Question:
Dear Lawyer, our company is currently in the process of completing an online game. This is a type of game where many players can participate simultaneously, interact, form teams or compete with each other in a virtual world, and all player data is processed through our company’s server system. Before officially launching the game in the Vietnamese market, what legal issues should we pay attention to in order to ensure compliance with regulations?
Answer:
Based on your description—where multiple players interact with each other simultaneously through the enterprise’s server system—under Decree No. 147/2024/ND-CP, this is classified as a G1 online game. To legally publish this type of game in the market, your company cannot proceed immediately but must satisfy two prerequisite licensing conditions. First, your company must obtain a License for Provision of G1 Online Game Services, which demonstrates its capacity in terms of finance, personnel, and technical infrastructure. Second, for the specific game you are developing, the company must apply for a Decision approving the release of the G1 online game, which involves appraisal of the game’s content and script.
From a technical and management perspective, Decree 147/2024 sets out stringent requirements that enterprises must fulfill prior to operation. The company must establish a system capable of storing and verifying player information in Vietnam via mobile phone numbers, ensuring that only verified accounts are allowed to participate. Notably, the system must include features to manage daily playing time for users under 18 years old, limiting playtime to no more than 60 minutes per game and no more than 180 minutes per day across all games provided by the enterprise. At the same time, the company is required to continuously display health warnings on players’ devices at a frequency of once every 30 minutes during gameplay.
Another important point is the obligation to self-classify games by age group based on their content, images, and sound. Pursuant to Article 38 of the Decree, games must be clearly labeled according to ratings such as 18+, 16+, 12+, or 00+, and such classification must be continuously displayed on the device screen as well as in all advertising materials. If the game content contains elements of violence, horror, or content deemed contrary to social ethics and cultural standards, the enterprise will not be granted the release approval. Strict compliance with licensing and technical management requirements not only helps the enterprise avoid risks such as suspension of operations or revocation of licenses under Article 47, but also demonstrates the company’s responsibility in building a healthy entertainment environment.
