Key considerations for enterprises purchasing data on data exchanges under Decree 314/2026/ND-CP

On August 8, 2026, the Government issued Decree 314/2026/ND-CP regulating the operation of data exchanges (“Decree 314”). Taking effect on September 25, 2026, Decree 314 establishes an important legal framework governing the national data exchange and other data exchanges, and also regulates matters such as data processing, cross-border data sharing, control of the purpose of use, and the responsibilities of the entities providing and exploiting data. This article by NHQuang&Associates shall analyze certain notable provisions of Decree 314 which enterprises exploiting and using data, data products, and services on data exchanges (“Data-purchasing enterprises”) should be aware of:

1. The conditions for Data-purchasing enterprises to participate in transactions and the procedures for registering a transaction account on the data exchange;
2. The form for Data-purchasing enterprises to establish transactions on data exchanges;
3. The right of Data-purchasing enterprises to test data before transaction.

Key considerations for Enterprises purchasing data on data exchanges under Decree 314/2026/ND-CP

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