Skip to content
Duong Tri Law
Request Advice
G1 online game licensing in Vietnam

G1 Online Game Licence Services in Vietnam

Duong Tri Law helps applicants review eligibility, reconcile legal and technical materials, and prepare G1 service-licence applications. Each proposed G1 title also needs its own release decision before launch. For overseas publishers, the applicant structure and market-access route must be assessed first.

Technical readiness review
G1 service scheme
Individual game release

Classify before filing

When is a G1 online game licence required?

G1 games involve simultaneous interaction between multiple players through the enterprise’s game-server system. Classification depends on the actual interaction model, rather than the game’s genre, mobile or desktop platform, or marketing description. Other models may fall under G2, G3 or G4 and should not be assumed exempt.

An enterprise providing G1 services needs a G1 online game service licence. This approval concerns the provider’s eligibility and operating arrangements; it is not an approval for one particular title.

Each proposed G1 title also needs its own G1 game release decision before release. A service licence does not automatically authorise the publisher’s catalogue.

Unsure of the classification?

Review player interaction before choosing the procedure

A short description and demo should show how players connect, interact with the servers and interact with one another. The appropriate application route follows that review.

G1–G4 classification guide (Vietnamese) →

Two separate approval stages

How do the enterprise licence and game release decision differ?

Plan both stages before committing to a Vietnam launch. The provider’s service licence and the decision for each game address different requirements, documents and reviews.

Stage 01 · The enterprise

G1 online game service licence

  • The applicant must be an enterprise established under Vietnamese law and meet the applicable operating conditions. Foreign-investment eligibility is assessed separately.
  • The formal application uses Form 29 and a service-provision scheme confirmed by the enterprise’s legal representative or head. The separate ERC/IRC copy requirement was repealed in April 2026.
  • The scheme describes service scope, financial and organisational capacity, systems, locations, domains, IP addresses, payment connections, player protection and contingency arrangements.
  • The statutory authority review period is 20 days from receipt of a valid application, rather than a complete-project commitment.
  • The official procedure lists no service-licence fee. Professional fees and other project costs are separate.

Official service-licence procedure ↗

Stage 02 · Each title

G1 game release decision

  • A separate application is needed for each G1 title intended for release in Vietnam.
  • Form 34 is accompanied by rights evidence, the game-release scheme and representative electronic gameplay materials required for the review.
  • The materials cover content, script, characters, tasks, maps, virtual items, interactions, version, age classification, payment arrangements and relevant operating controls.
  • The authority review period is a separate 20 days from receipt of a valid application.
  • The published content/script appraisal fee isVND 5,000,000 per application; check the applicable charge when filing.

Official game-release procedure ↗

A linked condition: the enterprise’s G1 service licence must have at least six months remaining when it applies for the game release decision.

Legal and operational readiness

What requirements should a G1 applicant prepare for?

The application must reflect an eligible applicant and an operating model capable of meeting the applicable controls. A description of a feature in a scheme does not build that feature or establish compliance in practice.

Vietnam applicant and registered activities

The enterprise must be established under Vietnamese law, have online-game service provision recorded on the National Business Registration Portal, and have a clear, reachable office address and telephone contact. Foreign investors need a separate ownership and market-access assessment; an offshore publisher or app-store listing does not replace the licensing route.

Service domains

Register the domain used to provide the service. Domains, IP addresses, distribution channels and connectivity should be consistent with the scheme and proposed system architecture.

Financial, organisational and staffing capacity

Prepare the financial, management and game-operation arrangements appropriate to the planned scale. Identify who is responsible for the service and how the operation will be supported.

Payments and transaction records

The technical system must support lawful connections to payment or payment-intermediary providers, keep accurate updated records and let players access details of their in-game payment accounts.

Player information and verification

Provide the required storage and updating of player information and verify accounts through Vietnamese mobile telephone numbers before allowing play. Data handling and access arrangements must also meet the applicable rules.

Players under 16

A parent or legal guardian registers the account using their own information and is responsible for supervising the child’s playtime and game content.

Playtime controls for players under 18

Daily controls must limit this age group to 60 minutes for each game and 180 minutes across the enterprise’s games covered by the rule. The system needs to distinguish per-title time from the aggregate daily limit.

Age classification and health warnings

Display the applicable age classification when introducing, advertising and providing the game. Implement the required health-warning display and frequency; the legal and engineering teams should check the actual screens and user flow.

Player communications and moderation

Provide systems and measures to manage exchanged or shared content in the game and its forum, where applicable, against the relevant content-management rules.

Virtual items, units and reward points

Maintain the required records of service use, account activity and virtual items, units and points. The operating model must also respect the specific restrictions on their use and exchange.

Information security and player protection

Prepare the required security, service-quality and player-protection arrangements. The provider must have at least one server system in Vietnam for statutory inspection, information-storage/provision and complaint-handling purposes.

Backup and contingency documentation

The service scheme still requires main/standby equipment, backup and contingency information. Decree 116/2026 repealed the separate condition at Article 39(1)(l); this does not remove the scheme’s remaining documentation requirements.

Distinguish law from design choices: engineering choices such as a particular HA design, monitoring stack, RTO/RPO target or penetration-test process should not be presented as standalone statutory conditions without a specific legal basis.

Technical readiness

Prepare the system description with the engineering team

The scheme and supporting diagrams should accurately describe the system intended for operation. Our legal review identifies requirements and inconsistencies; implementing, testing or remediating infrastructure is the applicant’s responsibility unless a separate task is expressly agreed.

Technical area What to review Typical gap to resolve
Main and standby systems Architecture, hosting locations, functions and proposed configurations of main and standby equipment, with the required contingency description. The scheme or diagram describes infrastructure different from the planned deployment.
Domains, IP addresses and connectivity Service domains, IP addresses, Internet/telecommunications connectivity providers and proposed connection capacity. Provider agreements, diagrams, domains or connectivity information do not match.
Player accounts Registration, Vietnamese mobile-number verification, player records and the parent/guardian route for players under 16. The application describes a feature without a demonstrable operational flow.
Playtime controls How the system measures and restricts under 18 playtime per game and across the relevant games provided by the enterprise. The per-title and aggregate limits are not implemented or distinguished.
Payments Lawful payment connections, records and the player’s ability to review the relevant account transactions. The actual payment route differs from the scheme or lacks clear records.
Virtual items and units The required updated records of virtual items, units, points and their use in the game. The history or permitted account use is unclear or inconsistent with the proposed game model.
Content and community Management of chat, forums and other player exchanges, including the escalation and moderation process. Interactive features are described without a workable moderation mechanism.
Backup, contingency and security The scheme’s backup and contingency description, service continuity, security and player-protection arrangements. Generic descriptions cannot be reconciled with the actual design, equipment or operating responsibility.

Documents and client inputs

What documents are needed for the G1 service licence?

Distinguish the formal filing dossier from the wider information needed to review eligibility and prepare it. For the initial discussion, a non-confidential overview is sufficient; agree a suitable channel before sending detailed technical or rights documents.

Filing document 01

Form 29 application

The prescribed G1 service-licence application form under Decree 147/2024, completed consistently with the applicant and proposed service.

Review inputs

Applicant and project records

Provide company and ownership details, available ERC/IRC or other relevant records, game description and demo, technical architecture, operating team and intended launch date. ERC/IRC copies can assist our review but are no longer a separate formal service-licence dossier item after Decree 116/2026.

Filing document 02

Confirmed G1 service-provision scheme

The scheme covers service scope, capacity, staffing, systems and locations, main and standby equipment, connectivity, domains, IP addresses, payment plans, player protection, data backup and contingency. It must be confirmed by the enterprise’s legal representative or head.

Common clarification points: diagrams and equipment specifications conflict; verification or age-control flows are unclear; payment, data, backup or contingency descriptions are generic; distribution channels or domain/IP details do not match the intended deployment.

The regulatory procedure

What are the stages of the G1 licensing route?

Start with eligibility and system readiness. Filing an application is not permission to launch; the authority decides whether the conditions for each approval have been met.

01

Review the applicant and activities

Confirm the Vietnam enterprise, ownership route, registered activities, office and contact details before preparing the service-licence dossier.

02

Confirm the game classification

Review the actual interactions between players and servers to identify the relevant G1 or other game category.

03

Review technical readiness

Reconcile servers, locations, domains, IP addresses, player verification and data, age/playtime controls, payments, security and contingency information.

04

Prepare the application and scheme

Complete Form 29 and the confirmed service scheme, using the actual project information. Separately identify the materials required for each game’s release decision.

05

File through the official channel

The service-licence application goes to the Ministry of Culture, Sports and Tourism through the Authority of Broadcasting and Electronic Information, using the available official filing route.

06

Respond to the review

The authority reviews the valid dossier. Coordinate any requested explanations or additional records; required technical remediation must reflect the actual system.

07

Receive the authority’s result

If the conditions are met, the authority issues the service licence. A refusal must state reasons. Duong Tri Law hands over the result and agreed filing records; approval cannot be guaranteed.

08

Complete each title’s release route

File the separate game-release dossier and obtain the release decision before release. Put required licensing information, record-link codes and operating controls in place before launch.

Timing and fees

How long does G1 licensing take, and what affects cost?

Separate statutory authority review from client preparation, implementation and negotiations over game rights. Complete and consistent inputs are necessary before a realistic filing plan can be agreed.

Enterprise service licence

20 days

The statutory review period runs from receipt of a valid application. The published procedure lists no service-licence fee; this does not include professional fees or implementation costs.

Each game release decision

20 days

A separate authority review period applies to each valid release application. The published content/script appraisal charge isVND 5,000,000 per application, subject to the applicable schedule when filed.

Professional fees

Quoted for the agreed project scope

Fees depend on applicant readiness, the scheme and technical documentation, rights materials, the number of titles, translation/formalities and the agreed filing and follow-up work. Engineering remediation and other third-party costs should be identified separately.

The two periods do not guarantee a 40-day launch. Document preparation, technical changes, missing rights evidence, clarification requests and client decisions can change the project timetable. Each approval remains a separate authority decision.

Prepare each title for release

What is needed before an individual G1 game launches?

The game-release review concerns the rights to publish in Vietnam, content and script, age classification, version, payment arrangements and representative electronic gameplay materials. The dossier includes Form 34, rights evidence, a confirmed release scheme and the required demonstration materials.

For a title licensed from an overseas rights-holder, review the contracting entities, Vietnam territory, term and rights granted. Consular legalisation and certified Vietnamese translations are required where applicable; identify the document route before obtaining originals or translations.

For a self-developed title, IP records can help establish the rights concerned but do not replace the service licence or the individual release decision. Check the content restrictions and age rating before committing to a release date.

A condition at application

At least six months on the service licence

The applicant’s G1 service licence must have at least six months remaining when it seeks the release decision. Rights, content and age-classification conditions must also be met; having a valid company licence alone is insufficient.

Vietnam game-release guidance (Vietnamese) →

Ongoing obligations and later applications

Maintain the required operating controls, player protections, licence information and official-record links on the service website and app-store description where applicable. The provider must make six-monthly reports using Form 47, no later than 6 June and 25 November each year, and provide additional reports when lawfully requested.

Changes to the company name, legal representative, office addresses or server address require a service-licence amendment application within 10 days. Changes to a game title, origin, age rating, content/script, distribution scope or server location have their own amendment rules. Ownership changes can require new applications; review the actual change before implementation.

An extension of the publishing-rights agreement follows the game-release amendment route. The former G1 service-licence and game-release reissuance procedures were repealed in April 2026. Renewal is separate: temporary rules delegate service-licence renewal to the provincial cultural authority from 1 June 2026 through 1 March 2027, subject to replacement provisions. Check the current route when preparing an application.

Published licensing documents

Examples of G1 licensing documents

The documents below illustrate published G1 licence results. Each applicant, system and title requires its own review under the rules applicable when filing; an earlier result does not establish eligibility or predict approval for another project.

Selected documents

G1 service-licence examples

Select an image to enlarge

Case-specific review: these examples do not disclose a complete project file, agreement or technical architecture. The scope and supporting evidence for a new engagement must be established independently.

Our service scope

What can Duong Tri Law’s G1 licensing service include?

The engagement specifies the applicant, applications, game titles, deliverables, client inputs and work covered. Additional titles, project changes, engineering implementation, investment work or other specialist procedures may require a revised or separate scope.

Game classification

Review player interactions and the service model to identify the applicable category before choosing the filing route.

Applicant eligibility

Review the Vietnam enterprise, activities, ownership route, domains and legal records needed to assess readiness.

Legal and technical gap review

Review system materials against licensing and operational requirements and identify information or implementation gaps for the applicant’s technical team.

G1 service scheme

Draft and reconcile the scheme, architecture descriptions, equipment information and service arrangements against the actual project for client confirmation.

Application documents

Prepare the agreed forms, legal and technical materials and evidence checklist. The package follows the current dossier rules rather than an obsolete registration-certificate checklist.

Filing and authority follow-up

Submit or assist with the agreed filing within the authorised mandate, track correspondence and coordinate explanations or supplementary materials where requested.

Individual game-release dossiers

Review rights, content/script materials, age classification, payment arrangements and representative electronic materials for the titles expressly included.

Handover and later changes

Hand over filing records and the authority result, explain applicable conditions and provide the agreed compliance checklist. Review later company, domain, system or game changes before implementation.

Connected legal work

Identify whether foreign investment, corporate changes, copyright, contracts or other procedures need separate advice. Legal guidance does not itself complete those procedures or build the technical controls.

Our engagement process

How do we coordinate the G1 legal work?

This is the client-service workflow, separate from the authority’s statutory procedure. We agree responsibilities and project assumptions so the legal drafting and technical evidence remain consistent.

01

Understand the project

Review the applicant, demo, proposed architecture, rights source, existing approvals and target launch date. Start with a non-confidential overview.

02

Identify the gaps

List the requirements and information already available, the missing evidence and the technical or rights issues the applicant needs to resolve.

03

Agree the scope and plan

Define the applications and titles covered, documents to be provided, outputs, fee basis, working language and expected stages. Separate preparation from authority review.

04

Reconcile the filing materials

Prepare the scheme and forms, align diagrams and specifications, and obtain the client’s confirmation of the factual and technical descriptions.

05

File and coordinate responses

Carry out the agreed filing support, update the client on material correspondence and coordinate responses to clarification or supplementation requests.

06

Hand over the result and next steps

Deliver the authority’s result, retained application materials and agreed checklist. If the service licence is issued, identify the remaining individual-title approvals and operating requirements before launch.

Risks and continuing compliance

What happens if a provider operates without the right approvals?

Operating without the enterprise licence, releasing a title without its decision and operating outside approved arrangements are distinct compliance issues. Assess the actual conduct and applicable sanctions before deciding how to respond.

Enterprise approval

Providing G1 services without the service licence

This is separate from missing an individual title’s release decision. Submission, an app-store listing or an overseas approval should not be treated as Vietnam permission to operate.

Individual title

Releasing or advertising a game too early

Each G1 title needs its release decision before release. The rules also restrict advertising before the relevant release approval; plan marketing and distribution with the approval route.

After approval

Changing the operation without reviewing the procedure

Changes to the applicant, systems, servers, domains, title or distribution model can trigger amendment or other requirements. Review the change before putting the new arrangement into operation.

Sanctions and corrective measures depend on the conduct, responsible party and rules in force at the time. Decree 174/2026 includes online-game violations; a single fine should not be presented as applying to every case. See Vietnam game-operation guidance (Vietnamese) →

Frequently asked questions

Questions about G1 game licensing in Vietnam

What makes a game G1?

The defining model is simultaneous interaction between multiple players through the enterprise’s game-server system. Review the actual interactions before choosing the route. Other models may fall under G2, G3 or G4 and are not automatically exempt from regulation.

Does a G1 service licence permit every game to launch?

No. The service licence concerns the enterprise’s provision of G1 services. Each G1 title also requires its own release decision before release. Filing the application does not authorise launch, and pre-approval advertising is also restricted.

Can one G1 service licence cover a provider with several titles?

The service licence is issued to the enterprise rather than separately for every title. Each G1 game still needs a release decision and must operate consistently with the provider’s valid licence, systems and applicable requirements. The engagement should specify the number of titles and applications included.

How much validity must remain on the service licence?

At least six months must remain when the enterprise applies for a game release decision. The rights, content, script and age-classification conditions also need to be met.

What technical materials should we prepare first?

Start with architecture and hosting locations, main and standby equipment, domains, IP addresses and connectivity, verification and player records, age/playtime controls, moderation, payments, backup and security arrangements. These must reflect the proposed system. At least one server system must be in Vietnam for the statutory operational purposes.

Can a title licensed from a foreign rights-holder obtain a release decision?

It can be assessed if the applicant establishes the required rights to publish in Vietnam and meets the other conditions. Review territory, term, parties, content and supporting evidence. Foreign rights documents require review of legalisation and certified Vietnamese translation requirements for the actual case.

When do the 20-day periods begin?

The statutory periods are 20 days from receipt of a valid service-licence application and a separate 20 days from receipt of a valid title-release application. The provisions use days rather than working days. Client preparation, missing materials, clarification and technical remediation are separate from a promised project completion date.

Do server, domain or system changes require a procedure?

The route depends on the change. Certain company or server-address changes require a service-licence amendment application within 10 days. Game changes have their own amendment rules, and ownership changes can require new applications. Review the current route before implementation rather than relying on an old reissuance checklist.

Can a foreign-invested company apply?

A Vietnam applicant and a separately assessed foreign-investment route are required. Review the investor, ownership structure, proposed activities and applicable market-access conditions before confirming eligibility. Incorporation or a G1 application does not itself approve foreign investment. Foreign-law advice, company formation and investment filings are separate unless agreed.

Related English services: foreign investment in Vietnam; company formation for foreign investors.

Discuss your G1 project

Prepare the licensing route before committing to a launch

Send a short overview of the Vietnam applicant, game demo and interaction model, system readiness, publishing rights and target date. Duong Tri Law will identify the matters to review and define the proposed legal scope, inputs, deliverables, timetable assumptions and fees. Agree an appropriate channel before sharing sensitive technical or rights records.

Duong Tri Law

Tell us what you need

Tell us about your business, the matter and any deadline. We will discuss the scope of assistance before work begins.

Contact Duong Tri Law (EN)