Direct trading
The operator sells its own goods or services through the app; it still needs applicable platform, consumer and disclosure checks.
E-commerce App Registration & Compliance in Vietnam
Assess a mobile app’s business model, operator and transaction functions before choosing the current e-commerce filing and operating obligations.
SERVICE GUIDE
Classify the app by its real functions
An app-store description often hides the legal complexity. We classify what the operator and other participants actually do in the app.
Intermediary marketplace
Third-party sellers open accounts, list offerings or transact with users; the operator has a different governance role.
Integrated platform
The app aggregates or connects services, sellers or other platforms; each transaction and responsibility flow needs mapping.
The platform category is based on the E-commerce Law and Decree 248/2026, not on whether the product team calls the app a store, super-app or marketplace.
SERVICE GUIDE
What to collect from product and operations
Screens, policies and operator records need to describe the same version of the app.
Product evidence
App-store link or test build, key screenshots, user and seller onboarding, checkout, payment, cancellation and dispute paths.
Operator evidence
Legal entity details, contact point, app name, connected domains, service providers and responsible team.
Policy evidence
Terms, privacy notice, seller rules, complaint process, content controls and any proposed platform operating scheme.
We review a functioning build where possible. A PDF deck alone may miss features that change the platform category, such as third-party storefronts or in-app payment routing.
SERVICE GUIDE
Review public information before filing
The regulator’s file, app interface and customer-facing terms should be consistent at every step.
Operator disclosure
Show the legal operator and reliable contact and complaint channels.
Transaction transparency
Make price, order confirmation, payment, fulfilment and cancellation understandable in the actual screen flow.
Seller governance
For a third-party model, describe seller checks, prohibited content, listing controls and dispute handling.
App-store approval checks platform-store rules, not Vietnamese legal compliance. The company must separately assess personal data processing, consumer protection and any sector licence triggered by the goods or services.
SERVICE GUIDE
Avoid the errors that delay an application
The Vietnamese source highlights mismatches between the declared model and the product as a recurring cause of clarification.
Wrong platform category
An app declared as own-sales may in fact host independent sellers or facilitate their transactions.
Outdated screenshots
The submitted screens may not match the current release or omit seller and checkout functions.
Incomplete policies
Terms may fail to explain payments, complaints, takedowns, data use or the operator’s responsibilities.
The remedy is a product-to-filing matrix and a short list of design or policy fixes before submission. We identify the current filing channel and supporting documents only after the category is settled.
SERVICE GUIDE
Launch, transition and feature changes
A pre-1 July 2026 confirmed app has a transitional position through 30 June 2027; a new launch should be planned under the current framework.
Existing confirmation
Compare the confirmed profile with today’s operator, app name and functions before relying on it.
New launch
Check the current route, disclosures and platform controls before opening transactions.
Later release
Reassess new seller, payment, livestream or cross-border features and update the record where required.
The legal-service quote separates classification, policy drafting and filing from implementation work and later feature reviews. The company retains responsibility for operating the app consistently with the approved or notified profile.
SERVICE GUIDE
Foreign investors and cross-border app models
International operators often combine an app, overseas infrastructure and a Vietnam-facing commercial activity.
The initial review identifies which entity owns and operates the app, who contracts with users, where payment is collected and whether independent sellers participate. The answer may affect both the e-commerce route and connected foreign-investment, tax, consumer or data obligations. A Vietnam subsidiary does not automatically make every function of an overseas group app part of its existing filing.
We distinguish the operator’s current release from planned functionality. This prevents a future marketplace, advertising or cross-border feature from being treated as if it had already been reviewed and authorised. The engagement can include a roadmap assessment if those features are expected soon.
SERVICE GUIDE
A product-team checklist before submission
Legal wording alone cannot repair a screen flow that hides the operator, obscures charges or lacks a usable complaint route.
Product and operations should verify the real screens for account creation, seller onboarding, transaction confirmation, cancellation, payment, support and takedown. The declared platform model, terms and policies should describe those screens accurately. The legal team records gaps as product tasks with owners before the filing is finalised.
After submission, keep the version and screenshots used for the filing. When the app changes, compare the new version with that evidence and assess whether disclosures, seller rules or filing details need an update.
HOW WE WORK
From first review to next decision
- Map the app and partiesMap the app’s operator, user and seller journeys, including payment and dispute flows.
- Determine the current legal categoryClassify the current release under the e-commerce framework and check any legacy confirmation.
- Prepare policies and required recordResolve gaps between live screens, terms, seller rules and the filing evidence.
- File and monitor feature changesUse the applicable current submission route and review material feature releases before launch.
INITIAL REVIEW
What to send for a useful first review
These items let us classify the route and give a realistic scope before requesting originals, translations or formal signatures.
- App-store URL or test build and the version planned for launch.
- Screens showing customer and seller onboarding, listings, checkout and payment.
- Operator details, connected website/domain and support contacts.
- Terms, seller rules, privacy and complaint-handling policies.
- Earlier app filing confirmation or plans to add third-party and cross-border features.
SERVICE GUIDE
What the engagement can deliver
A screen-flow review, platform classification note, policy and filing checklist, and a launch/change register for new features. Before release, reconcile app-store descriptions, in-app terms, operator details and the legal filing. Keep a change log for seller onboarding, payments, livestream, cross-border features and any move from direct sales to an intermediary model. Quote the initial classification, policy drafting and filing work separately from later feature reviews.
Questions before you proceed
Does every shopping app need the same registration?
No. The platform type and its actual functions determine the route.
What if the app adds third-party sellers later?
Reassess its classification and filings before launching the new feature.
Is app-store approval sufficient for Vietnam?
No. The store review and Vietnamese e-commerce obligations address different questions.
Does an own-sales app have no filing duty?
Do not infer that from the absence of third-party sellers. Check the current procedure and required public information.
When should a feature update be reviewed?
Before enabling seller accounts, new payment flows, livestream, aggregation or cross-border functionality that may change the platform classification.
LEGAL BASIS
Source and scope
This guide draws on Law 122/2025/QH15 and Decree 248/2026/ND-CP and the corresponding Vietnamese service page. Forms, deadlines and filing routes should be confirmed against the current rules and the facts of each matter before submission.
NEXT STEP
Discuss the facts before filing
Send the current records, your planned activity and any deadline. We will identify the initial questions and agree the scope of work.