Regulations on Dossier Requesting Testing of Digital Technology Application Products and Services

Regulations on dossier requesting testing of digital technology application products and services are important content aimed at creating a legal corridor for deploying new technology models and solutions in the practice of enterprises in Vietnam. Preparing an accurate dossier determines the possibility of being granted a pilot implementation license. The following content by Long Phan Consulting Company will clarify the regulations on dossier requesting testing of digital technology application products and services.

The goal of testing products and services that utilize digital technology

According to Article 13 of Decree 353/2025/ND-CP, the objectives include:

• Exemption: Organizations and enterprises participating in testing are exempt from complying with certain legal regulations for a limited time, space, and scope.
• Innovation: Encourage innovation and promote the “smartization” of industries and fields.
• Evaluation: Create a testing environment to evaluate features, risks, costs, and benefits of new products and services.
• Risk Control: Control and limit potential risks when applying new products and services.
• Legal Adjustment: Testing results serve as a basis for state agencies to review and evaluate potential risks before deciding to adjust relevant legal regulations to put new products and services into use and provide them to the market.

>>>See more: When does the exemption from inspection and supervision of food testing facilities occur?

What are the conditions and criteria for digital technology products and services in controlled trials?

Based on Article 15 of Decree 353/2025/ND-CP, the conditions and criteria include:

1. Nature: Must be a product/service applying digital technology, formed through convergence, integration, or combination of digital technologies with each other or with products/services of other industries.
2. Legal Gap: The use of this product/service is unregulated by law or differs from current legal regulations, leading to the inability to deploy.
3. Risk Management: The proposing organization/enterprise has built a plan for managing, remedying risks, and protecting the interests of participants and related parties during testing.
4. Innovation Value: The use of this product/service has innovative nature, is capable of bringing benefits, added value, and promoting technology development.

What documents are required for a product or service trial using digital technology?

According to Article 24 of Decree 353/2025/ND-CP, the dossier includes:

1. Application Form: Request to participate in controlled testing (Form TNCN S01 in the Appendix of the Decree).
2. Testing Plan: Including time, space, scope, subjects of testing, and other related information.
3. Impact Assessment Report: Assessing impacts on testing participants and related organizations/individuals.
4. Value Assessment Report: Assessing benefits, novelty, new value, innovation, and commercialization potential.
5. Safety Plan: Ensuring safety for assets, health, life, legal rights/interests; ensuring cybersecurity; risk control measures; complaint resolution mechanisms; compensation scope/measures; and remedial plans according to civil law.
6. Technical Plan: Technical characteristics, parameters, standards, quality, technical solutions, maintenance plans, etc.

Procedure for reviewing applications to participate in trials of digital technology products and services

According to Article 25 of Decree 353/2025/ND-CP, the sequence includes:

Step 1: Submission The organization/enterprise submits 01 set of dossiers (by post, direct submission, or online via National Public Service Portal) to the competent licensing authority (defined in Article 16).

Step 2: Receipt Confirmation & Supplementation Request

• Within 05 working days of receipt: The authority confirms receipt of a valid dossier in writing.
• If invalid/incomplete: The authority requests supplementation in writing.
• If not supplemented within 15 days of request: The authority returns the dossier.

Step 3: Appraisal

• Within 60 days of receiving a valid dossier: The authority coordinates with related agencies to complete the appraisal (including field inspection if necessary).
• Clarification: If clarification is needed, the authority requests it in writing. The applicant must explain within 15 days; otherwise, the dossier is returned.

Step 4: Licensing Decision

• After appraisal, the authority issues the Decision on Licensing Controlled Testing (Form TNCN 02).
• If refused, a written reply stating the reason is issued.

Step 5: Implementation

• Within 90 days of licensing, the enterprise must conduct testing (unless force majeure/objective obstacles approved by the authority).
• Failure to conduct testing results in a Decision to End Testing Ahead of Schedule (Form TNCN 07).

The competent authority grants licenses for testing products and services using digital technology

According to Article 16 of Decree 353/2025/ND-CP:

• Provincial People’s Committee: For testing limited to one or several areas/localities within its management scope.
• Ministries/Ministerial-level Agencies/Ministry of National Defense: For testing limited to areas/localities belonging to 02 or more provinces within their management sector.
• Prime Minister: Decides in cases of difficulty regarding licensing authority.
• Data Products/Services: Licensing authority follows the law on data.

>>>See more: Authority to License Digital Technology Testing

Long Phan Consulting Company provides consulting services on applications for testing digital technology products and services

Long Phan Consulting Company provides comprehensive legal solutions for businesses to carry out procedures for obtaining technology testing permits. With our team of experienced legal experts, we will assist our clients in:

• Providing advice on meeting the criteria for testing products and services using digital technology.
• Consulting regulations on dossier requesting testing of digital technology application products and services
• Assisting in conducting product condition reviews and developing technical documentation.
• Consulting support helps minimize the risk of application rejection due to missing technical information.
• Support in developing risk management and intellectual property protection strategies during controlled testing.
• We represent our clients in working directly with the relevant regulatory authorities.

By choosing Long Phan Consulting Company, you will receive ongoing support from the preparation stage to the completion of the trial process. We are committed to delivering practical value by handling complex legal situations professionally and effectively.

Frequently Asked Questions about regulations on dossier requesting testing of digital technology application products and services

Below, Long Phan Consulting Company provides some frequently asked questions related to regulations on dossier requesting testing of digital technology application products and services. We invite interested clients to refer to them:

Who are the stakeholders involved in the mechanism for testing products and services using digital technology?

According to Article 14 of Decree 353/2025/ND-CP, the entities involved in the mechanism for testing products and services using digital technology include:

• Organizations and businesses are licensed to conduct controlled testing.
• The competent authority grants permission for controlled testing.
• Organizations and individuals participate in controlled trials.
• Other organizations and individuals involved in controlled testing.

What are the principles for approving organizations and businesses to participate in testing products and services using digital technology?

According to Article 17 of Decree 353/2025/ND-CP, the principles for approving organizations and businesses to participate in the trial are as follows:

• Ensuring the principles of voluntariness and equality among organizations and businesses in participating in and exercising rights and obligations during the testing process.
• Ensure openness and transparency regarding the criteria, conditions, and procedures for evaluating and selecting organizations and businesses to participate in the pilot program.

What are the regulations regarding the testing period for products and services using digital technology?

According to Clause 1, Article 18 of Decree 353/2025/ND-CP, the testing period for digital technology application products and services is determined by the competent authority granting the testing license based on the actual situation, but not exceeding 3 years from the date of license issuance. The maximum extension period for testing is 3 years from the date the competent authority grants the extension, and it can only be extended once.

After the testing period ends, what will happen to the product?

According to Article 32 of Decree 353/2025/ND-CP:

• Upon completion of the trial within the timeframe stipulated in Clause 1, Article 20 of Decree 353/2025/ND-CP, or upon completion of the trial ahead of schedule in the cases specified in points a and b, Clause 2, Article 20 of Decree 353/2025/ND-CP, the organization or enterprise granted the trial license shall submit a request dossier to the competent authority for consideration and decision on certifying the completion of the trial in accordance with Articles 28 and 29 of Decree 353/2025/ND-CP.
• The competent authority for licensing testing shall issue a Decision certifying the completion of controlled testing of digital technology application products and services as prescribed in Articles 28 and 29 of Decree 353/2025/ND-CP.

What are the regulations regarding the scope and subjects of testing for products and services utilizing digital technology?

According to Clause 3, Article 18 of Decree 353/2025/ND-CP, the scope and subjects of testing are defined as follows: organizations and enterprises licensed to conduct testing are only permitted to provide tested products and services within the scope and subjects specified in the testing license decision.

Conclusion

Mastering the regulations on dossier requesting testing of digital technology application products and services helps businesses be proactive in their innovation roadmap. Clients need to ensure the accuracy and transparency of all documents.

Let Long Phan Consulting Company support you in performing these complex legal procedures professionally. Contact Hotline 1900636389 immediately.