1.            Expansino and Legal Codification of Digital Transformation Definitions

Under Article 1, LDT 2025 defines its regulatory scope to encompass Digital Government, Digital Economy, and Digital Society. However, to avoid overlap or conflict with existing sectoral laws, LDT 2025 provides reference and a principle of precedence as follows: “Matters falling within the domains of data, electronic transactions, cybersecurity, telecommunications, artificial intelligence, and other specialized fields shall be governed by the respective sectoral laws, and must ensure consistency with the principles and requirements provided under this Law.”

According to Article 3 of the LDT 2025, digital transformation is defined as the process of transforming modes of operation, governance, and service delivery based on digital technologies, digital data, digital systems, digital platforms, and digital processes, to create new value, enhance efficiency, and ensure transparency.

The “digital environment” as defined in Article 3, is no longer a conceptual or abstract space, but a recognized domain of activity, interaction, and transaction, formed by digital infrastructure, digital systems, and digital data. The establishment of this “digital legal space” allows the State to assert national digital sovereignty, while also laying the legal foundation for applying sanctions and enforcement measures in the digital environment equivalent to those in the physical environment.

LDT 2025 also codifies other foundational concepts such as “Digital System”, “Digital Platform”, “Public Digital Infrastructure”, “Digital Government”, “Digital Economy” and “Digital Society”. The legal codification of these terms aims to unify the understanding of all entities within the political system and among enterprises engaging in digital transformation, thereby ensuring scientific coherence and common conceptual clarity across the legal and operational framework of digital transformation, specifically as follows:

This structural shift reflects efforts to institutionalize Resolution No. 52-NQ/TW of the Politburo on proactively participating in the Fourth Industrial Revolution, in which institutional reform and improvement are identified as foundational, and the development of Digital Government is considered a breakthrough. The core philosophy of “transform first – digitize later” officially mandates that agencies and organizations must restructure their internal processes and renew organizational models before migrating activities to the digital environment.

2.            Principles of Digital Transformation

Pursuant to Article 6, LDT 2025 establishes the principle of user-centricity. All initiatives promoting innovation and enhancing service quality must revolve around the objective of creating new value and maximum convenience for agencies, organizations, enterprises, and citizens. It is strictly prohibited to design technology systems that are convenient for administrative authorities but burdensome to end users.

“Once-only declaration by default” principle^[2] obliges state agencies to strengthen data connectivity and sharing in order to enhance administrative efficiency and reduce the procedural burden on society. This means that once individuals or businesses provide information to one state agency, that data must, by default, be shared and synchronized across relevant agencies for reuse. The aim is to improve governance capacity, eliminate duplication, streamline administrative procedures to the greatest extent possible, and support evidence-based decision-making by competent authorities.

Alongside expanded connectivity is the legal requirement for strict cybersecurity and data protection. LDT 2025 stipulates that cybersecurity, personal data protection, and privacy must be ensured in accordance with relevant legislation, including the Law on Cybersecurity 2025 and the Law on Personal Data Protection 2025. Moreover, agencies are encouraged to adopt cutting-edge technological measures to enhance safety and resilience. The legal framework also requires that digital transformation must be implemented in a flexible and adaptive manner, in response to the ever-evolving nature of technology. It promotes regulatory sandbox mechanisms and the application of emerging technologies suited to the characteristics of each specialized sector^[3].

Digital transformation efforts must guarantee inclusiveness, ensuring equal access and participation for all individuals and organizations – especially vulnerable groups in remote and disadvantaged areas – to use digital services safely, conveniently, and effectively. Additionally, any decisions made based on digital technologies must uphold the principles of transparency and accountability to build digital trust and safeguard privacy rights in compliance with legal standards. This process is closely linked with continuous measurement, evaluation, monitoring, and improvement, to ensure service quality is constantly enhanced. All state agencies are under a binding legal obligation to comply with these principles, while the State encourages private sector organizations and enterprises to apply the same principles in their operations^[4].

3.            Digital Transformation – Three Pillars: Digital Infrastructure – Digital Data – Digital Platforms

Article 9 LDT 2025 clearly reflects the State’s strategic orientation through three core policy pillars: Digital Infrastructure, Digital Data, and Digital Platforms. The State prioritizes the allocation of resources to develop a unified, secure, reliable, and scalable digital infrastructure, recognizing it as an essential form of infrastructure, equivalent in importance to electricity, roads, schools, and healthcare facilities. In parallel, LDT 2025 promotes the formation and development of national digital data, recognizing data as a new economic resource. The State views digital data not merely as a byproduct of digital activities, but as a critical asset that underpins decision-making, innovation, and service delivery in both the public and private sectors.

Furthermore, LDT 2025 encourages the development and adoption of shared digital platforms, open digital platforms, and “Make in Vietnam” digital technology products, to enhance technological sovereignty and reduce dependency on foreign digital ecosystems. These platforms serve as foundational tools for delivering public services, supporting businesses, and fostering citizen engagement in the digital era. Notable directions include:

3.1.       Unified, Secure, and Reliable Digital Infrastructure Ensuring Cybersecurity and Information Safety

Develop telecommunications infrastructure, data centers, cloud computing systems, etc., with scalability to meet the demands of connectivity, data sharing, and the provision of digital services. The Government prioritizes cloud computing and open architecture, minimizes infrastructure duplication, and strengthens the management and supervision of digital systems and digital platforms to ensure a healthy competitive environment.

LDT 2025 additionally mandates the principle of system design in the direction of “connectivity by default, data sharing by default, security by default”, with a strong commitment to ensuring cybersecurity and data protection throughout the digital transformation process, preventing, detecting, and handling violations of law in the digital environment. This represents a step forward compared to previous regulations, affirming the viewpoint that “security must be prioritized” in digital technology development. At the same time, the State also strengthens the management and special supervision of large-scale intermediary digital platforms to ensure fair competition, transparency, and safety^[5].

 3.2.          Development and Sharing of Digital Data; Shared and Open Digital Platforms

LDT 2025 emphasizes the requirements for data governance, connectivity, and sharing in line with the “National Digital Architecture Framework” “National Data Architecture Framework” and “National Data Governance Framework” in order to ensure coherence and continuity^[6].

LDT 2025 encourages the development and use of national digital platforms, open digital platforms, and shared digital technology products to serve the purposes of governance, public service delivery, and socio-economic development. On that basis, the state authority will operate wholly in the digital environment, and administrative procedures shall be provided as wholly online public services by default, while partially online public services shall only be provided in cases where the laws prescribe otherwise or when technical incidents prevent immediate resolution.

The mechanism of “shared platforms” is intended to prioritize systems that enable interoperability and integration, while limiting infrastructure monopolies by ministries, sectors, and local authorities^[7].

 3.3.          Encouragement of Innovation and Pilot Testing

Encourage innovation and controlled experimentation (sandbox) of new technologies to improve service efficiency and develop digital products. LDT 2025 introduces a pilot and independent trial mechanism to minimize risks, specifically designing a “pilot phase” for unprecedented projects, which allows the use of dedicated budgets and the piloting of solutions prior to formal investment^[8]. This mechanism enables effectiveness validation, prevents wasteful public spending, and promotes innovation, especially in emerging fields such as big data and artificial intelligence.

3.4.          Attraction and Training of Talents

The State establishes special mechanisms to train human resources, attract and employ experts, talents, and high-quality human resources in the field of digital transformation. These mechanisms are applied in accordance with relevant laws on public officials and civil servants, science and technology, and the digital technology industry, with the aim of creating flexible arrangements and appropriate incentives to retain skilled personnel. At the same time, LDT 2025 promotes digital literacy and capacity-building training for civil servants, public employees, and the general public^[9]. This provision is intended to address the problem of “brain drain” in the public sector, ensuring that the state apparatus possesses sufficient capacity to lead the national digital transformation agenda.

LDT 2025 also allows state agencies and state-owned enterprises to hire domestic and international experts and collaborators under flexible agreements concerning the form and duration of contracts^[10]. This means that agencies may enter employment contracts or service contracts with foreign experts for digital transformation purposes, facilitating the exchange of global experience. State-owned enterprises are likewise encouraged to cooperate and exchange experts in support of digital transformation. In addition, individuals with outstanding achievements in the field of digital transformation shall be honored and rewarded in accordance with LDT 2025 on emulation and commendation. Thus, LDT 2025 not only provides policy support but also serves as a motivational framework to inspire the digital expert community.

 3.5.          Support for SMEs and Cooperatives

LDT 2025 identifies the digital economy as a new driver of growth and therefore introduces mechanisms to support SMEs in developing within the digital domain. The State encourages these enterprises to apply digital platforms and participate in digital value chains, with the expectation of achieving double-digit growth contributions in the coming years.

This includes financial support, access to technology, and training programs aimed at enhancing the competitiveness of Vietnamese enterprises in the digital economy. The policy is intended to enable Vietnamese businesses to actively participate in the national digital value chain.

At the same time, state agencies are required to publicly and transparently disclose their digital transformation plans immediately after approval, in order to create timely opportunities for organizations and enterprises to engage in the digital transformation market. This also aims to promote the use and consumption of domestic “Make in Vietnam” products and services, thereby encouraging domestic production and enhancing the country’s economic and technological self-reliance.

3.6.          Development of Digital Citizens and Bridging the Digital Divide

LDT 2025 also emphasizes policies aimed at bridging the digital divide, particularly in remote areas, border regions, and islands. Accordingly, the State prioritizes the allocation of resources so that these areas are equipped with robust infrastructure to support essential digital services, such as online learning, remote medical consultations, and online public services. It also promotes the development of digital citizenship through electronic identification, digital signatures, online public services, telecommunications, and cashless payment systems, in accordance with applicable sectoral legislation. This aims to ensure that all citizens, including those in disadvantaged areas – have equitable access to the benefits of digital technology. In addition, LDT 2025 provides preferential policies to develop digital infrastructure and digital competencies for people with disabilities, the elderly, ethnic minorities, and populations in border and island regions, thereby actively narrowing the digital divide.

The budget for digital transformation is set at a minimum of 1% of total annual State budget expenditure, reflecting the highest level of prioritization for developing data centers and building a high-quality digital workforce^[11]. Moreover, LDT 2025 ensures alignment with current strategic directions (e.g., Resolution No. 57/NQ-TW, the National Digital Transformation Program, and Project 06/CP, etc.), and is consistent with broader Resolutions and policies of the Party and the State on digital economy development, thereby establishing an appropriate and unified policy framework while resolving the issue of fragmented implementation – “mạnh ai nấy làm”.

4.          Prohibited Acts in Digital Transformation Activities

To safeguard order and security within the digital environment, Article 5 of LDT 2025 establishes boundaries by explicitly defining prohibited acts. The first group of prohibited acts relates to obstructing or sabotaging digital transformation activities, including both administrative hindrances and technical attacks that disrupt system operations. The second group concerns data-related violations, it is strictly prohibited to access, interfere with, falsify, or destroy digital data without authorization, as well as to trade, share, or exploit data illegally, in ways that infringe upon privacy rights and breach data protection regulations. LDT 2025 also prohibits the abuse of digital transformation or emerging technologies such as artificial intelligence for the purposes of fraud, distortion, manipulation, or personal gain.

Importantly, LDT 2025 prohibits abuse of position or authority to hinder digital transformation or to create data monopolies or silos that restrict competition. Agencies or organizations that refuse to share data or deliberately obstruct interoperability to retain exclusive advantage shall be deemed in violation of LDT 2025. These provisions aim to eliminate parochial and siloed thinking, ensuring the unimpeded flow of data in service of the nation’s shared interests.