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ARTICLE · 06 JULY 2026

Vietnam Introduces Sectoral List Of High-Risk AI Systems

Tilleke & Gibbins
Tilleke & Gibbins
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Tilleke & Gibbins

Tilleke & Gibbins

Tilleke & Gibbins has been present in Vietnam since 1992, when it became the first foreign law firm...

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Vietnam has officially designated certain AI systems as high-risk, imposing strict compliance requirements on developers, suppliers, and deployers. Decision No. 33/2026/QD-TTg establishes which AI applications across education, healthcare, banking, transport, and other sectors will face mandatory conformity assessments, local presence requirements, and enhanced liability standards.

VietnamTechnology

Vietnam has introduced an official list of high-risk AI systems, triggering more stringent compliance obligations for developers, suppliers, and deployers operating in the country. On June 30, 2026, the prime minister issued Decision No. 33/2026/QD-TTg (Decision 33), which establishes the List of High-Risk AI Systems under the Law on Artificial Intelligence (AI Law) and Decree No. 142/2026/ND-CP (Decree 142). Decision 33 takes effect on August 15, 2026.

Decision 33 is significant because only AI systems included on the list will be subject to the heightened compliance obligations applicable to high-risk AI systems under the AI Law and Decree 142. These include, among others, local presence requirements for foreign providers, mandatory conformity assessment before deployment, comprehensive risk management and data quality documentation, and strict liability for damages even when the provider is fully compliant. Decision 33 also specifies the applicable conformity assessment pathway

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