Digital goods fuel innovations but the laws are catching up in the virtual economies.
Vietnam’s digital economy is growing fast. More apps are offering digital rewards, in-app purchases, and monetized gifts. But behind the excitement, a new law is changing the rules. Platforms that fail to prepare may find themselves blocked.
The challenge lies in a misunderstood legal space: virtual goods regulation in Vietnam. While developers focus on user experience, Vietnamese authorities are now watching the virtual economy with closer eyes. The law defines, classifies, and supervises digital items with real world value.
If your business involves in-app credits, gifting tools, or user-generated rewards, you would need to watch and avoid five mistakes and stay legally safe under the virtual goods regulation in Vietnam.
Why Virtual Goods Suddenly Matter in Vietnam
For years, Vietnam allowed digital platforms to operate in a legal gray zone. Apps distributed across borders. Payments flowed freely. No one asked tough questions about how virtual items were created, sold, or exchanged.
Then came the Vietnam law on digital technology industry, a major legal reform that takes effect on January 1, 2026. This law defines what virtual goods are, who can distribute them, and how platforms must operate.
Now, virtual items are not just game stuff anymore. They are legally recognized assets. That means they come with obligations.
This shift is not just a local issue. Any platform that allows Vietnamese users to top up credits, send gifts, or receive monetized rewards must comply with these rules under virtual goods regulation in Vietnam.
What You Would Need To Know?
In here, we will break down the five most common traps foreign platforms fall into when dealing with virtual goods regulation in Vietnam, being:
- What qualifies as a virtual good
- Why digital features may require licensing
- How payment flows trigger compliance
- What sandbox approvals mean and when you need them
- How to structure agreements with Vietnamese resellers
We will then go through a step-by-step guide on virtual goods regulation in Vietnam and FAQ to help your team navigate the new law that details virtual goods regulation in Vietnam. Whether you are a developer, legal counsel, or CEO, this gives you some ideas toward compliance in operations in Vietnam.
What Virtual Goods Look Like in Real Life
Look into your platform that allow:
- Users buy “gems” to unlock features in a game
- Viewers tip livestreamers using “stars”
- Fans send “gifts” to content creators
- Users earn “tokens” that convert to cash
All of these would count as virtual goods under the new legal framework.
What makes this complex is how the goods interact. One digital item may be purchased with real money, another may be earned, a third might be traded or redeemed. When these virtual units affect user spending or income, they become legally significant.
It is no longer about code. It is about currency, tax, and compliance.
The 5 Legal Traps You Must Avoid Under Virtual Goods Regulation in Vietnam
Trap 1: Assuming virtual goods are unregulated
The Vietnam law on digital technology industry defines virtual goods as any digital items with transactional value. If your platform sells or allows the resale of digital units, even indirectly, you must comply under the virtual goods regulation in Vietnam.
Do not assume that this game is only about entertainment or not withdrawable nature that you can get away without being subject to enforcement. The law looks at economic function, not just technical design under the virtual goods regulation in Vietnam.
Trap 2: Using unlicensed payment channels
Many platforms rely on resellers or corporate top-up agents. In Vietnam, this model may be flagged if the agreement involves virtual goods but lacks clear tax treatment or legal purpose under the virtual goods regulation in Vietnam.
Bank transfers oversea have been denied because platforms could not explain what the payments were for. If your distributor agreement is vague, it may block funds.
Trap 3: Ignoring consumer rights and refund rules
Vietnamese law protects users who purchase or lose digital items. If a user buys credits and does not receive them due to a technical issue, or if a gift is wrongly transferred, your platform may be liable.
Under virtual goods regulation in Vietnam, platforms must adopt clear policies for user complaints, refunds, and lost assets. Ignoring these can lead to investigation.
Trap 4: Misunderstanding What Counts as a Virtual Goods
Many platforms presume their “gifts” are just emojis or icons. But Vietnamese regulators are focusing on function over form. Under virtual goods regulation in Vietnam, if the item represents value, it is treated like a digital asset, even if the platform calls it something playful.
Trap 5: Overlooking reseller compliance
If your platform signs contracts with Vietnamese entities to distribute digital units (e.g., top-up partners or local agents), those contracts must be reviewed to reflect local law.
If the reseller can not prove legal use of funds or purpose of transaction, Vietnamese banks may reject transfers. That affects your cash flow, and your reseller relationships.
Every agreement should define:
- The type of virtual goods involved
- Purpose of the transaction
- Pricing model (fixed or flexible)
- Restrictions on resale or refunds
Step-by-Step Guide to Stay Compliant
Step 1: Map all virtual goods used on your platform.
Step 2: Identify if users in Vietnam can access, buy, or redeem them.
Step 3: Review your distributor or reseller agreements.
Step 4: Ensure the agreements explain the product, payment purpose, and refund rules.
Step 5: Consult a local lawyers in Vietnam to determine virtual goods definition.
Step 6: Prepare internal documentation to explain virtual asset flows.
Step 7: Establish user complaint and refund policies for Vietnam.
Step 8: Monitor updates from authorities on enforcement guidance.
FAQ: Virtual Goods Regulation in Vietnam
Q1: My platform doesn’t use real money. Are we still affected?
Yes. If users exchange digital goods that represent value (gifts, credits, tokens), it may still be regulated.
Q2: We only sell to distributors. Why are banks rejecting transfers?
Banks in Vietnam are cautious with payments labeled as “virtual items” unless clear legal justification is provided. Documentation preparation helps.
Q3: What is the sandbox, and why apply?
It’s a government program that allows platforms to test regulated features without facing full enforcement. It’s ideal for experimental monetization tools.
Q4: What happens if we do nothing?
You risk blocked payments, app store removals, or being blacklisted as non-compliant.
Q5: Can we rename our digital goods to avoid legal problems?
No. The law focuses on function, not names.
Act Now, Do not Wait
The time to act is not next year. It is now. Platforms that begin compliance work in 2025 will be ready when the Vietnam law on digital technology industry is enforced. Those who wait may face confusion, disruption, or shutdown.
Go review your systems. Talk to your legal counsels in Vietnam. Protect your users.
About ANT Lawyers, a Law Firm in Vietnam
We help clients overcome cultural barriers and achieve their strategic and financial outcomes, while ensuring the best interest rate protection, risk mitigation and regulatory compliance. ANT lawyers has lawyers in Ho Chi Minh city, Hanoi, and Danang, and will help customers in doing business in Vietnam.
Source: https://antlawyers.vn/update/virtual-goods-regulation-in-vietnam-traps.html
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