The 2024 Data Law (Luật Dữ liệu) created the National Aggregated Database (Cơ sở dữ liệu tổng hợp quốc gia), a central store that pulls together data from national and sector databases. The law also said that outside users would pay to query it. Until now nobody knew the price. A four-page circular from the Ministry of Finance sets it, and the fee applies from 1 November 2026, ten days from now.
The document
- Number: Thông tư 156/2026/TT-BTC
- Issued by: Ministry of Finance (Bộ Tài chính); signed by Deputy Minister Cao Anh Tuấn
- Signed: 20 October 2026
- Effective: 1 November 2026
- Full title: Quy định mức thu, giảm, chế độ thu, nộp phí khai thác và sử dụng thông tin trong Cơ sở dữ liệu tổng hợp quốc gia (fee rates, reductions and the collection and payment of the fee for accessing and using information in the National Aggregated Database)
Its legal bases include the Law on Fees and Charges (97/2015/QH13), the Data Law (60/2024/QH15), the Law on Electronic Transactions (20/2023/QH15), Nghị định 165/2025/NĐ-CP, which implements the Data Law, and Nghị định 278/2025/NĐ-CP on mandatory data sharing between agencies of the political system.
Who pays, and who doesn’t
Article 38 of the Data Law already divides users into three groups:
- Party and State bodies, the Vietnam Fatherland Front and socio-political organisations use the database free of charge.
- Organisations and individuals accessing their own data pay nothing.
- Everyone else pays under the fee law.
The circular deals only with the third group. It names the National Data Center (Trung tâm Dữ liệu quốc gia) as the collecting body. Anyone who requests and uses information from the database pays the fee, except in cases where the data or electronic-transaction laws say no fee is due.
Article 35 of the Data Law also says who in that third group can get data at all. Open data is free to use. Personal data requires consent from both the National Data Center and the data subject. Other data requires the Center’s consent. The fee is the price of access once permission has been granted. It does not grant access by itself.
The rates
| Period | Fee per data field |
|---|---|
| 1 November 2026 – 31 December 2028 | 300 đồng |
| From 1 January 2029 | 600 đồng |
The fee is charged per data field (trường dữ liệu), not per request or per record. A query that returns a person’s name, date of birth and address counts as three fields. The Ministry of Finance used the same per-field model in 2022 for the National Population Database, under Thông tư 48/2022/TT-BTC.
The circular does not explain the 600-đồng figure, but the August 2026 draft did. LSVN reported that the ministry estimated average annual operating costs of 2,884.6 billion đồng and about 4.8 billion chargeable fields a year in its 2026 baseline scenario. That works out to 600.95 đồng per field, rounded down to 600. The 300-đồng rate to the end of 2028 is a half-price introductory period. The draft gave this reason: a fixed end date is easier to monitor than a rolling “first three years”.
Reductions for individuals
Individuals pay 50% less if they fall into any of these groups:
- children;
- members of poor households;
- elderly people;
- people with disabilities;
- people with meritorious service to the revolution (người có công với cách mạng);
- ethnic minority people living in communes with especially difficult socio-economic conditions.
The reductions do not stack. Someone in two or more groups still gets only 50% off. In practice these individuals pay 150 đồng per field until the end of 2028 and 300 đồng from 2029.
Compared with the draft: the rates themselves did not change, but the final text adds two groups. The August draft covered only the elderly, people with disabilities, people with meritorious service and ethnic minorities in disadvantaged areas. Children and members of poor households were added before signing. The draft wrote the transitional reduction as “25% of the 600-đồng rate”, which is also 150 đồng. The final text gets the same result in simpler terms.
Payment and refunds
Fees are paid into the state budget using the methods in Nghị định 362/2025/NĐ-CP. The National Data Center passes on 100% of what it collects, including any interest earned. Its operating costs are funded from the budget, not from the fee.
The circular also includes a refund rule. If a payer receives none or only part of the data they paid for, or is charged twice or overcharged, the National Data Center must reconcile the payment and refund the difference under tax-administration law.
What it means in practice
- Businesses that verify customers, such as banks, fintechs, insurers, telcos, notaries and e-commerce platforms, should identify which of their lookups go to the aggregated database rather than the population database. They should then estimate how many fields each lookup returns and budget for it. At 300 đồng a field, a lookup of 20 fields costs 6,000 đồng. The price doubles in 2029.
- Ask for fewer fields. Because the fee is charged per field, requesting only the fields you need is now cheaper as well as better data-protection practice under the Personal Data Protection Law.
- Individuals checking their own records pay nothing under Article 38(2) of the Data Law. That exemption comes from the law, not from this circular.
- Agencies are not affected. State-to-state sharing remains free.
Open questions
- What counts as a field? The circular does not define trường dữ liệu. It also does not say how fields are counted for statistical extracts, bulk API connections or responses that come back empty.
- Overlap with the population database fee. Some data is held in both the population database and the aggregated database. The circular does not say which fee applies when the same data could come from either.
- Rounding. The circular sets no minimum charge and does not say how small automated lookups will be billed. The National Data Center’s guidance will decide this.
Sources
- Thông tư 156/2026/TT-BTC — signed text (Ministry of Finance / VPCP, PDF)
- Government legal documents portal — list of new documents
- LSVN — Draft fee for accessing the National Aggregated Database (August 2026)
- LSVN — How the National Aggregated Database is accessed under Nghị định 165/2025
- Luật Dữ liệu 2024 — Điều 35 (access and use)
- Luật Dữ liệu 2024 — Điều 38 (fees)
- LSVN — Thông tư 48/2022/TT-BTC on population database fees
This post is general information, not legal advice.