The Law on Data 2024, which was passed on November 30, 2024, will officially take effect on July 1 and specifies the establishment of a data exchange. Under the definition set out in the Law, a data exchange is a platform that provides data-related resources to support research, startups, innovation, and socio-economic development, and must ensure safety, transparency, and legal compliance while not facilitating any transactions involving national defense, security, or personal data without consent.

Vietnam’s National Data Strategy to 2030 aims to develop a data market, including piloting and testing five data exchanges to create a secure and legally-compliant environment for buying, selling, and sharing data.

Building a trusted marketplace

The national data exchange platform will enable ministries, sectors, localities, and businesses to share, buy, and sell data. According to Major Dao Dinh Nam, Deputy Director of the Center for the Research and Application of Population Data and Citizen Identification - National Population Data Center (C06) under the Ministry of Public Security, sensitive or prohibited data will be strictly regulated while lawful data from ministries, sectors, local authorities, and businesses will be verified, labeled, and permitted for transaction on the exchange.

Overall, the data exchange will serve three primary functions. First, it will facilitate data transactions, allowing the buying and selling of lawful data. Second, it will provide infrastructure and data from the National Data Center for enterprises, organizations, and individuals to develop new data products. And third, it will offer sandbox services, integrated with AI and cloud capabilities, to support businesses in developing technologies and fostering innovation.

Major Nam emphasized that data transactions will be closely managed through the exchange, similar to the stock market, to ensure security and transparency. Businesses will benefit significantly from such an exchange. Specifically, the National Data Center will support enterprises through the National Data Development Fund, offering financial, technological, data, and legal resources to develop tech products.

The sandbox system will also facilitate the testing and development of innovative solutions. Enterprises will be able to access and utilize data more easily via the data exchange and the open data portal. In addition, the Center will support scientific and technological activities, innovation, and the development of data products through registration and collaboration services.

From legality to transparency

One of the most pressing questions for many businesses is what types of data will actually be allowed for trading. According to Major Dao Duc Trieu, Deputy Head of Division 1/A05 and Secretary General of the National Data Association, any data that is not explicitly prohibited may be listed on the data exchange. In principle, there are three main conditions that determine whether data can be traded.

First, data that is not restricted by law may be eligible for transactions. However, core and critical data, which is defined under the Law on Data, will generally not be available for free trade or will be subject to strict regulatory conditions.

Second, data must be clearly traceable in terms of origin, legal status, and ownership. It cannot be illegally acquired or stolen.

Third, sensitive data, particularly personal information, cannot be freely traded. Drawing from international best practices, personal data must be anonymized or de-identified before it can be listed. Vietnam’s forthcoming Law on Personal Data Protection, now under review by the National Assembly, is expected to provide clear guidance on this matter.

There are also categories of highly-sensitive data that, if disclosed, could directly affect the interests of individuals or organizations. Such data will be strictly excluded from trading activities.

Major Nam emphasized that the design of Vietnam’s data exchange has taken into account international regulations as well as lessons learned from the successes and failures of global data marketplaces. The data trading process will function much like agricultural commerce, where products must be certified for origin and quality before entering the market. Intermediary organizations will certify the data, and the exchange operator will conduct additional reviews to ensure compliance and transparency.

To further ensure data quality, the exchange will include a preview function, allowing buyers to examine or test data samples before making purchasing decisions. AI tools will also be used to suggest data sets and provide initial quality assessments. Independent certification bodies will perform preliminary evaluations to confirm that data meets quality standards. Only after all of these checks are completed will data be allowed onto the exchange for trading, Major Nam explained.

Ms. Nguyen Thuy Duong, Chairwoman of EY Vietnam Consulting, sees that businesses today are eager for access to reliable data. Some want to buy it, others want to request or collaborate on it. A well-regulated data exchange would open the door for two-way data sharing, enriching datasets and improving their accuracy while also unlocking new commercial opportunities. However, she stressed that clear policies are essential to help stakeholders collaborate effectively, support each other, and ultimately create value, or in other words, monetize data.

Major Trieu added that in order to truly foster a thriving data economy, Vietnam needs a creative and flexible exchange that meets the practical needs of businesses, organizations, and individuals. Drawing from global experiences, he pointed out a key lesson: many data exchanges have failed due to a lack of clear data governance policies. Without such frameworks, businesses are left uncertain about what data can be shared, what can be purchased, and whether those transactions are even legally valid.

Unlocking data value

In the age of AI, data is widely regarded as “gold” or the “new oil”, and businesses are increasingly hungry for it. As Mr. Pham Anh Liem, Chief Information Officer (CIO) at the One Mount Group, put it: “There is never enough data.” Once the data exchange becomes operational, he added, “we will definitely participate, at least as buyers. We see tremendous opportunity and potential in accessing open data sources that One Mount does not currently possess.”

However, he also raised concerns about verifying the origin and legality of data. He hopes for clear guidance to ensure data privacy and security while also supporting the digital economy and unlocking the true value of data.

Mr. Hoang Long, Head of Information Technology at the Viettel Group, said data held in isolation, whether within a single business or sector, can never reach its full potential. True value emerges when data is integrated across sources, similar to the approach taken by global big tech firms. These companies build expansive product ecosystems such as YouTube, Gmail, and Google Drive, and offer most of their services for free or through premium models.

Even the free services deliver enormous business value because they generate a comprehensive data picture covering every aspect of an individual. Mr. Long affirmed that Viettel is certainly interested in both buying and selling legally permitted data, but emphasized the ongoing challenge of maximizing data value while protecting privacy.

Another concern for businesses is data pricing. While no specific regulations exist yet, pricing is expected to follow several basic principles. For public data, meaning data owned by government agencies and compiled by the National Data Center, the pricing rule is that the selling price must not be lower than the input cost, including the cost of data collection, management, and distribution.

For private-sector data, pricing will be entirely market-driven, negotiated freely between buyers and sellers. Additionally, auction models may be introduced, including both ascending-price (forward) and descending-price (reverse) formats. These auctions will be organized and agreed upon by the transacting parties. The data exchange will only provide operational services and will not interfere in the actual transactions.

The launch of the national data exchange marks a major milestone in Vietnam’s digital economy strategy. With a steadily improving legal framework, transparent operational mechanisms, and strong participation from both regulators and the business community, the data exchange is expected to become a powerful catalyst. It will help unlock the immense value of data while ensuring national security, privacy, and shared benefits.

Clarifying the rules on tradable data types, certification of data ownership, and quality assurance will be critical to the long-term success and sustainability of the model.