1. Why is obtaining a game license in Vietnam important ?

Vietnam is one of the fastest-growing video game markets in Southeast Asia; however, this comes with a highly specific legal requirement system. Simply putting an entertainment product on online app stores and running advertising campaigns to attract users may be effective in many other countries, but in Vietnam, businesses need to pay special attention to legal compliance. If an enterprise releases an entertainment product accessed by players in the territory of Vietnam and generates fee-collection activities such as in-app purchases, maintaining membership subscriptions, selling virtual items, or displaying commercial advertisements, possessing a valid license is a prerequisite. Common risks when businesses lack or provide incorrect license information encompass many particularly serious aspects that directly affect the survival of the project.

1.1 Risk of payments being blocked or requirements for additional documents

The online payment system is a key factor maintaining the business operations and capital recovery capability of every video game. Under the regulation of legal documents on non-cash payments, specifically Decree No. 52/2024/ND-CP, cross-border payment activities are subject to extremely strict supervision. Payment platforms, credit institutions, intermediary payment gateways, or advertising partners have the right and obligation to require the publishing enterprise to prove its compliance with local laws through valid licenses. When the authorities discover a game without a license or using unapproved payment flows, the State Bank of Vietnam has the authority to request organizations providing intermediary payment services to disable transaction codes connecting to the enterprise’s destination account, causing an immediate interruption of revenue.

1.2 Risk of the application being removed or restricted in distribution

 An inevitable consequence of ignoring legal regulations is direct intervention from state management agencies regarding digital product distribution channels. Vietnamese authorities regularly conduct reviews of the network environment and will send written requests to global app distribution platforms such as Apple and Google to proceed with the removal of games that violate local laws. If reported by consumers or discovered during periodic reviews to have signs of violation, unlicensed games will immediately be required to be removed or have their visibility restricted across all app stores for users in Vietnam.

1.3 Administrative violation penalties

Depending on the nature of the act and the actual severity of the violation, foreign enterprises or their representative publishing partners in Vietnam may be subject to very severe administrative handling measures. Based on Decree No. 15/2020/ND-CP, amended and supplemented by Decree No. 14/2022/ND-CP, and most recently Decree No. 211/2025/ND-CP, the financial penalty for the act of organizing the release of unlicensed games is very substantial for an organizational legal entity. Accompanying these financial penalties are radical remedial measures such as forcing the return of all illegal profits obtained from the act of organizing the provision of illegal services.

1.4. The importance of a long-term publishing strategy

 If the enterprise intends to release a product under a long-term strategy, build brand reputation, and develop a loyal player community, the principle of strictly complying with legal regulations right from the project initiation phase always yields much higher economic efficiency than having to consume resources to handle legal crises later. Possessing a valid license provides the enterprise with legitimate rights to sign public advertising contracts, connect directly with domestic payment gateways with preferential transaction fees, and comprehensively protect the intellectual property rights of the product.

2. Context: A growing market but tighter management

The online entertainment market in Vietnam continues to record strong growth year over year; however, this rapid development always comes with increasingly strict and comprehensive state management requirements.

2.1 The development of the digital entertainment ecosystem

The growth of the domestic market is driven by a very high rate of users owning smartphones and the notably increasing habit of willingness to spend on digital entertainment content. Along with that, the payment ecosystem and content distribution channels have become extremely diverse, ranging from common domestic e-wallets to bank card payment channels, creating incredibly favorable technical conditions for the commercialization of all types of products.

2.2 Direction on content control and age rating

Parallel to the growth in scale, state management agencies have also begun to tighten the control of script content, player age ratings, and the elimination of easily controversial elements. The issuance of Decree No. 147/2024/ND-CP has established a completely new standard for the protection of children in the cyber environment. This legal document requires publishing enterprises to deploy technical systems to manage playtime, specifically stipulating that players under eighteen years of age are not allowed to participate in one video game for more than sixty minutes per day, and the total time participating in all games must not exceed one hundred and eighty minutes in a day. At the same time, the management of games provided via the internet and forms of community interaction is standardized to thoroughly prevent violent elements or cultural deviation tendencies.

2.3 Mandatory requirement for a responsible entity within the territory

 The current state management direction strengthens the mandatory requirement of having a direct legally responsible entity in Vietnam. Any international organization providing cross-border information services that generate revenue from domestic users is bound by strict regulations regarding the requirement to authenticate user identity using mobile phone numbers in Vietnam, comply with the obligation to store personal information data on server systems, and bear the responsibility to coordinate in handling incidents upon request from state management agencies.

3. Regulatory bodies and scope of application

In Vietnam, the review for licensing and administrative procedures related to the release of online games are generally associated with specialized regulatory agencies under the Ministry of Information and Communications.

3.1 Specialized regulatory agencies at the central and local levels

 The highest state management responsibility for this service belongs to the Ministry of Information and Communications. Within the management organizational structure, the Authority of Broadcasting and Electronic Information is the unit directly in charge of receiving dossiers, conducting technical appraisals, and considering licensing for the most complex types of games, specifically games under the G1 classification. For game groups with simpler interactive characteristics including G2, G3, and G4 classifications, the authority to receive notifications and manage activities is decentralized to the Department of Information and Communications or the Department of Culture and Sports in the locality where the enterprise registers its head office.

3.2 Scope of application for revenue-generating publishing activities

 The scope commonly subject to regulations regarding mandatory licensing includes products released and targeted at users in Vietnam, especially when there is the presence of commercial fee-collection forms. Besides, games with online connection features, maintaining interaction among players, operating a server system, or providing community maintenance services all fall under the direct control of state management agencies.

3.3 Criteria for determining target players in Vietnam

 A crucial legal note is that the country where the physical server system is located is not always the sole factor determining jurisdiction. In practice, state management work often focuses on the impacted target players and the paid service provision activities taking place in the territory of Vietnam. If an entertainment product attracts a large number of Vietnamese users to participate and generates a domestic payment cash flow, the entire local legal system will be activated and strictly applied to that product.

4. License classifications: What are G1, G2, G3, G4 ?

In the practice of legal consultancy and conducting service operations, online games in Vietnam are typically divided by law into four basic groups from G1 to G4. Businesses need to correctly understand the nature of each classification group in order to prepare dossiers and build an accurate release plan.

4.1 Nature and characteristics of G1 video games

 G1 video games are defined as games that feature simultaneous interaction among multiple players through a game server system managed by the enterprise itself. Typical examples for this group include massively multiplayer online role-playing games, multiplayer online battle arenas, shooting games with online matchmaking and competitive interaction features, or games that maintain a guild system, feature internal item trading, or have cross-server chat. If the game maintains real-time multiplayer interaction features or complex social features, that product will lean toward the G1 classification.

4.2 Nature and characteristics of G2 video games

 G2 video games are games that only feature direct interaction between each single player and the enterprise’s server system, but with absolutely no direct interaction among the players themselves. Typical examples for this group are online games in the form of developing personal account progression, featuring one-way achievement leaderboards, or server-controlled competition events but with no direct competitive matching features between users at the same time.

4.3 Nature and characteristics of G3 video games

G3 video games are games that feature multidimensional interaction among multiple players, but this interaction is not through an independent game server system established and managed by the enterprise itself. The connectivity nature and interaction platform of this group may completely rely on other intermediary platforms or through a peer-to-peer interaction format that does not operate under a traditional server model.

4.4 Nature and characteristics of G4 video games

G4 video games are games downloaded by users via the internet but have no online interaction among multiple players and are not operated under a continuous online service model. This group typically includes offline games, games with simple content, or puzzle games designed for a single player, although the maintenance of paid ad displays and the distribution method over the network environment still place them in the category that needs to be considered for management. If the game is primarily for a single player but requires account login, stores data progression on a cloud platform, or organizes reward-receiving events, the enterprise needs to evaluate it thoroughly to avoid a misclassification situation compared to legal regulations.

5. Which games need to be approved ? Which cases are simpler ?

A safe approach to assessing the obligation of legal compliance is based on the core criteria related to the target user audience and the applied business model.

5.1 The trio of criteria for determining legal compliance obligations

To accurately determine the level of risk and the mandatory requirement for licensing, enterprises need to evaluate the product based on three focal questions. First, is the game designed to target or allow players in Vietnam to access the system? Second, does the game carry out money-collecting activities from selling in-app items, maintaining membership subscriptions, or displaying commercial advertisements? Third, does the game have continuous online elements and is it operated as a community management service, maintaining a server? Generally, when the answer is affirmative for the criteria of Vietnamese target users and money-collecting activities occur, the level of compliance risk will increase significantly, forcing the enterprise to proceed with obtaining a license.

5.2 Legal assessment for offline game products

 Certain cases may be assessed by state agencies as simpler in terms of dossier operation requirements, depending on the script content and business model. Games of a purely offline nature, operating completely without a server system and lacking an interactive community, or games with simple content and low risk regarding sensitive topics, will usually undergo a less complex review process.

5.3 Potential risk factors for games with simple content

However, businesses should note that even a game deemed very simple can still be strictly reviewed by state agencies if it integrates commercialization mechanisms directly targeting the Vietnamese user group. Furthermore, if the product content inadvertently contains sensitive elements violating moral standards, features images distorting history, or if the product receives too many complaints and negative reviews from the community leading to its inclusion in the review list, authorities have full power to apply display prevention measures and issue penalties similar to the most complex game products.

6. Detailed step-by-step game licensing process in Vietnam

 Depending on the classification of the product into groups from G1 to G4 and the server operation model, the dossier set as well as the sequence of executing administrative procedures will have distinct differences. Below is a reference process built in a practical direction to help businesses coherently visualize the steps that need to be prepared.

6.1 Step 1: Determine product classification and publishing scope

 The first and most important task is to cross-check all interactive features of the game against the classification criteria set from G1 to G4. The enterprise needs to clearly define the release plan on mobile operating system platforms, personal computer platforms, web browser versions, and determine whether to launch on international stores or domestic distribution systems. Along with that, the commercialization plan through the sale of virtual items, displaying banner ads, or issuing event participation ticket packages needs to be detailed in planning.

6.2 Step 2: Standardize content and control legal risks

 Before compiling the dossier, the enterprise must thoroughly review all sensitive content at risk of violating the law, such as elements of extreme violence, gambling mechanisms, political elements, map images violating national sovereignty, religious issues, or sexually suggestive elements. It is necessary to prepare a very coherent gameplay description, make all payment mechanisms transparent, and have a ready plan for self-classifying player ages along with warning symbols displayed on the screen if required by law.

6.3 Step 3: Prepare a legal entity or representative partner in Vietnam

In case the development studio is a legal entity headquartered abroad, specialized laws mandatorily require a corporate entity in Vietnam to stand as the name-bearer and take responsibility for publishing or take responsibility for supporting the execution of procedures. The two partnering sides need to establish an extremely clear contract mechanism, detailing the scope of publishing rights, technical operation plans, revenue sharing ratios, and distinctly delineating legal responsibilities before state agencies.

6.4 Step 4: Prepare the technical dossier and operation scheme

 The licensing request dossier usually includes basic information on the name, genre, script content, and platform providing the game. The enterprise must draft and provide documents detailing features, multiplayer interaction mechanisms, and payment mechanisms, accompanied by screenshots, short intro videos, or providing a trial installation version to serve the appraisal work. Especially for the G1 classified game group, regulations mandate that the enterprise provide extremely detailed information regarding the server system structure, user data management system, and plans for executing domestic customer care.

6.5 Step 5: Submit the dossier and monitor the appraisal process

The enterprise proceeds to submit the licensing request dossier through the correct receiving channel or format required by the competent state agency, which can be submitted via direct methods or via the online public service portal using electronic digital signature tools. During the evaluation process by the professional council, the enterprise needs to assign personnel to closely monitor all feedback and quickly supplement explanatory documents if requested by the regulatory agency to clarify technical features or scripts.

6.6 Step 6: Receive results and deploy publishing according to the approved scope

Upon officially receiving the license from the state agency, the enterprise must absolutely ensure that the actual commercial release version’s content perfectly matches the trial version approved by the appraisal council. Simultaneously, the enterprise needs to unify with the development partner on the process of implementing updates for new software versions, in-app events, and supplementary content to avoid the risk of deviating from the core content, leading to a violation of the initial legal commitments.

7. The role of legal entities and partners in Vietnam vis-a-vis foreign development studios

For international-scale game development studios, the most difficult point when approaching the market often lies not in the product programming phase but in having to clearly identify which entity will bear the name and take comprehensive legal responsibility in Vietnam.

7.1 Obligations for commercial presence and legal liability

Vietnamese authorities resolutely demand a clear legal focal point within the national territory to handle operations and execute related obligations such as organizing customer care, directly handling consumer complaints, and complying with the unconditional coordination obligation when management agencies request information investigations.

7.2 Model of Vietnamese publishers directly distributing

Commercial practices have formed prevailing collaborative models. The first model is a reputable domestic publisher directly receiving the product publishing rights. In this structure, the Vietnamese entity will have its name on all administrative licenses and proceed to govern all tasks related to publishing, marketing, and distribution.

7.3 Model of legal entrustment service combined with operation

The second model involves the foreign enterprise proceeding to sign a legal entrustment service contract combined with a minimal level of operation from the partner. The domestic partner will play a supporting role to complete administrative procedures, while the core technical governance and development orientation remain under the control of the international development studio. In agreements under this model, the contract needs to delineate extremely clearly regarding intellectual property rights, user database control rights, revenue sharing reconciliation mechanisms, and procedures for assigning responsibility for incident handling such as when payment errors arise or the product is removed from applications.

7.4 Establishing direct commercial presence in Vietnam

The third model is often applied when an international development studio wants to commit to a long-term investment strategy, which is to establish a direct commercial presence in Vietnam on its own through the process of setting up a foreign-invested enterprise to be fully autonomous in business decisions.

8. Five common mistakes leading to rejection, blocked payments, or removal from app stores

 Failures in releasing entertainment products often stem from systemic errors during compliance with specialized regulations. Below is a detailed analysis of actual mistakes that frequently occur.

8.1 Incorrectly classifying the game group from G1 to G4 right from the beginning

 The fact that enterprises incorrectly self-assess the game’s technical interaction nature leading to an incorrect group classification right from the initial stage will entail a chain of serious consequences such as preparing incorrect dossier components, applying wrong administrative procedure processes, and pointlessly prolonging the appraisal waiting time.

8.2 Sensitive content or descriptions inconsistent with the trial version

A very common violation situation is that the design description document submitted to the authorities completely does not match the actual features operating in the trial installation version. In addition, content updated into the software after it has been licensed that shifts the structure away from the initially approved limited scope is also a primary cause leading to the state agency issuing a decision to revoke the license.

8.3 Non-transparent commercialization and risks from payment flows

The currency payment flow is the most sensitive point in terms of legal management. The enterprise’s establishment of a lack of transparency in user fee collection mechanisms, ambiguity regarding discount rates, or the intentional embedding of elements easily deemed by authorities as gambling organization behavior will create extremely huge risks. Particularly, random item chest opening mechanisms without a public and transparent explanation of probability rates, if applied per the request of partners or platforms, will directly violate the strict regulations on managing virtual items and reward points under the provisions in Decree No. 147/2024/ND-CP.

8.4 Having no or weakly preparing the responsible entity in Vietnam

When the authorities begin conducting periodic inspections or when urgent explanation requests arise regarding negative feedback flows from users, the fact that the international enterprise lacks an appropriate personnel focal point in Vietnam to receive information and handle incidents will immediately turn that game into an entity providing illegal services, leading to the consequence of being required to disable network connections immediately.

8.5 Lack of a legal compliance plan after being licensed

Many businesses bear a subjective mentality after having the license in hand, subsequently arbitrarily deploying operation campaigns, updating new events, launching new items, or inserting more advertisement banners inside the game without ever building an internal censorship process beforehand. This severe shortcoming creates a very high compliance risk, easily leading to having to receive periodic penalty decisions from management agencies.

9. Expected timeframe and factors that prolong the approval time

 The actual timeframe to complete the entire procedural process depends heavily on the level of methodical preparation by the enterprise’s side.

9.1 Timeframe for resolving administrative procedures according to regulations

The progress of resolving dossiers depends strongly on which classification group the game belongs to and the complexity level of its internal interactive features. In terms of current legal regulations, for the G1 game group, the deadline for considering the issuance of a service provision license is set at twenty working days, and the deadline for the council to issue the decision approving the release content is an additional twenty working days. For game groups with simpler characteristics including G2, G3, and G4, the time for considering certificate issuance is shortened to fifteen days counting from the day the regulatory agency receives a valid dossier.

9.2 Practical factors delaying the appraisal progress

However, the cleanliness level of visual content, the detail and completeness of explanatory documents, along with the enterprise’s feedback speed in rectifying errors when the appraisal council requests supplementary modifications, are the very core factors deciding the punctuality of the procedure. In addition to that, the coordination capacity of the representative partner in Vietnam in legitimizing the dossier preparation stages also greatly impacts the total actual time needed.

9.3 Strategies to shorten preparation and approval time

To optimize the entire licensing progress, the enterprise needs to proactively standardize the entire document system right from the first planning steps, paying special attention to clarifying the description of gameplay mechanisms, online interactive features, and commercial payment cash flows. Conducting independent review assessments of content elements that are potentially sensitive prior to officially submitting the dossier and establishing a process to freeze changes to the trial installation version throughout the working period of the professional council are the most effective risk management methods to save time.

10. Frequently Asked Questions (FAQs)

Throughout the execution process of consulting and practical operation, businesses and development studios often encounter typical queries.

10.1 Does a game with only basic online features need to be licensed ?

Question: Is a video game with only a few basic online features like an achievement leaderboard and the ability to store user data on the cloud mandatorily required to proceed with licensing procedures ?

Answer: This requirement depends entirely on how the system is deployed and the degree of online interaction of the product. If the game attracts players within the territory of Vietnam to access it and generates financial revenue sources from this user group, the enterprise should conduct a thorough legal assessment to avoid misclassifying the group and bearing unexpected risks during long-term operation.

10.2 Can a foreign development organization bear its own name on the license ?

Question: Can a software development studio headquartered entirely abroad self-bear its name to submit a licensing dossier for direct publishing in Vietnam ?

Answer: The enforcement practice of legal regulations mandatorily requires a unit holding valid legal entity status in Vietnam to directly bear the name in submitting the dossier or to proceed with bilateral coordination under lawful entrustment models to ensure conformity with state management standards in the telecommunications sector.

10.3 Legal risks when publishing first and then carrying out procedures later

Question: How will the legal consequences unfold if a product has been intentionally commercially released and then later proceeds to submit a licensing request dossier for legitimization ?

 Answer: The act of going against this process brings extremely huge risks to the product’s ecosystem. The enterprise will directly face the risk of being required by the state management agency to supplement a series of stringent explanatory documents, having all interbank payment transactions blocked by monetary authorities, or being forced to immediately adjust and change the game’s source code. Therefore, the plan to proceed with legitimizing administrative procedures needs to be prioritized for early implementation and must mandatorily have a transparent roadmap of action.

10.4 Conditions for implementing new version updates after licensing

Question: After having officially received the approval license from the state, is the enterprise allowed to proceed with regular game software updates ?

 Answer: The law always allows businesses to conduct periodic software update activities to enhance the experience for end-users; however, a prerequisite is that the enterprise must self-build a truly strict internal censorship review process to ensure that any new content added to the system never exceeds the initial script scope approved by the state, avoiding the creation of any severe law violation risks. It is necessary to specially note that, if an update changes the core script for the G1 classified game group, the enterprise is mandatorily required to execute submitting a dossier requesting amendments and supplements to the publishing decision to the management agency before applying the update.

11. Conclusion: Doing it right from the beginning for sustainable publishing

The activity of perfecting the procedures for requesting a video game license in the Vietnamese market is not simply a matter of having to complete an administrative process of a compulsory formal nature. This is exactly the step of establishing a core legal foundation that helps businesses unblock a stable payment connection system, minimizing to the maximum extent the risks of the distribution platform issuing a coercive application removal decision. Only when a strictly and rigorously law-compliant mindset is established right from the very beginning can an enterprise be completely assured in long-term operations of large-scale user attraction campaigns, guaranteeing the maintenance of stable profits and constantly increasing brand value sustainably in the digital space.

This article is for informational purposes only and does not replace professional legal advice. For support tailored to your situation, please contact HMLF lawyers.

HARLEY MILLER LAW FIRM

• Email: [email protected]
• Web: hmlf.vn
• Hotline: +84937215585