Vietnam's Amended Advertising Law Takes Effect January 2026 — KOLs and KOCs Legally Recognized as "Sellers," TikTok Shop Doubles Up Its Ad Review, Key Legal Changes D2C Brands Must Know for Their Influencer Strategy

Vietnam's Amended Law on Advertising took effect on January 1, 2026. The biggest change is that KOLs (Key Opinion Leaders) and KOCs (Key Opinion Consumers) are now clearly and legally defined as "advertising subjects." Influencers who endorse functional foods, cosmetics, and healthcare products are now obligated to confirm certification from the Ministry of Health or local health authorities in advance, and may be held jointly liable for false advertising.

Key Points of the Amendment

TikTok's Response: Introducing a Dual Review System

In response to the amended law, TikTok Vietnam has introduced a hybrid monitoring system combining manual review with automated AI screening. It has implemented a mechanism that detects paid advertising content before it is posted and automatically applies a "sponsored" label. An in-app tool has also been newly added for influencers to declare an ad before publishing content.

Impact on D2C Brands: Higher Costs vs. Greater Market Trust

This legal amendment has two effects on Vietnam's D2C market:

Higher Short-Term Costs: Engaging a KOL now requires confirming product certification in advance, bearing verification costs, and preparing formal contracts, which raises operating costs especially for small and mid-sized D2C brands.

Building Medium- to Long-Term Market Trust: On the other hand, as consumer distrust caused by rampant false advertising is resolved, brands with genuine quality find it easier to differentiate themselves. A 2017 AsiaKOL survey found that 77% of Vietnamese online consumers made purchase decisions based on influencer recommendations, and the legal framework has now caught up with this high level of influence.

Implications for Japanese Companies Entering Vietnam's E-Commerce Market

For companies entering Vietnam's e-commerce market from Japan, this amended law calls for the following responses:

1. Formalizing KOL Contracts Legally: Specify the product verification obligation before endorsement in the contract terms
2. Preparing Certification Documents in Advance: Prepare Ministry of Health certification and quality proof in both English and Vietnamese
3. Platform Compliance: Check the advertising regulations specific to each platform — TikTok Shop, Shopee, and Lazada

TikTok Shop Trends in Vietnam's D2C Beauty Market and TikTok Shop Fee Hike Reading this together with the above will allow for a multi-angled look at Vietnam D2C strategy for the second half of 2026.