Law note · Vietnam

Law on Personal Data Protection, cross-border transfer

cite Law No. 91/2025/QH15, Article 20 stage RECENT in force 8 months effective 2026-01-01 kind Cross border transfer binds private bodies reviewed 2026-08-29

What it requires

An app transferring the personal data of an individual in Vietnam, including biometric data, to a recipient outside the country must satisfy Article 20's cross-border transfer conditions; a violation risks a fine of up to 5 percent of the organization's prior-year revenue, a materially higher tier than the Law's general penalty.

When LexLint raises it

crawls_web
trains_models
processes_voice
processes_biometrics

What we found

Article 20 enumerates the cases in which cross-border transfer of personal data is permitted; its substantive conditions, including any adequacy standard, government approval requirement, or data-localization element, were not read beyond the article's heading and opening clause this pass.

A separate penalties article confirms a materially strict enforcement posture: the maximum fine for an organization violating cross-border transfer regulations specifically is 5 percent of the organization's prior-year revenue, distinct from and higher than the Law's general violation fine tier.

Primary source

Government Portal (chinhphu.vn) citation
substantive text read via a private secondary translation (LuatVietnam)

← Back to the example · Lint your app →