Heightened enforcement of consumer protection laws in Vietnam: Digital platforms and influencer marketing in focus – www.hlc.com

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Vietnamese authorities are stepping up enforcement of the 2023 Law on Protection of Consumer Rights, with a clear focus on data use and advertising practices.
Recent penalties against several major online content and communications platforms signal a change in approach with scrutiny in three key areas: (1) consumer consent for data use, (2) influencer marketing disclosures, and (3) standard terms of contracts with customers.
Enforcement targets both local companies and global platforms, with increasing financial and reputational exposure.
For businesses operating in Vietnam, 2026 is a critical period to review compliance frameworks, especially for digital advertising, platform governance and consumer data practices. Additional enforcement actions may be forthcoming from the Ministry of Public Security on the basis of the new Law on Personal Data Protection, which it is tasked with enforcing.
The Vietnam Competition Commission (“VCC”), under the Ministry of Industry and Trade (“MOIT”), issues new penalties under the 2023 Law on Protection of Consumer Rights,_¹ signalling a shift to a more systematic enforcement.
On 2 June 2026, the VCC publicly announced sanctions against a foreign-invested company for: (i) failure to provide users with an opt-out mechanism for the use of their personal data in advertising and commercial activities, (ii) failure to disclose sponsored influencer content, and (iii) inclusion of prohibited clauses in standard terms and conditions.
This enforcement action forms part of a continuing series of penalties, following January 2026 decisions against other major online content and communications platforms. These decisions underscore the VCC’s increased regulatory scrutiny for compliance with consumer data protection practices.
Across the recent enforcement actions, three recurring risk areas emerge: 
Companies operating in Vietnam should expect more active enforcement, particularly for digital and Internet platform-based models. Regulators are increasingly focused on whether compliance is effective in practice, rather than merely formalistic. Priority should therefore be given to consent and data usage flows, influencer disclosure protocols, standard terms compliance, and consumer-facing processes, including addressing complaints and implementing opt-out requests as required by law.
The recent data privacy enforcement actions were all initiated by the VCC, which is mainly responsible for ensuring fair competition and consumer protection, with an emphasis on transparency, user control and fairness, particularly in digital environments. International businesses should note that further enforcement actions may be initiated by the Department of Cybersecurity and High-Tech Crime Prevention (A05) under the Ministry of Public Security on the basis of the Law on Personal Data Protection No. 91/2025/QH15 dated 26 June 2025 and its implementation Decree No. 356/2025/ND-CP dated 31 December 2025. 
The VCC’s recent enforcement actions are not isolated incidents; rather, they reflect a broader global tightening of legislative and regulatory scrutiny over digital platforms. Regulators across the APAC region and globally are increasingly targeting systemic issues such as user consent, marketing transparency, and fair contract terms. For instance, the European Union is currently advancing its proposed Digital Fairness Act to combat deceptive “dark patterns,” addictive product design, subscription traps, and undisclosed influencer marketing, amongst others. Concurrently, antitrust and data regulators in China are intensifying their scrutiny of algorithmic consent, hidden advertising, and predatory platform rules under the frameworks of antitrust anti-unfair competition rules as well as data regulations.
 
 
Authored by Gastón Fernández, Duong Pham, and Jiaming Zhang.
References
Gaston P. Fernandez
Hanoi, Ho Chi Minh City
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Duong Pham
Hanoi
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Jiaming Zhang
Hong Kong
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