AI Regulation Tracker / Government AI
Vietnam's National Public Service Portal now has an express AI article requiring AI output to stay advisory
Decision 29/2026/QĐ-TTg took effect on 20 July 2026. Article 48 of the Regulation it promulgates is an express AI article for that portal, and it provides that AI may inform the decision but may not replace the decision of the competent authority or alter legal responsibility.
What does Decision 29 actually change?
Vietnam's broader AI obligations come from other instruments, including its AI Law risk tiers and conformity regime. Decision 29 does something narrower. It writes the rules for one named system.
The Regulation annexed to the Decision sets out how the National Public Service Portal is managed, operated and exploited. Article 48 covers AI functions there including automated guidance to users, dossier classification and completeness checking, anomaly detection during processing, and management-level synthesis. Then comes the constraint on all of it.
Providing information and outputs of a reference and supporting nature for users and administering agencies, which do not replace the decision of the competent agency, organisation or individual and do not alter responsibility as prescribed by law.Article 48, Regulation annexed to Decision 29/2026/QĐ-TTg (English rendering; the signed PDF is a scanned image and the Vietnamese text has been restored to standard orthography; verify against a clean text before citing in legal filings)
Two limbs, and the second is the one people skip. The first says the AI does not replace the decision. The second says it does not shift where legal responsibility sits. An official who rejects a dossier after an AI completeness check flagged it still owns that rejection. The model is not a co-signer and not a defence.
The Decision also repeals Decision 31/2021/QĐ-TTg. The AI functions on the portal are subject to Vietnam's network security, personal data protection and state secret protection law, with the data feeding those functions subject to access control and activity logging.
Which portal is this, and how does it differ from the Decree 142 entry?
Worth being precise, because the tracker carries both and they are easy to conflate. This piece is about the National Public Service Portal, Cổng Dịch vụ công quốc gia, the citizen-facing system through which administrative procedures are filed and processed. The instrument is a Prime Minister's Decision promulgating that portal's operating Regulation, replacing the 2021 Decision.
The separate entry on Decree 142 and its AI Law portal transition deadline concerns a different instrument, a different portal and a different legal basis. A supplier can be inside the scope of one and outside the other. If you are mapping obligations, treat them as two separate rows.
Who carries the duty?
The duty runs to the state side first: ministries and ministerial-level agencies, provincial People's Committees, and the Ministry of Public Security as portal operator. Below them, the civil servants who process administrative procedures, because the advisory-only limb only means something if a human is deciding.
Vendors supplying the portal are affected indirectly: the state agencies operating the portal cannot lawfully deploy an AI system that auto-decides without a competent official in the loop, so that constraint becomes a procurement specification.
How does this compare with other government AI mandates?
The interesting thing about Article 48 is not the advisory-only substance, which is increasingly common, but the altitude at which it operates. In this case, Vietnam attached the duty to a specific deployment, the National Public Service Portal, rather than framing it as a general rule for all public-sector AI. That narrow attachment point makes the rule easier to test in practice, because there is a specific screen and a specific workflow to inspect.
| Element | What the instrument provides |
|---|---|
| Attachment point | One named system, the National Public Service Portal, rather than a technology class or a category of agency |
| Operative provision | Article 48 of the annexed Regulation, on the application of artificial intelligence on the National Public Service Portal |
| Bindingness | Binding law. A Prime Minister's Decision promulgating an annexed Regulation, in force from 20 July 2026 |
| Core constraint on the AI | Outputs are of a reference and supporting nature. They do not replace the decision of the competent agency, organisation or individual and do not alter responsibility as prescribed by law |
| Outside the attachment point | Nothing here reaches AI that never touches the portal. Those duties sit in other Vietnamese instruments |
What does this mean for a US supplier or compliance officer?
Three practical consequences.
First, the advisory constraint belongs in the product requirements, not in the policy binder. If a feature terminates a citizen's request without an official acting, that feature does not ship into this portal. The cleanest evidence is an interface where the AI output is presented as a recommendation with the official's action recorded separately.
Second, logging is an explicit expectation. Data exploitation for the AI functions is to be subject to access control and activity logging. If your architecture cannot show who saw what and who acted on it, you cannot demonstrate the human was in the loop even when the human was.
Third, do not generalise the rule. Article 48 is scoped to this portal. It is not a Vietnamese rule for private-sector AI, and it does not bind AI providers outside the portal. Vietnam's broader duties come from other instruments, including its AI Law and its personal data protection law. Mapping this Decision onto them and calling it one duty will produce a wrong answer in both directions.
What the Decision does not do
It does not create a general AI regulation for Vietnamese public administration. It does not set out a licensing or registration scheme for AI systems. It does not bind AI providers whose products never touch the National Public Service Portal. And the entry-into-force date is the news here: the Decision was signed on 4 June 2026, and 20 July 2026 is when it began to apply.
Frequently asked questions
What does Article 48 of the Regulation annexed to Decision 29/2026/QĐ-TTg require?
Article 48 of the annexed Regulation governs AI on Vietnam's National Public Service Portal. It requires the AI functions to provide information and outputs of a reference and supporting nature, which do not replace the decision of the competent agency, organisation or individual and do not alter responsibility as prescribed by law. The Decision took effect on 20 July 2026, and its scope is that portal alone.
How is this different from Vietnam's Decree 142 portal transition deadline?
They are separate instruments. Decision 29/2026/QĐ-TTg promulgates the operating Regulation for the National Public Service Portal and repeals Decision 31/2021/QĐ-TTg. The Decree 142 tracker entry concerns a transition deadline tied to a portal under Vietnam's AI Law. A vendor can be in scope of one and not the other.
What should a vendor supplying AI into the portal be able to evidence?
That the AI output is presented as reference and support rather than as a decision, that a competent official remains the decision maker, and that data exploitation for the AI functions is handled consistently with the access control and logging expectations set out in the Regulation. The AI functions also sit under Vietnam's network security, personal data protection and state secret protection law.
Last verified: July 28, 2026