generally introduce new substantive obligations. Instead, it establishes a more comprehensive sanctions framework for non-compliance with obligations already prescribed under existing laws and regulations, including the Telecommunications Law, the Electronic Transactions Law and Decree No. 147/2024/ND-CP (“Decree 147”), among others. Businesses operating in these sectors should review their compliance with licensing, user verification, content management and technical infrastructure requirements, as violations may now result in significant fines, service suspensions and other remedial measures.
Key takeaways and recommended actions
Businesses operating in the following sectors should review existing compliance obligations, as Decree 174 introduces a more robust enforcement regime, including substantial fines, service suspensions and remedial measures for regulatory breaches.
Online gaming services
- Review player verification and onboarding procedures to ensure compliance with existing identity verification requirements.
- Assess whether in-game virtual items, credits and reward points mechanisms could be viewed as facilitating conversion into cash or other forms of monetary value.
- Confirm that server-hosting and technical infrastructure arrangements satisfy applicable local requirements.
- Verify that all required licenses, approvals and notifications remain valid and up to date.
Social networks and cross-border information provision
- Reassess content moderation and content removal processes, particularly for responding to regulator requests.
- Review user registration, verification and complaint-handling procedures.
- Evaluate whether existing governance and reporting mechanisms are sufficient to comply with applicable regulatory requirements.
- Consider whether additional monitoring measures are needed to mitigate enforcement risks.
Telecommunications services
- Verify compliance with applicable licensing, registration and notification requirements.
- Review operational and technical compliance programs against the Telecommunications Law and its implementing regulations.
- Assess cross-border service offerings to determine whether any local regulatory requirements may apply.
- Review internal controls relating to customer management, data handling and regulatory reporting.
Cloud computing and data center services
- Review compliance with applicable requirements to publish service quality.
- Ensure complete retention of information provided by users when entering service contracts.
- Review regulatory reporting procedures to ensure timely, complete and accurate submission of required information and data.
- Evaluate contractual and operational arrangements that may create regulatory exposure.
Broadcasting and television services
- Review compliance with applicable radio frequency licensing requirements.
- Ensure broadcasting equipment is installed and operated in accordance with license conditions.
- Implement required measures to address harmful interference.
- Cease equipment use when required by the competent authority.
Across all digital services sectors
Although Decree 174 does not generally create new substantive obligations, it significantly increases enforcement exposure through higher fines, service suspensions, revenue recovery measures and other corrective actions. Businesses should conduct a Decree 174 readiness review, map existing regulatory obligations against the new sanctions framework and prioritize remediation of high-risk compliance gaps.
In more detail
Online gaming services
- Online gaming remains a key enforcement focus for Vietnamese regulators, particularly in relation to virtual economies, player protection and local infrastructure requirements. Decree 174 reinforces this framework by prescribing penalties for non-compliance with existing requirements under Decree 147 and related regulations, including licensing obligations and obligations relating to server localization, player identity verification, restrictions on cash conversion of virtual items and in-game currency, and age suitability and player protection measures.
- Violations may result in fines of up to VND 200 million, including for converting virtual items, credits or reward points into cash or cash equivalents, specified cards or other items with transaction value outside the game. Depending on the violation, applicable sanctions and remedial measures may include suspension of game release or operation for one to three months, confiscation of exhibits and means used to commit the violation, compulsory withdrawal of domain names or applications, and disgorgement of unlawful gains.
Social networks and cross-border information provision
- Decree 174 prescribes penalties for breaches of licensing requirements for domestic social networks and existing obligations concerning content management, user management, transparency and reporting applicable to domestic social network operators and cross-border information providers.
- The applicable fines reach VND 70 million for domestic social network requirements and VND 50 million for cross-border information provision requirements, while fines of up to VND 100 million apply to providing, exchanging, transmitting, storing or using digital information to disseminate false information about Vietnam’s territorial sovereignty. Depending on the violation, applicable sanctions and remedial measures may include suspension of social network license rights or service provision, confiscation of exhibits and means used to commit the violation, compulsory withdrawal of domain names or removal of applications, removal of unlawful information or locking of accounts, community pages, groups or content channels, and withdrawal of telecommunications number prefixes or numbering resources and disgorgement of unlawful gains.
Telecommunications, cloud computing, cata centers and offshore service providers
- For domestic and offshore providers of basic telecommunications services over the Internet, cloud computing services and data center services, Decree 174 prescribes penalties for non-compliance with existing registration, notification, service provision and regulatory reporting requirements under the Telecommunications Law and Decree No. 163/2024/ND-CP. The requirements differ by service and include updating registration or contact information, publishing service quality, authenticating users, obtaining prior consent to access terminal-device features, retaining user information and facilitating telecommunications connectivity for data center users.
- Registration and notification violations may attract fines of VND 20–100 million for specified failures to update registration or contact information or for providing services without the required notification or registration certificate. Failures to authenticate users of basic telecommunications services over the Internet, facilitate telecommunications connectivity for data center users, or retain complete information provided by users when entering into contracts may attract fines of VND 70–120 million, depending on the violation. Telecommunications reporting violations may attract fines of VND 50–140 million for late or incomplete reporting, inaccurate data, or failure to establish the required technical reporting connectivity. Applicable remedial measures include compulsory disgorgement of unlawful gains from providing services without the required notification or registration certificate and compulsory retention of complete user information.
Broadcasting and television services
- For broadcasters and television service providers operating radio transmitters, Decree 174 prescribes penalties for breaches of frequency licensing and technical requirements, including unlicensed transmission, use of unauthorized frequencies, excessive transmission power and installation at unlicensed locations, as well as failure to implement legally prescribed or authority-required measures to address harmful interference.
- Fines of VND 70–100 million apply to continued use of radio equipment after a competent authority has ordered cessation because it causes harmful interference to radionavigation, safety, search and rescue, national defense or security communications. This violation and failure to implement required interference-handling measures may also result in confiscation of exhibits and means used to commit the violation and suspension of the right to use the radio frequency license for one to three months.
Conclusion
Decree 174 brings the consequences of non-compliance into sharper focus across Vietnam's gaming, social network, telecommunications, cloud computing, data center sectors, and cross-border information provision, as well as broadcasting and television operations that use radio frequencies. Although it generally enforces obligations already found in existing laws and regulations, the potential impact on both finances and service continuity makes it more than a routine regulatory update. The practical priority is to ensure that compliance on paper is reflected in how services are delivered, users and content are managed, reports are prepared and technical systems are operated. By strengthening these arrangements now, businesses will be better placed to respond to regulatory scrutiny and reduce the risk of avoidable disruption to their Vietnam-facing operations.
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Manh Hung Tran, Partner, Huyen Minh Nguyen and Huu Tuan Nguyen, Special Counsels, Minh Tan Dang, Senior Associate, Alex Do, Data & Cyber Specialist, and Kim Anh Nguyen, Law Clerk, have contributed to this legal update.
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