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ARTICLE · 16 JANUARY 2026

Key Developments In Personal Data Protection Under Decree 356

Decree No. 356/2025/ND-CP (‘Decree 356'), effective from 1 January 2026, provides comprehensive guidance for implementing certain provisions of the Personal Data Protection Law (‘PDPL').

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Decree No. 356/2025/ND-CP ('Decree 356'), effective from 1 January 2026, provides comprehensive guidance for implementing certain provisions of the Personal Data Protection Law ('PDPL'). Compared with Decree No. 13/2023/ND-CP, Decree 356 marks a clear shift from a principle-based framework to more specific, concrete compliance requirements that are practically enforceable and verifiable.

This update outlines the key provisions of Decree 356 that organisations should comply without delay.

I. Highlights of Decree 356

1. Stricter compliance obligations for handling sensitive personal data

Decree 356 provides a wider non-exhaustive list of sensitive personal data as compared to previous regulations.1 Notably:

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