Ho Chi Minh City. 29 September 2026
Introduction
In addition to direct business e-commerce platforms, intermediary e-commerce platforms, social networks engaging in e-commerce, and integrated e-commerce platforms are also widely implemented in practice. Building on the previous parts, Weekly Debrief – Part 3 focuses on analyzing noteworthy legal regulations concerning the obligations and responsibilities of businesses operating these platforms and provides practical recommendations for regulatory compliance.
Registration Obligation
Unlike direct business e-commerce platforms with online ordering functions, intermediary e-commerce platforms, social networks engaging in e-commerce, and integrated e-commerce platforms must register with and obtain confirmation from the Ministry of Industry and Trade. Businesses should therefore review and correctly classify the relevant platforms to fulfil the applicable registration or notification requirements. Please note that e-commerce platforms with confirmed notification or registration before 01 July 2026 may continue to operate until 30 June 2027, but must carry out procedures to amend or supplement their confirmed application dossiers in accordance with current regulations.
Upon approval, the operators will receive the following electronic registration symbol to be displayed on the platform:
Key Legal Responsibilities
Depending on their nature and operating models, different types of e-commerce platforms are subject to distinct legal responsibilities. These primarily concern seller identity verification, consumer protection towards defective goods, dispute handling and settlement, and cooperation with competent authorities. The following highlights several key legal responsibilities that businesses should consider when operating the relevant platforms.
Intermediary e-commerce platforms
Electronic verification of seller identities from 01 January 2027, including those of domestic or foreign individuals and organisations, is one of the key responsibilities of intermediary e-commerce platform operators. Fulfilling this obligation enables operators to provide necessary information to transaction participants and competent authorities in the event of disputes or detected legal violations.
Before displaying goods or services on the platform, the operators are responsible for reviewing the relevant information. For platforms offering online ordering functions, the operators are also required to accept returns of goods provided by sellers if such goods do not conform to the information previously announced, listed, advertised, or presented. Where defective goods are identified, the operators must publish a recall notice on the platform, notify buyers directly and act as the point of contact for receiving returned goods as agreed with the seller.
It is also worth noting that the operators must always ensure that information and data in relation to goods and services posted on the platform remain accessible. For platforms offering online ordering functions, the operators must also provide tools allowing sellers to access their accounts and download data in relation to goods and services, as well as the details of concluded contracts.
Social networks engaging in e-commerce
By its nature, this type of platform must first comply with the legal requirements applicable to social networks. Given its involvement in e-commerce activities, the platform operators are also subject to additional obligations and responsibilities under applicable e-commerce regulations.
Accordingly, the operators must allow users the option to register for a seller account and publicly display an identifier for such accounts. This identifier must be clearly visible, easily recognizable, and distinguishable enough to avoid confusion with others.
Apart from general legal responsibilities, the operators of social networks engaging in e-commerce that feature an online communication function integrated with a notification tool for confirming contract conclusion must establish a mechanism for storing data in relation to concluded contracts and require users to use their seller account information when using this function. If the platform includes an online ordering function, the operators must separate the e-commerce content associated with this function into a dedicated section and require users to use their seller account information when using that function.
Integrated e-commerce platforms
Given their ability to incorporate other e-commerce platforms, the operators of integrated e-commerce platforms must ensure that no platforms violating the applicable law are integrated. To fulfil this obligation, the operators must connect to and regularly update the list on the E-commerce Management System to promptly identify and remove platforms that fail to comply with legal requirements.
In order to ensure transparency and protect user rights, the operators must provide full information regarding the names of embedded platforms, the rights and obligations of the parties involved, and dispute settlement procedures. Additionally, the operators must establish a mechanism allowing users to provide their consent before each access to an embedded platform. Notably, consent must be obtained separately for each instance of access. As such, mechanisms relying on default consent or one-time consent for subsequent visits may be deemed non-compliant with this requirement.
In addition, the operators must develop tools enabling embedded platforms to access and utilize the generated data. Information and data exchanged between the integrated and embedded e-commerce platforms must be stored for a minimum period of three years.
Periodic Reporting Obligation
Similar to direct business e-commerce platforms, before February 15 of each year, the operators must report their e-commerce activities online via the E-commerce Management System or provide information as requested by the competent authorities.
Conclusion
Based on current regulations, the new legal framework imposes a range of compliance obligations on the operators of intermediary e-commerce platforms, social networks engaging in e-commerce, and integrated e-commerce platforms, including several notable new requirements. Accordingly, businesses need to proactively review their operating models, update operational procedures, and implement necessary measures to ensure full compliance with the relevant legal obligations as analyzed above.
In the final part, Weekly Debrief – Part 4 will focus on analyzing notable legal changes affecting the e-commerce activities of foreign entities, thereby concluding the series on legal updates in this sector.
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See the previous part here: Part 1a| Part 1b
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If you would like to discuss how the new e-commerce regulations may affect your business or require tailored advice, please contact our team.
info@indochinecounsel.com
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