DFDL Vietnam: Proposed Changes to Administrative Penalties for Competition Violations and First Fine for Non-Notification

M&A activities in Vietnam have been vibrant, with the number of economic concentration notification dossiers submitted to the Vietnam Competition Commission (“VCC”) steadily increasing over the years: from 63 dossiers in 2020, to 130 dossiers in 2021, and to 197 dossiers in 2024. This trend reflects the consistent growth of the national economy, while also indicating the increasing attention and compliance of foreign and domestic enterprises with Vietnam’s competition regulations.

In September 2019, the Government of Vietnam issued Decree No. 75/2019/ND-CP on administrative penalties for competition violations (“Decree 75”). After five years of implementation, the Government has identified a number of issues which it seeks to address in the draft decree amending Decree 75 (“Draft Amending Decree”) released on 29 July 2025 for public consultation by the Ministry of Industry and Trade (“MOIT”).

The MOIT has been collecting and addressing feedback on the Draft Amending Decree since its initial release culminating with the most recent revision issued on 12 September 2025. We understand that the Draft Amending Decree is expected to be submitted to the Government for consideration in November 2025.

 

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