LEGAL AND IMPLEMENTATION BOTTLENECKS IN VIETNAM’S NATIONAL DIGITAL TRANSFORMATION

Abstract

This article assesses legal and implementation bottlenecks in Vietnam’s national digital transformation from 2020 to September 2026. It examines the National Digital Transformation Programme, Project 06, related implementation programmes, the 2024 Data Law, the 2025 Personal Data Protection Law, the 2025 Digital Transformation Law and implementing instruments, and compares their regulatory design with official implementation reports. The analysis finds that the central problem is no longer the absence of strategic direction or a general statutory framework. Since 1 July 2026, the Digital Transformation Law and Decree No. 224/2026/ND-CP have introduced the once-only principle, requirements for online public services, and new rules on financing, investment, procurement and experimentation. Remaining bottlenecks concern uneven data quality and interoperability, incomplete process re-engineering, differences in implementation capacity across public bodies, the still-untested effectiveness of newly introduced investment and procurement mechanisms, and inconsistent integration of cybersecurity and personal-data protection across system lifecycles. The article argues that legal reform should now focus on enforceability, measurable outcomes and accountability in data governance, digital public services, digital investment and system security