Every Water Plant Gets a Code, No Household Gets Profiled: The National Water Supply and Drainage Database Takes Effect

For two years Việt Nam’s water utilities have been feeding a trial database run by the Ministry of Construction under an internal interim regulation. From today that trial has the force of law. Thông tư 69/2026/TT-BXD takes effect on 1 November 2026, and with it every water plant, intake, pump station, wastewater treatment works and sludge facility in the country becomes a numbered object in a single national information system, governed by the Data Law rather than by a ministry memo. Four days before the deadline the ministry also issued the data dictionary that tells utilities exactly what each field must be called and how it must be formatted.

What the document is

The full title is Thông tư quy định về Hệ thống thông tin, Cơ sở dữ liệu cấp nước sạch và thoát nước đô thị, a circular on the information system and database for clean water supply and urban drainage. Thứ trưởng Bộ Xây dựng Nguyễn Tường Văn signed it on behalf of the Minister on 15 September 2026, at the proposal of the head of Cục Kết cấu hạ tầng xây dựng (the Department of Construction Infrastructure). The Government Office posted the signed text on 24 September, and Báo Chính phủ reported it the next day. The circular has 5 chapters, 28 articles and four annexes, and runs to 82 pages. Điều 28 sets the effective date at 1 November 2026.

Its legal basis is the full 2025 data stack: Luật Dữ liệu 60/2024/QH15, Luật Giao dịch điện tử 20/2023/QH15, Luật Bảo vệ dữ liệu cá nhân 91/2025/QH15, Luật An ninh mạng 116/2025/QH15 and Luật Bảo vệ bí mật nhà nước 117/2025/QH15, plus the decrees that implement them: Nghị định 165/2025/NĐ-CP (Data Law), 194/2025/NĐ-CP (national databases and open data), 278/2025/NĐ-CP (mandatory data sharing), 326/2026/NĐ-CP (location identification), 331/2026/NĐ-CP and 333/2026/NĐ-CP (cybersecurity of information systems). The water-sector base remains the old pair of decrees, Nghị định 117/2007/NĐ-CP on clean water and Nghị định 80/2014/NĐ-CP on drainage and wastewater.

What it replaces

Before this circular there was no legal instrument at all. The ministry’s own explanatory note, issued by Cục Kết cấu hạ tầng xây dựng on 5 August 2026, says the database had been piloted in all 34 provinces and centrally run cities under a Quy chế tạm thời, an interim internal regulation that could not bind provincial governments, utilities or other ministries. The pilot showed the model worked but that completeness and quality varied widely between localities, that update and verification procedures were inconsistent, and that the trial dataset did not yet cover planning information, raw water, service areas, capacity, network development, stormwater, flooding or sludge. The note also states that the circular creates no new administrative procedure, business condition, fee or financial obligation.

The circular contains no repeal clause, because there was nothing of equal rank to repeal. Instead Điều 27 lets data created under the pilot continue in use with its source, status and quality level attached, and gives the agencies holding it 24 months to reconcile, link and standardise it.

Eleven data groups and a permanent code for every asset

Điều 5 organises the database into eleven groups: administrative and organisational data (utilities, service areas, population, connections); approved water and drainage planning, which is reference data only and does not replace the approved planning file; the water supply chain from source to distribution network; drinking water quality, service quality, incidents, complaints, tariffs and online monitoring; drainage asset owners, operators, contracts and service prices; centralised and decentralised wastewater collection and treatment; stormwater, retention works, flooding points and dredging; sludge; the electronic documents behind the data; aggregate indicators; and shared catalogues, master data and metadata.

Điều 8 is the structural heart of the text. Every core object must receive a mã định danh chuyên ngành (sector identifier) the first time it is created in the system: water supply and drainage companies, water plants, intakes, raw-water and booster pump stations, clean-water reservoirs and towers, wastewater plants and stations, decentralised treatment works, wastewater and stormwater pump stations, retention works, outfalls, sludge facilities and stand-alone online monitoring stations. The code is permanent. It survives a change of name, owner, administrative boundary or operating status, and it is never reused; when an asset is merged, split or decommissioned the code is kept as history and linked to its successor. For companies the system records the enterprise or tax code alongside.

Crucially, the sector code does not replace the 12-digit mã định danh địa điểm that every physical place receives under Nghị định 326/2026/NĐ-CP, which this blog covered when it took effect on 1 September. Phụ lục III requires the two codes, together with organisation codes, administrative unit codes and source-system codes, to be stored in separate fields that may not be substituted for one another. The water system only requests, receives and stores location IDs from the national location database; it may not mint its own or guess at their structure.

Collect once, feed automatically, no re-typing

Điều 4 states the design principles in the language of the national data framework: data is created once at source and reused many times; feeds from national and sector databases take priority; and automatic updates from operational systems, meters, sensors and monitoring systems are preferred over manual entry. Điều 12 lists four input methods: online forms, API or data-platform synchronisation, batch packages, and direct ingestion from measuring devices and SCADA systems after the operator has verified, calibrated and authenticated them. If a connection drops, the system must buffer and back-fill, and manual entries made in the meantime must carry a warning flag.

Two clauses protect utilities from duplicate work. Điều 14 and Điều 20 say that where data is already lawfully shared by a source system, no utility may be told to install an additional transmitter or to send the same data a second time. And Điều 6 says fields that depend on equipment, such as online readings of pH, turbidity and residual chlorine, only have to be filled where that equipment has been installed or is required by law or an approved project.

Deadlines that start today

Điều 16 fixes the clock. Monthly data must be successfully posted within 10 working days of month end, quarterly data within 15 working days and annual data within 30 working days, unless a sector reporting rule or the source system sets a different term. Data triggered by an event, such as a new asset, a change of operator or an incident, must be posted within 5 working days of the file being complete. The system records the time of submission and raises an overdue warning. Incident entries in the database do not replace the separate notification and response duties under sector law.

Điều 27 adds a three-step implementation path counted from 1 November 2026. Within 6 months, by early May 2027, each provincial Sở Xây dựng must complete a list and standardisation plan for every object that needs a sector identifier. Within 12 months localities must have the foundational data in place: identity, location, scale, capacity, operating status, service area and minimum legal file. Within 24 months every field that has a lawful source and the technical conditions must be filled, and legacy data must have been migrated. Objects that already meet the minimum information requirement under Nghị định 326 must be synchronised for a location ID without waiting for this schedule.

No profiling of households, tight control of network maps

Khoản 10 Điều 4 contains the sentence the legal press picked out: personal data collection must be minimal, purposeful and necessary, and the database does not collect identity data on water customers who are individuals or households, except where a law provides otherwise and within that law’s scope and authority. Customers appear in the data as counts of connections and categories, not as people.

Điều 10 classifies everything else into open data, data shared within the state, data provided on request or by assigned scope, and restricted data. The restricted list is explicit: detailed maps of the main supply and drainage networks, coordinates of critical works and head pump stations, protection plans, control configurations, system accounts, detailed financial data, personal data and trade secrets. These may only be accessed within an assigned scope, and every access is logged. Điều 24 adds a commercial safeguard: the link between supply volumes and predicted wastewater may be used for planning and forecasting, but not to audit a utility’s revenue or invoices.

Security follows Luật An ninh mạng: the ministry must classify the system’s security level under Nghị định 331, administrator and restricted-data accounts need multi-factor authentication, access is role-based on a least-privilege basis, and users authenticate with their electronic identification account (tài khoản định danh điện tử), with transitional accounts only where integration is not yet possible. A breach triggers isolation, evidence preservation and notification of affected parties where the personal-data or cybersecurity laws require it.

Who does what

Bộ Xây dựng owns the system. Cục Kết cấu hạ tầng xây dựng manages the business content: data model, field lists, master data, catalogues, the 47 management indicators in Phụ lục IV, and the proposals for open, shared, important and core data. The ministry’s Trung tâm Công nghệ thông tin runs the infrastructure, connections, accounts and logs. Provincial People’s Committees direct implementation; the Sở Xây dựng is the local data focal point and the body that reviews and records the quality status of records, without taking over responsibility for their accuracy. Commune People’s Committees enter the complaints they receive and verify service areas and flooding points on the ground. Owners of drainage assets supply and verify asset and contract files; water and drainage companies create and maintain their own operational data and hand it over when an operating contract ends. Funding comes from the state budget under the existing allocation rules.

Open data, mainly aggregates, goes on the Cổng dữ liệu quốc gia or the ministry’s data portal, preferably through an API. Drinking-water quality data is shared with provincial health departments and disease control centres. Mandatory inter-ministry sharing runs through the national data sharing and coordination platform under Nghị định 278/2025.

The dictionary and the law that is coming

On 27 October 2026 the ministry issued Quyết định 1852/QĐ-BXD, the version 1.0 data dictionary for the database. It fixes the technical name, definition, type, length and format of every minimum field, reusing the vocabulary already in the construction sector’s shared dictionary (the BXD-CDE base group and the BXD-XDDT urban infrastructure domain) and adding a water-sector code set, BXD-CTN. Where a unit of measure in the circular differs from the shared dictionary, the inherited unit wins. The dictionary’s metadata is to be published on the national data dictionary system.

The sector law is next. Quyết định 2061/QĐ-TTg of 28 October 2026, signed by Phó Thủ tướng Lê Tiến Châu, assigns Bộ Xây dựng to draft a Luật Cấp, thoát nước, the first water supply and drainage law, with the policy file due to the Government in December 2026, the bill in January 2027 and submission to the Standing Committee in February 2027 for the National Assembly’s third session in May 2027. That law will eventually replace the 2007 and 2014 decrees on which this circular still rests.

Practical implications

Water and drainage companies should audit their asset registers against the Phụ lục I and II field lists and the 1852 dictionary now, assign a focal point, and check which of their GIS, SCADA and billing systems can feed the API. The 6-month identifier census is run by the Sở Xây dựng, but the data comes from the utility.
Software vendors to the water sector have a published target schema and a stated preference for API delivery; any system that stores sector codes, location IDs and enterprise codes in one field will fail the Phụ lục III rule.
Provincial Sở Xây dựng acquire a continuous quality-review role, with automated rule checks, risk-based sampling and a running list of records flagged for correction, and must plan staffing for it within existing headcount.
Residents are not in the database by name. What they will see, in time, are open datasets on coverage, water loss, supply hours, wastewater collection rates and flooding points by locality.

Open questions

The circular says nothing about the interim regulation that governed the pilot, so its formal withdrawal is left to the ministry. Rural water supply stays with Bộ Nông nghiệp và Môi trường; the circular records rural areas only where an urban utility serves them directly and insists this changes no jurisdiction, which leaves the two databases to be reconciled through sharing. The text promises no new fees but also no new money beyond the ordinary budget, and the 24-month target depends on equipment that many smaller utilities do not yet have. And the relationship between this circular and the water law scheduled for May 2027 is unwritten; the law may well restate the database on a statutory footing.

Sources

This post is general information, not legal advice.