VietnamLaw on Artificial Intelligence, transparency obligation
Law No. 134/2025/QH15, art. 11
In force since .
An AI transparency rule binding public and private bodies.
- How the hook was established
- express
- What makes it apply
- Place of effect
- Obligation class
- Content labelling, Disclosure
- Audit expectation
- none
- Setting the rule reaches
- General
What it requires
- Design an AI system that interacts directly with users so that users can recognise they are interacting with an AI system, unless the law provides otherwise.
- Mark AI-generated audio, image, and video content in a machine-readable format under the Government's regulations.
- Notify the public clearly when providing AI-generated or AI-edited text, audio, images, or video that could cause confusion about the authenticity of an event or a person.
- Attach an easily recognisable label to AI-generated or AI-edited content that simulates or replicates a real person's appearance or voice, or recreates a real event.
These lines are LexLint's reading of the law's text.
In the frameworks
- NIST AI RMF
- MEASURE 2.8Risks associated with transparency and accountability – as identified in the MAP function – are examined and documented.
- NIST AI 600-1
- GAI-RISK-07Human-AI Configuration
- GAI-RISK-08Information Integrity
- OWASP Agentic Top 10
- ASI09Human-Agent Trust Exploitation
- MIT mitigations Draft
- FINOS AIGF
- AIR-DET-021Agent Decision Audit and Explainability
- ETSI EN 304 223
Our reading of where this law's duties sit in each framework. It never says that running a control meets the law. How we read a framework against the law
Identifiers refer to ETSI EN 304 223 V2.1.1 (2025-12), © ETSI 2025, all rights reserved. ETSI owns the standard; no ETSI text (titles or sentences) is reproduced here. The standard is free to download from ETSI.
What it makes you log
Logging duty
Article 11 requires a provider to design systems so users can recognise they are interacting with AI, to mark generated audio, image and video in a machine-readable format, to notify the public when generated or edited content could cause confusion about authenticity, to label content that simulates a real person or recreates a real event, and to keep that transparency information current throughout the system's or content's life. None of the six paragraphs names a log, record, event recording or audit trail, and paragraph 5's duty to keep information current is about keeping the label or notice itself up to date, not about retaining a record of having given it.
- Kind
- None
- As of
What this law does
Article 11 requires a provider to design and operate an AI system that interacts directly with humans so that a user can recognise they are interacting with such a system, unless the law provides otherwise, and to mark AI-generated audio, image, and video content in a machine-readable format under forthcoming Government regulations.
A deployer must clearly notify the public when providing AI-generated or AI-edited text, audio, images, or video that could cause confusion about the authenticity of an event or a person, and must attach an easily recognisable label to AI-generated or AI-edited content that simulates or replicates a real person's appearance or voice or recreates a real event, with a lighter labeling standard for cinematographic, artistic, or creative works so the label does not obstruct enjoyment of the work.
Both providers and deployers must keep this transparency information current throughout the life of the system, product, or content.
When LexLint raises it
When your app profile says your app deploys a chatbot, generates audio with AI, generates content with AI, generates images with AI, generates text with AI, generates video with AI or processes biometric data.
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