Four things organisations need to know

Self-classification is an obligation

Under Decree 142/2026/ND-CP, providers of AI systems classify their risk level before putting a system into use, and are accountable for that classification. We prepare a classification record with its legal basis, checked item by item against the list.

The high-risk list is closed

Decision 33/2026/QD-TTg, in force since 15 August 2026, lists 46 systems in 6 sectors. For banking, its two entries apply only when a system executes transactions or grants credit automatically, without independent human review or approval.

Human approval has to be provable

A human approval step is what keeps a system off the list. When an inspection comes, the approval trail needs to come from system logs, not only from a process on paper.

Personal data is the larger risk

The Personal Data Protection Law 91/2025/QH15 sets fines of up to 5% of the previous year’s revenue for breaching the rules on transferring personal data abroad. Keeping data in your own cloud account and region is the simplest answer.

When a system is integrated, modified or repurposed, it must be classified again. This page is an introduction and does not replace legal advice for a specific case.

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