Law on Artificial Intelligence 2025: Comprehensive Legal Framework and Implementation Roadmap - Tran Tran Law

On December 10, 2025, Vietnam marked a historic milestone in its legislative history as the National Assembly officially passed the Law on Artificial Intelligence (AI) with a 90.70% approval rating. With this legislation, Vietnam joins a pioneering group of nations—alongside the European Union—to possess a dedicated, comprehensive legal framework to regulate the core technology of the Fourth Industrial Revolution.

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The AI Law 2025 is designed with a “Regulation for Development” philosophy, aiming not only to control potential risks but also to create a robust legal “launchpad” for Vietnamese enterprises to master technology and enhance national competitiveness. This article deconstructs the specific provisions of the Law and their direct impacts on organizations and individuals participating in the AI market.

1. Legal Definition System: Building a Common Language for AI

One of the highlights of the AI Law 2025 is the establishment of a unified definition framework in Article 3, which helps eliminate technical barriers in law enforcement.

Artificial Intelligence (AI): Defined as the electronic implementation of human intellectual capabilities, including learning, reasoning, perception, judgment, and natural language understanding.
AI System: A machine-based system capable of varying levels of autonomy, adaptation, and reasoning from input data to generate outputs (predictions, content, recommendations, decisions) that influence physical or virtual environments.
Definition of 5 Key Stakeholder Groups:
- Developer: Individuals or organizations that design, train, and control technical methods, training data, or model parameters.
- Provider: The entity that places an AI system on the market or puts it into service under its own brand.
- Deployer: Organizations, individuals, or state agencies using an AI system under their control for professional, commercial, or service-providing activities.
- User: Organizations or individuals directly interacting with the AI system.
- Affected Person: Those impacted in their rights, health, or property by the outputs of an AI system.

Clearly defining these roles provides the legal basis for determining civil liability and compensation obligations when incidents occur.

2. Governance Philosophy: Human-Centric and AI Ethics

Article 4 of the AI Law 2025 explicitly states that all AI research and application activities must be human-centric. AI is regarded as a supporting tool that does not replace human authority or responsibility.

Golden Principles in AI Operation:

Maintenance of Human Control: Humans must retain the ability to intervene in all significant decisions made by the system.
Fairness and Transparency: AI must not be biased or discriminatory and must comply with ethical standards and Vietnamese cultural values.
National AI Ethics Framework (Article 26): The Minister of Science and Technology will issue this framework to guide the design and release of safe, reliable, and responsible AI systems.
Green AI: Encouraging the application of technology that is resource-efficient, energy-saving, and minimizes negative environmental impacts.

3. Risk Classification: A Smart and Flexible Management Model

Rather than extremist prohibition, Vietnam has chosen a risk-based approach—similar to the models of Japan and South Korea but with higher safety thresholds. Under Article 9, AI systems are categorized into three main risk levels:

3.1. High-Risk AI Systems

Definition: Systems capable of causing significant damage to life, health, human rights, national security, or public interest.
Obligations for Providers (Articles 13, 14):
- Must undergo conformity assessment and certification before deployment.
- Establish strict risk management and training data governance systems.
- Maintain activity logs for post-market surveillance.
- Ensure human oversight and intervention capabilities.

3.2. Medium-Risk AI Systems

Definition: Systems capable of confusing or manipulating users, particularly AI-generated content or direct interaction chatbots.
Obligations (Articles 11, 15): Focus on transparency responsibilities and explaining objectives and operating principles upon request from authorities.

3.3. Low-Risk AI Systems

Definition: Simple support systems with minimal social impact.
Obligations: Encouraged to voluntarily comply with technical standards without creating unnecessary administrative burdens for enterprises.

4. Transparency and Deepfake Control: Solutions for the Digital Content Era

In response to the explosion of deepfakes, Article 11 introduces “revolutionary” transparency regulations:

Machine-Readable Markers: All audio, image, and video content generated by AI must be marked in a machine-readable format. This allows social media platforms and search engines to automatically identify and warn users.
Labeling Responsibility: Deployers must clearly notify the public when providing simulated or synthesized content that recreates real people or events to avoid public confusion.
Flexibility in Arts: For cinematic or creative artistic works, labeling can be implemented flexibly to avoid interfering with the viewing experience while still ensuring necessary distinction.

5. Prohibited Acts: Legal “Red Lines”

To protect fundamental values, Article 7 lists prohibited behaviors in AI activities:

Exploiting AI to violate the law or infringe upon the rights and interests of organizations and individuals.
Using AI to manipulate human behavior intentionally and systematically, causing serious harm.
Exploiting the vulnerabilities of vulnerable groups (children, the elderly, persons with disabilities) to harm themselves or others.
Generating fraudulent content dangerous to national security and public order.
Collecting or training AI in violation of Intellectual Property and Personal Data laws.

6. Infrastructure Development and National AI Sovereignty

Vietnam identifies AI infrastructure as strategic infrastructure. Chapter III of the Law paves the way for building national endogenous capacity:

National Computing Infrastructure: The State invests in national AI computing centers to reduce costs for enterprises and startups.
Data for AI (Article 17): Establishing a shared data system (controlled open data) for AI training, with priority given to Vietnamese language and culture data.
Mastering Core Technology: Prioritizing resources for research on Vietnamese Large Language Models (LLMs), hardware, and semiconductors. This helps Vietnam avoid total dependence on cross-border AI platforms.

7. Innovation Support Mechanisms: Major Incentives for Enterprises

The AI Law 2025 goes beyond “regulation” to offer significant incentives to promote the market:

National AI Development Fund (Article 22): A non-profit fund utilizing a specific financial mechanism that accepts risks in science and technology innovation.
AI Voucher Mechanism (Article 25): Supporting costs for SMEs and startups using computing infrastructure or shared datasets.
Sandbox Mechanism (Article 21): Allowing controlled testing of sensitive AI solutions, where participants may be exempted from or granted reduced legal liability based on test results.
Highest Level Incentives: Enterprises in the AI sector enjoy the highest incentives under the laws on Science and Technology and High Technology.

8. Liability for Compensation and Incident Handling

A critical new point is the establishment of a strict compensation mechanism in Article 29:

Abolishing Fines Based on Revenue: Shifting toward full compensation for actual damages and applying service suspension sanctions.
No-Fault Liability: For high-risk AI systems, the deployer is liable for compensation even in the absence of fault (except in cases of force majeure or intentional fault by the victim). This aims to maximize public protection against complex AI algorithms.
One-Stop AI Portal: All serious incidents must be reported promptly through this platform for authorities to guide the response.

9. Compliance Roadmap: What Should Enterprises Do Now?

The AI Law takes effect on March 1, 2026. However, the Law provides a transition roadmap in Article 35 for enterprises to adapt:

By September 1, 2027 (18 months): AI systems in Healthcare, Education, and Finance must achieve full compliance.
By March 1, 2027 (12 months): AI systems in other sectors must complete classification and transparency procedures.

Recommendations from Tran & Tran:

Conduct an AI Audit: Determine which risk level (High, Medium, or Low) your enterprise’s AI system falls under.
Establish Technical Documentation: Especially for high-risk AI, prepare safety assessment dossiers for post-market audits.
Review Intellectual Property: Check training data sources to ensure no copyright infringement occurs under prohibited acts.
Implement Labeling Mechanisms: Begin building processes for identifying and labeling AI-generated products.

10. Conclusion

The Law on Artificial Intelligence 2025 is the “constitution” of Vietnam’s digital technology sector. With a balanced approach between “Safety like the EU” and “Promotion like Japan/South Korea,” this legislation promises to transform Vietnam into a self-reliant AI nation where technology thrives sustainably under human control.

Tran & Tran International Intellectual Property Law Firm stands ready to accompany your enterprise in searching, consulting on AI Law compliance strategies, and protecting intellectual property assets in the digital era.

Contact Information: Tran & Tran

Address: Room 802, Talico Building, 22 Ho Giam Street, Dong Da District, Hanoi.
Consulting Hotline: 024 3732 7466
Email: ip@trantran.vn

Note: The content of this article is intended for legal analysis based on the Law on AI 2025. For specific solutions regarding your business model, please contact Tran & Tran directly for in-depth consultation.