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AesirX ComplianceOne | Vietnam Data Law Decree 165/2025/ND-CP

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Decree 165/2025/ND-CP: Scope and Current Status

Decree 165/2025/ND-CP is an active implementing decree under Law 60/2024/QH15. It was issued on 30 June 2025 and has been effective since 1 July 2025.

The decree provides the operational detail required to execute Data Law work. ComplianceOne represents it as a child instrument, not as a separate parent law, so evidence remains connected to the broader data-governance framework.

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How Decree 165 Relates to the Vietnam Data Law

The Data Law establishes the parent governance framework. Decree 165 supplies the procedures, timelines, risk treatment, guidance, and official forms that support implementation.

The decree is also distinct from the Draft Decree on Data Exchange Operations. Decree 165 is active; the data-exchange instrument remains a draft. ComplianceOne keeps current execution separate from draft preparation.

Explore the Vietnam Data Law

Technical Provisions and Compliance Obligations

Operational AreaDecree 165 RoleEvidence to Maintain
Data governanceAdds procedures and guidance beneath the parent lawAssigned work, decisions, approvals, and supporting records
Time-bound workDefines operational timelines for relevant proceduresDue dates, completion proof, and escalation history
Risk handlingIdentifies compliance and operational risk areasRisk records, controls, findings, and remediation
Authority-ready documentationProvides official Mẫu số formsCompleted forms, source evidence, review, and approval
Cross-framework contextConnects to personal data protection and cybersecurity where relevantLinked evidence with preserved source and ownership

Official Forms

Decree 165 provides eleven official forms: Mẫu số 01a, 01b, 02, 03, 04a, 04b, 05a, 05b, 06, 07a, and 07b. ComplianceOne retains the official identifiers and connects each form to its supporting evidence.

The operational supplement does not create a second set of forms. It adds procedures, deadlines, risk records, and guidance around the official forms already associated with the Data Law implementation stack.

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How ComplianceOne Supports Decree 165 Compliance

Teams can select the relevant official form, assign contributors, collect supporting records, and route the package through review and approval. Form content and evidence remain linked throughout the process.

Procedure and timeline records provide accountable ownership for operational steps. Risk findings can be connected to controls and remediation instead of remaining as narrative warnings.

Audit history captures changes, contributions, reviews, and approvals. Evidence packages can be prepared for internal review or authority interaction without reconstructing the history from email and file shares.

Related Modules

Data MappingData Mapping

Maintains the data and system context behind governance records.

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Data ClassificationData Classification

Records classification decisions and review history.

Explore Data Classification

Program GovernanceProgram Governance

Maintains Records of Processing Activities aligned with Phu luc I data structure requirements.

Explore Program Governance

Compliance FormsCompliance Forms

Supports the eleven official Mẫu số forms.

Explore Compliance Forms

Audit TrailAudit Trail

Preserves evidence, contributor, review, and approval history.

Explore Audit Trail

Compliance Readiness Checklist

Organizations implementing Decree 165 compliance should confirm:

The parent Data Law and Decree 165 are represented as connected but distinct instruments.

The applicable official form is selected by its correct Mẫu số identifier.

Supporting evidence is linked to the form rather than stored separately.

Procedure owners and relevant due dates are assigned and monitored.

Risk findings are linked to controls or remediation actions.

Human review and approval are recorded before authority-facing use.

Audit history can be produced with the completed evidence package.

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See Decree 165 Compliance in Action

See how ComplianceOne connects official forms to procedures, risk records, evidence, and approval.

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Ronni K. Gothard Christiansen

Ronni K. Gothard Christiansen - Technical Privacy Engineer & CEO

Technical Compliance Expert, 32+ Years Open Source Advocate, X-BoD Open Source Matters Inc.

Or contact via

ronni@aesirx.io+84 909 500 760

Frequently Asked Questions

Yes. Decree 165/2025/NĐ-CP has been effective since 1 July 2025 and is the active implementing decree beneath the Vietnam Data Law.

The decree provides eleven official Mẫu số forms. ComplianceOne preserves their official identifiers and connects form preparation to supporting records and approval.

No. The supplement adds procedures, deadlines, risk records, and guidance around the official forms already present in the Data Law implementation stack.

No. Decree 165 is active. The Draft Decree on Data Exchange Operations is a separate child instrument that is not yet in force.

No. It supports controlled work, evidence, forms, reviews, and audit history. The organization remains responsible for legal interpretation and approval.

Next Steps

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Start a Compliance Pilot

Test Decree 165 forms, evidence, procedures, and review gates with your team.

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Discuss Your Compliance Needs

Review your Decree 165 evidence sources, owners, and authority-readiness process.