Registration Procedure Guide: Intermediate e-commerce platform, social network operating in e-commerce, integrated e-commerce platform

Pursuant to the regulations set forth in Decree 248/2026/ND-CP:

Regulated Entities: Enterprises or organizations owning intermediary e-commerce platforms (e.g., Shopee, Lazada, classified advertisement websites), social networks integrated with transaction or store creation features, and integrated e-commerce platforms. (Note: Individuals lacking business registration are ineligible).
Core Requirements: Submission of an Operational Plan (Form 05) satisfying current technical standards (including e-KYC for sellers and live-streamers, removal of infringing information within 24 hours, data retention for one year, and compliance with personal data protection laws and regulations) and fulfillment of market access conditions applicable to Foreign Direct Investment (FDI).
Competent Authority & Processing Timeframe: The Ministry of Industry and Trade (Department of E-commerce and Digital Economy) shall review the application dossier within seven (07) working days via the National Public Service Portal. (Note: Requests for amendments shall result in automatic cancellation of the application after sixty (60) days if the enterprise fails to provide a response).

The proliferation of hybrid business models, ranging from traditional marketplaces and social networks integrated with shopping cart features to super-app ecosystems, necessitates stricter legal oversight by competent authorities. Developing a comprehensive operational plan and completing the registration process for e-commerce platforms with the Ministry of Industry and Trade (MOIT) constitute mandatory obligations for enterprises to ensure lawful operation.

To assist businesses in complying with e-commerce regulations, CDLAF Law Firm provides detailed guidance on the latest procedures for registering a new intermediary e-commerce platform below.

Table of contents:

1. Applicable Entities and Scope of Application

Eligible entities include merchants (enterprises, household businesses) or organizations legally established under the laws of Vietnam. (Note: Individuals operating without business registration are not entitled to register for this type of service).

This procedure applies where an enterprise or organization establishes a website or mobile application providing at least one of the following services to third parties (other sellers) participating in commercial activities:

E-commerce Marketplace: A platform facilitating third parties to post, promoting, and selling goods or services (e.g., models similar to Shopee, Lazada, or classified advertisement websites).
Social Networks Operating as E-commerce Platforms: Forums and social media networks offering features that enable users to create online stores, verify seller identities, or execute online transactions.
Integrated E-commerce Platforms: Technology systems that integrate multiple intermediary functions, such as commerce, payment processing, or logistics, to connect relevant stakeholders.

2. Conditions for Implementation

In order for the Ministry of Industry and Trade to approve the registration, enterprises must satisfy the following four (04) conditions:

Legal Capacity: Possession of a valid business license (for enterprises, household businesses, or organizations) with the appropriate industry code (e.g., 4791 – Retail sales via mail order houses or via Internet).
Operational Plan: A clearly defined plan delineating the business model, operational mechanisms, logistics, and the respective rights and responsibilities of all participating parties.
Internal Regulations & Public Disclosure: The platform must publicly display operational regulations, transaction terms, privacy policies, dispute resolution mechanisms, and pricing schedules (requiring a twenty (20) days advance notice for any price adjustments).
Foreign Capital Conditions: In the presence of foreign investment, the entity must comply with statutory market access and national security requirements as mandated by Decree 248/2026/ND-CP.

3. Procedural Steps

Step 1. Log in to the National Public Service Portal, complete the required online declaration form, and submit the accompanying documentation (if any) as prescribed.

Step 2. Within seven (07) working days from the receipt of a complete and valid dossier, the platform owner shall receive one of the following official responses:

Registration Confirmation: The platform’s information shall be publicly listed in the Registry of E-commerce Platforms on the E-commerce Management System integrated with the National Public Service Portal. Concurrently, the platform owner shall be issued an electronic registration confirmation icon to be displayed on the platform; upon clicking this icon, users shall be redirected to the official information published on the E-commerce Management System.
Request for Clarification/Amendment: The platform owner shall be required to repeat Step 1. Should the platform owner fail to respond or submit incomplete/invalid information within sixty (60) days from the initial request for clarification, the application dossier shall be automatically terminated.

4. Required Documents to Be Prepared

Enterprises must prepare a comprehensive dossier comprising the following documents:

An Information Declaration Form compliant with Form No. 02, Appendix II of Decree 248/2026/ND-CP;
Certified copies of licenses, certificates, confirmations, or approvals issued by competent authorities, or equivalent documents for goods and services falling under the List of conditional business investment sectors as prescribed by investment laws.
If such documents are already available as legally valid electronic data accessible via interconnection and sharing among the Administrative Procedure Resolution Information System, national databases, specialized databases, and the National Public Service Portal, resubmission is not required;
An E-commerce Project Proposal complying with Article 30 of Decree 248/2026/ND-CP.
This proposal must clearly articulate the managing entity, the connection model, and the product classification.
Technically, the proposal must stipulate solutions for e-KYC (electronic authentication) for sellers and live-streamers, a mechanism for the expeditious removal of infringing content within 24 hours, a diagram of the payment security infrastructure, and a formal commitment to retain transaction data for a minimum of one (01) year.
The enterprise must establish definitive procedures for receiving online complaints and a framework detailing responsibilities for compliance with personal data protection laws.
The proposal shall be drafted according to Form No. 05, Appendix II of Decree 248/2026/ND-CP;
Regulations governing live-streaming sales activities, provided the platform incorporates live-streaming services;
A standard contract or agreement template executed between the seller and the platform owner.

5. Legal Recommendations from CDLAF Law Firm

The registration of an intermediary e-commerce platform entails a rigorous appraisal process encompassing both legal validity and the technical functionality of the website. Consequently, enterprises should exercise utmost diligence regarding the following three (03) critical aspects upon submission of the dossier:

Technical Project Proposal (Form 05): In the current era of digitalization and stringent policies enforcing alignment between the proposed project and actual operations, competent authorities scrutinize the rationale of the e-commerce website project proposal with extreme rigor. Essential components such as cybersecurity, personal data protection, electronic contracting, cash flow management, authentication protocols, and risk mitigation strategies are subject to particular scrutiny.
60-Day Deadline Limitation: The application shall be subject to automatic termination within the system should the enterprise fail to implement the requisite supplements or amendments within sixty (60) days upon the request of the Ministry of Industry and Trade.
Synchronization with Personal Data Protection (PDP) Regulations: Platform regulations and vendor agreements must comprehensively incorporate provisions on data security and processing in strict adherence to current legal frameworks. Notably, information concerning personal data processing publicized on the platform must be fully consistent with the enterprise’s overarching personal data protection policy.

CDLAF’s Legal Consulting Services for E-commerce Platform Registration

CDLAF Law Firm partners with enterprises to optimize resources and ensure absolute legal compliance through the following services:

Appraising the operational model and assessing foreign investment (FDI) capital conditions.
Standardizing the Operational Plan (Form 05) in accordance with the technical criteria mandated by the Ministry of Industry and Trade.
Drafting comprehensive Operational Regulations, Standard Contracts, and Personal Data Protection (PDP) Policies.
Acting as the authorized representative to submit the dossier, provide necessary explanations, and obtain the official registration confirmation from the Ministry of Industry and Trade.

📩 BOOK A CONSULTATION WITH CDLAF’S LEGAL TEAM

Do not let procedural errors disrupt your business plans. Contact CDLAF today to receive a preliminary risk assessment from our team of Lawyers and E-commerce Legal Experts:

Hotline/Zalo: [+84 909 668 216]

Email: info@cdlaf.vn

Why choose CDLAF’s service?

We provide effective and comprehensive legal solutions that help you save money and maintain compliance in your business;
We continue to monitor your legal matters even after the service is completed and update you when there are any changes in the Vietnamese legal system;
Our system of forms and processes related to labor and personnel is continuously built and updated and will be provided as soon as the customer requests it;
As a Vietnamese law firm, we have a thorough understanding of Vietnam’s legal regulations, and grasp the psychology of employees, employers, and working methods at competent authorities;
CDLAF’s team of lawyers has many years of experience in the field of labor and enterprises, as well as human resources and financial advisory.
Strict information security procedures throughout the service performance and even after the service is completed.

You can refer for more information:

Guidance on Amending the Registration of a Foreign Direct E-commerce Platform

Guidance on registration procedures for foreign direct business e-commerce platforms doing business in Vietnam

Guidelines on Amending and Updating the Registration of E-commerce Platforms and Social Commerce Networks under the Latest Regulations

Latest Guidelines on the Procedures for Withdrawing the Security Deposit for Foreign E-commerce Platforms

Latest Guide to the Notification Procedure for E-commerce Platforms Engaged in Direct Online Sales

Procedure for Issuance of the License to Provide Electronic Contract Authentication Services in Commerce