On 17 September 2025, Deputy Prime Minister Nguyễn Chí Dũng signed Decision No. 2074/QĐ-TTg, thereby approving a scheme to build a National Enterprise Database (the “Database”) covering all economic segments—state-owned, non-state, and foreign-invested enterprises. The Scheme is intended to serve both governance objectives and improvements to business support services, including transparency, monitoring, and facilitating investment, production, and enterprise activity.
The Scheme mandates that by end-2025, a basic enterprise database shall be established using four primary data sources: business registration, taxation, import-export, and social insurance. That foundational stage is to support the development of an Enterprise Health Index to gauge the general vitality of enterprises and entrepreneurs.
Thereafter, in 2026, the Database will be expanded to include credit and investment data, together with deployment of analytic tools leveraging artificial intelligence, machine learning, and big data techniques, aimed at more closely evaluating enterprise performance. From 2027 to 2030, the Database will further integrate data from labor and employment, intellectual property, innovation, technology, digital transformation, sustainable development, and related datasets on digital platforms. Real-time data enrichment, open data access, and improved digital infrastructure are integral to these phases.
Legally, the Database will share basic data with the National Resident Database, the national general database, and various sectoral databases. Authorities will introduce reporting systems for both financial and non-financial indicators, early warnings of violations, and post-inspection oversight based on the data collected.
The legal and practical ramifications for domestic and foreign businesses, and for legal advisors, are significant. Among the principal implications:
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Firms should anticipate more robust regulatory oversight based on enterprise performance metrics. Increased data sharing among ministries and local authorities means that inconsistencies, delays or non-compliance may become more visible.
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Enterprise registration, tax, import/export, and social insurance records will form part of public metrics; businesses should ensure their records are accurate, up to date, and compliant.
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The development of the Enterprise Health Index may influence eligibility for government programmes, financing, or incentives. How this index is constructed—what weighs more (financial vs non-financial indicators)—will matter.
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Intellectual property, innovation, digital transformation efforts will become increasingly relevant. Firms that invest in these areas could benefit through favorable signal in the governance system.
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Data protection, privacy, and cybersecurity legal frameworks will need to keep pace. As the Database collects and integrates cross-sectoral data—including personal or resident data for foreigners and citizens—legal compliance with data protection laws will be essential.
While the Scheme is ambitious and promising, its implementation will face challenges that legal advisors must help clients anticipate. Among these:
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Data integration across multiple ministries and local jurisdictions risks inconsistency. Differing interpretations of what data may be shared, how it is shared, and how often could create legal uncertainties.
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If the legal framework for data access, privacy, security, and liability is not sufficiently precise, enterprises may face exposure to regulatory risk or breach when data is shared or disclosed.
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The timelines are tight: launching basic database by end-2025, then rapidly expanding in 2026 and beyond, will require both technical and legal preparedness.
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Firm governance will depend heavily on quality of data; if data is unreliable, delayed, or incomplete, the Health Index and reporting systems may mislead rather than assist.
Decision No. 2074/QĐ-TTg establishes a foundational reform in Vietnam’s legal and regulatory landscape, aiming to build a comprehensive national business data architecture that supports governance, business facilitation, and transparency. For enterprises—whether domestic or foreign—legal practitioners, and policymakers, the coming months will be crucial: alignment of corporate data processes, review of compliance obligations, stronger internal record-keeping, and preparing for new reporting or early-warning systems will be essential to derive full benefit and manage legal risks.
