AIC has submitted comments to the Ministry of Public Security (“MOPS”) for the public consultation on the Draft Decree Guiding the Implementation of Law on Cybersecurity (“LOCS”). While, AIC commends MOPS and the Government of Vietnam for their efforts to implement cybersecurity measures and develop a legal framework for cyber and information security, the draft decree has led to industry concerns, particularly on the data localization requirements. Such requirements will stifle investment in Vietnam’s digital economy and prove harmful to Vietnam’s long-term economic growth. This will not only hurt international players but will also impact Vietnamese small businesses if they are faced with similar data localization measures as in other countries as they seek to expand. The requirement on the establishment of a branch or representative office in Vietnam ignores the benefits of global business models, as legitimate cyber security concerns can be addressed without the imposition of localization requirements. This requirement will also create undue burden for foreign businesses which are located in Vietnam.