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The draft resolution on the development of digital citizens, which was open for public consultation from Dec. 12 through Dec. 31, 2025, has stirred considerable public debate. [1] The controversy centers on the proposal to rank citizens on digital platforms.

Critics have focused on the mechanisms for “scoring” and “ranking,” fearing these tools could intensify discrimination and facilitate forms of “latent” punishment . [2] These concerns are particularly valid given that Việt Nam still lacks a comprehensive legal framework for personal data protection and for limiting state power in the digital sphere.

However, a critical document in the lawmaking process—the explanatory report accompanying the draft—reveals a different priority. According to the report proposed by the Ministry of Public Security, the resolution’s primary objective is actually the development of the “super app” VNeID. Viewed in this light, the scoring and ranking of citizens appear to be merely instruments designed to incentivize use of the application.

What is an Explanatory Report?

According to the 2015 Law on the Promulgation of Legal Normative Document s, an explanatory report is a mandatory component of the dossier when an agency proposes a new legal document, such as a resolution. [3]

This report must clearly articulate the “issues to be addressed,” the “necessity of promulgating the resolution,” and the “guiding viewpoints,” along with the proposed objectives and purposes. Essentially, this is the document where the proposing agency justifies the necessity of the new regulation.

Because the proposing body uses this report to reveal its underlying intentions, it serves as the “backbone” of any legislative project. Reading and weighing the explanatory report is not just an indispensable step when reviewing a draft law; it is the most important action a citizen can take.

What Does the Explanatory Report Contain?

The Ministry of Public Security devotes nearly half of the draft explanatory report to justifying the “necessity of promulgating the resolution.” [4] The ministry argues that while existing provisions mention "digital citizens," these regulations are “scattered” and “fragmented,” creating the need for a “unified regulation.”

To push this policy forward quickly, the ministry is bypassing the standard legislative process of waiting for a National Assembly law. Instead, it cites Resolution No. 206/2025/QH15 of the National Assembly. [5] Effective from July 1, 2025, this mechanism allows the government to issue resolutions—previously just executive instruments—as legal normative documents to “address difficulties and obstacles arising from legal provisions while awaiting amendments and supplements to laws.”

Additionally, the report dedicates 2 of its 13 pages to the “results of implementing Project 06.” Approved by Prime Minister Phạm Minh Chính in 2022, Project 06 focuses on “developing applications of population data, electronic identification, and authentication” for digital transformation. [6] [7] The ministry uses this project as the “practical” foundation for its argument to issue the new regulation.

Is Citizen Ranking the Main Objective?

A close reading of the explanatory report suggests that citizen ranking is not the primary objective. In a document as important as this, with only 13 pages to present key content, the distribution of topics is likely carefully calculated by the drafting body.

The sections regarding “incentive mechanisms” and the “Digital Citizen Score system” occupy only half a page. By contrast, the Ministry of Public Security devotes three times as much space to plans for developing the national digital identification application (VNeID).

The proposals throughout the report revolve around a central axis: promoting the use of VNeID and enriching its data. Key points include:

Section I.1 (“Political and legal basis”): Reiterates Plan No. 02-KH/BCĐ-TW, emphasizing that “the VNeID application is the key to identification, authentication, the provision of electronic documents, and the receipt of official notifications from authorities.”

Section I.2.1 (“Results of implementing Project 06”): Notes that “with 65 million VNeID accounts […] however, 82% of fully online administrative procedures have not generated online dossiers. Efforts to encourage citizens to fulfill their obligation to enrich data through data creation, updating, and authentication still face many barriers.”

Section I.2.2.1 (“Incentive mechanisms”): States that “existing preferential policies are not strong enough to ‘create motivation for citizens to actively participate in the digital environment.’ A unified, breakthrough mechanism nationwide is needed to encourage citizens to change habits and prioritize the use of online public services […]”

Section I.2.2.2 (“Digital Citizen Score system”): Describes this system as intended “to create a quantitative measurement mechanism and encourage positive behaviors in the digital environment,” thereby “promoting citizens to proactively update data […]”

Section I.2.2.3 (“Development of VNeID”): Envisions developing this application into a “super app” incorporating functions such as personal digital signatures (which could be rapidly popularized and reduce costs for the public security model), a national e-wallet (state-led and integrated with bank accounts via VNeID), and a social network (to popularize official channels and authenticate user identities). For each function, the Ministry of Public Security proposes how the law should be “adjusted” to achieve these objectives.

Section II.1 (“Purpose of promulgating the Resolution”): States the aim to “strengthen state management and social governance in the digital environment” and to “issue breakthrough, unified mechanisms and policies nationwide, particularly strong incentives related to fees and charges and the construction of the Digital Citizen Score system, to create motivation for citizens to change habits, actively participate in online public services, and engage in digital transformation activities.”

Consequently, the draft resolution appears designed to lay the groundwork for this “super app,” granting control over finance, expression, and identification. The citizen ranking mechanism serves merely as an instrument—a loyalty policy for “preferred customers”—to drive user engagement.

However, this does not diminish the validity of concerns regarding citizen ranking. Although the public consultation period has concluded, the debate must expand beyond “citizen scoring” to address the Ministry of Public Security’s ambitious plan to establish a “digital empire,” with all its implications for privacy and civil liberties.

Sa Huỳnh wrote this article in Vietnamese and published it in Luật Khoa Magazine on Dec. 27, 2025. Đàm Vĩnh Hằng translated it into English for The Vietnamese Magazine.

References: +

1. Dự thảo Nghị quyết về phát triển công dân số . (2025). Bocongan.gov.vn. https://bocongan.gov.vn/chinh-sach-phap-luat/lay-y-kien-du-thao/du-thao-nghi-quyet-ve-phat-trien-cong-dan-so-1765510047?tab=comment

2. Thúc Kháng. (2025, December 22). Bộ Công an có vượt quyền khi chấm điểm, xếp hạng công dân không? Luật Khoa Tạp Chí. https://luatkhoa.com/2025/12/bo-cong-an-co-vuot-quyen-khi-cham-diem-xep-hang-cong-dan-khong/

3. thuvienphapluat.vn. (2025, March 31). Luật ban hành văn bản quy phạm pháp luật 2015 . THƯ VIỆN PHÁP LUẬT; thuvienphapluat.vn. https://thuvienphapluat.vn/van-ban/Bo-may-hanh-chinh/Luat-ban-hanh-van-ban-quy-pham-phap-luat-2015-282382.aspx

4. Dự thảo Nghị quyết về phát triển công dân số . (2025). Bocongan.gov.vn. https://bocongan.gov.vn/chinh-sach-phap-luat/lay-y-kien-du-thao/du-thao-nghi-quyet-ve-phat-trien-cong-dan-so-1765510047?type=dang-lay-y-kien

5. tin, T. (2025). Nghị quyết số 206/2025/QH15 của Quốc hội: Về cơ chế đặc biệt xử lý khó khăn, vướng mắc do quy định của pháp luật . Chinhphu.vn. https://vanban.chinhphu.vn/?pageid=27160&docid=214210

6. thuvienphapluat.vn. (2025, May 19). Quyết định 06/QĐ-TTg năm 2022 phê duyệt Đề án phát triển ứng dụng dữ liệu về dân cư, định danh và xác thực điện tử phục vụ chuyển đổi số quốc gia giai đoạn 2022-2025, tầm nhìn đến năm 2030 do Thủ tướng Chính phủ ban hành . THƯ VIỆN PHÁP LUẬT; thuvienphapluat.vn. https://thuvienphapluat.vn/van-ban/Cong-nghe-thong-tin/Quyet-dinh-06-QD-TTg-2022-De-an-phat-trien-ung-dung-du-lieu-ve-dan-cu-2022-2025-499726.aspx

7. baochinhphu.vn. (2023, July 12). Đề án 06: Một nền hành chính văn minh, phát triển công dân số . Baochinhphu.vn. https://baochinhphu.vn/de-an-06-xay-dung-nen-hanh-chinh-van-minh-phat-trien-cong-dan-so-102230712153458649.htm