Scope and subjects of inspection
On 5 May 2026, the Prime Minister signed and issued Official Dispatch 38/CĐ-TTg dated 05/05/2026 on combating intellectual property violations; a software inspection campaign at enterprises was launched by the Ministry of Culture, Sports and Tourism from 07/05/2026. This is the clearest signal yet that the Government is seriously implementing the intellectual property protection roadmap Vietnam has committed to before the international community.
Official Dispatch 38 directs ministries, sectors and localities to conduct inspections at production and business establishments that use computers. Inspection teams are inter-agency task forces comprising inspectors from the Ministry of Culture, Sports and Tourism, Economic Police, in coordination with authorised representatives of software vendors in Vietnam.
- Enterprises with 10 or more computers, regardless of headcount.
- Industries with heavy use of specialised software: architecture, construction, graphic design, accounting, retail.
- Enterprises previously warned or appearing on Microsoft, Adobe, or Autodesk watchlists.
- Private educational institutions and training centres with computer labs.
Fines under Decree 341/2025
Decree 341/2025/NĐ-CP (effective January 2026) replaces earlier regulations on administrative penalties for copyright infringement, representing a significant change from the previous regime. Fines of 10 to 500 million VND apply depending on the severity of the violation — sufficient to have a material financial impact on any enterprise.
One point many enterprises have overlooked: fines are imposed per infringing software title, not per machine in aggregate. A single computer running three cracked applications can therefore attract three separate penalties. In serious cases, commercial legal entities may face criminal liability under Article 225 of the Penal Code — with monetary fines of up to 3 billion VND.
- Fine of 10–30 million VND for individuals, doubled for organisations — fewer than 10 unauthorised copies.
- Fine of 50–100 million VND for organisations with 10 or more unauthorised copies or a commercial element.
- Confiscation of infringing material and mandatory removal of unlicensed software from all devices.
- Public disclosure of the violating enterprise's name on the competent authority's portal — a new provision with direct reputational consequences.
Warning signs that put your business at risk
Before working through the action plan, run a quick self-check against the most common risk indicators Dzo's team encounters when auditing clients:
- Software installed from unknown sources, .exe files downloaded from forums or torrents — especially Adobe, Autodesk, and Microsoft Office.
- A single Microsoft 365 or Adobe CC account used across multiple machines simultaneously.
- Number of machines exceeding the number of purchased licences, even if those licences are otherwise valid.
- No VAT invoice (hoá đơn đỏ) receipts for software purchases in the past three years.
- IT department lacks an inventory of installed software and corresponding licence counts.
7 immediate action steps for enterprises
Based on experience deploying compliance audits for more than 200 enterprises, the following is the optimal roadmap to bring your company into compliance in the shortest possible time.
Step 1 — Full software inventory: instruct IT to compile a list of all software installed on each machine, including name, version, and source. Step 2 — Cross-reference licence documentation: gather licence confirmation emails, VAT invoices, and vendor agreements. Step 3 — Identify gaps: compare the number of running applications against valid licences, noting exactly how many copies are missing for each title.
Step 4 — Prioritise high-risk software: Adobe Creative Cloud, Microsoft Office / 365, and Autodesk AutoCAD are the primary focus of inspection checklists. Step 5 — Purchase additional genuine licences with VAT invoices (hoá đơn đỏ): buy through an authorised reseller; avoid purchasing from individuals who cannot issue valid electronic VAT invoices. Step 6 — Compile a compliance dossier: consolidate the inventory report, licence documentation, records of remediated violations, and internal software policy. Step 7 — Schedule periodic audits every six months.
Conclusion: acting early is always cheaper than paying fines
The software copyright inspection campaign of 07/05–30/05/2026 under Official Dispatch 38/CĐ-TTg is not the first warning, but it is the strongest signal yet that the Government will enforce compliance rigorously this time. With fines of 10 to 500 million VND depending on the severity of the violation under Decree 341/2025 and the risk of public name disclosure, the cost of licensing properly still falls well short of the consequences of being penalised.
Enterprises that act early retain more options: phased purchases aligned with budget cycles, the right plan for their needs, and time to prepare complete documentation. Enterprises that wait until inspectors arrive will have no such options.
Sources
- Official Dispatch 38/CĐ-TTg (05/05/2026) — vanban.chinhphu.vn
- Nationwide launch to prevent and handle intellectual property violations 07/5–30/5/2026 — baochinhphu.vn
- Decree 341/2025/NĐ-CP on administrative penalties for copyright infringement — vanban.chinhphu.vn
- Article 225 of the Penal Code 2015 — Offence of infringing copyright and related rights — thuvienphapluat.vn
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