Decision 33/2026/QD-TTg List of High-Risk Artificial Intelligence Systems

FOR THE PRIME MINISTER

DEPUTY PRIME MINISTER

Ho Quoc Dung

No.

System name

System description

Conformity assessment

Pursuant to Point b, Clause 2 Article 13 of the Law on Artificial Intelligence

Pursuant to Point a, Clause 2 Article 13 of the Law on Artificial Intelligence

I

Education Sector

1

Artificial intelligence system providing self-learning content under educational curricula using uncontrolled data sources

Applicable only where the artificial intelligence system:
– Provide automated content to support learners’ self-study activities according to the educational program;
– Use learning content input data that is not subject to control;
– Be deployed on a large scale, with the potential to create systemic risks or widespread impacts on learners.

X

2

The system uses artificial intelligence to automatically conduct examinations, assessments learning outcomes, and rank learners

Applicable only where the artificial intelligence system:
– Be used to conduct examinations or assessments of learners;

– Generate results that are used as the official basis for assessing learning outcomes, evaluating competencies, or ranking learners;

– The assessment is conducted within the national education system.

X

3

The system uses artificial intelligence to monitor and analyze learners’ behavior

Applicable only where the artificial intelligence system monitoring and analyzing learners’ behavior:

Use biometric data ( facial recognition, gaze tracking, behavioral, or personal emotional data); or establishing high-frequency automated feedback or warning mechanisms concerning learners’ attention levels, personal expressions, learning outcomes, or learner assessment that causes psychological distress or infringes upon learners’ privacy during the learning process.

X

II

Ethnic Affairs and Religion Sector

1

Artificial intelligence system automatically scoring, classifying, and ranking dossiers for determining eligible beneficiaries and geographical areas entitled to ethnic policies

Applicable only where the artificial intelligence system:
– Automatically score, and the results are used as the basis for competent state authorities to issue decisions (decisions approving, rejecting, or prioritizing dossiers, determining the list of eligible beneficiaries and geographical areas entitled to ethnic policies; directly affecting the lawful rights and interests of individuals or communities, or the allocation of public resources).

– Be not used as the official result for public disclosure.

X

2

Artificial intelligence system automatically verifying and determining the validity of information relating to ethnic affairs and religion

Applicable only where the artificial intelligence system:
– Automatically examine, cross-check, and verify information relating to ethnic affairs and religion, and decides whether to accept or reject such information;

– Operate without subsequent review or approval by a competent authority.

X

3

Artificial intelligence system automatically deciding whether to approve or reject dossier for registration, renewal, or revocation of state management decisions in the field of ethnic affairs and religion

Applicable only where the artificial intelligence system:
– Automatically make the final decision on approving or rejecting dossier for registration, renewal, or revocation of state management decisions in the field of ethnic affairs and religion;
– Operate without review, intervention, or subsequent approval by a competent authority.

X

4

Artificial intelligence system automatically making final decisions on approving or rejecting dossier for determining eligible beneficiaries and geographical areas entitled to ethnic policies

Applicable only where the artificial intelligence system:

Automatically make decisions, including decisions that create, modify, or terminate the lawful rights and interests of individuals or communities.

X

5

Artificial intelligence system automatically executing the suspension of benefit payments, recovery of benefits, or blocking entitlement to support on the basis of suspected fraud

Applicable only where the artificial intelligence system:
– Automatically trigger measures that interrupt subject’s entitlement to benefits or access to assets or services;

– Operate without an independent verification step before measures take effect.

X

6

Artificial intelligence system automatically issuing orders for the allocation or distribution of budgetary resources or support policies based on algorithmics

Applicable only where the system has the authority to implement, or automatically implements the budget allocation or support policy plan after the decision on allocation or distribution of budgetary resources has taken effect.

X

7

Artificial intelligence system inferring or classifying ethnicity, belief, or religion for the purpose of applying administrative management measures

Applicable only where the system:
– Automatically create classifications of individuals or community groups based on attributes relating to ethnicity, beliefs, or religion;

– Use the results as the basis for applying administrative management, inspection, or administrative enforcement measures.

X

III

Healthcare Sector

1

Artificial intelligence system supporting surgery/surgical robots

Applicable only where the artificial intelligence system:
– Be integrated into a robot that directly participates in surgical intervention or provides guidance for operative procedures;

– Be integrated into a fully autonomous robot or an intelligent robot that performs tasks in place of human actions.

X

2

Artificial intelligence system supporting surgery/surgical robots (A system of machinery and robotic equipment using artificial intelligence for automated control)

Applicable only where the artificial intelligence system:
– Be integrated into a robot that directly performs therapeutic interventions on a patient’s body in accordance with a physician’s order;

– Perform without requiring confirmation from a healthcare professional for each adjustment of parameters.

X

IV

Banking Sector

1

Artificial intelligence system automatically executing electronic transactions in banking activities

Applicable only to artificial intelligence systems that automatically execute electronic transactions in banking activities, provided that the following conditions are met:

– The system is capable of automatically creating, modifying, confirming, and approving transactions;
– The transactions are of high value as prescribed by the State Bank of Vietnam;

– No human review, approval, or oversight is carried out before the transactions are executed.

X

2

Artificial intelligence system automatically making decisions to extend credit

Applicable only to the artificial intelligence system that performs credit scoring, assesses borrowers’ repayment capacity, and automatically makes decisions on extending credit or disbursing loans, provided that the following conditions are met:

– The system makes the final decision on approving or rejecting the extension of credit;
– The system’s decision is used directly for granting credit or loan disbursement without independent approval by a credit officer; and
– The loan amount reaches the threshold prescribed by the State Bank of Vietnam.

X

V

Judicial Proceedings Sector

1

Artificial intelligence system for large-scale biometric identification used for the adjudication of public interest civil cases

Applicable only where the artificial intelligence biometric identification system is deployed on a large scale at the location where the unlawful act occurred or where the damage occurred.

X

VI

Transport Sector

1

Artificial intelligence system for high-level automated driving of transport vehicles

Applicable only where the artificial intelligence system:
– Control road vehicles, railway vehicles, inland waterway vessels, maritime vessels, or aircraft at a level that does not require continuous human supervision or intervention during operation;

– Or where decisions made by the artificial intelligence system directly determine the vehicle's control actions that may affect the safety of human life, health, or property.

X

2

Artificial intelligence system controlling or automatically operating road traffic signals and road or railway traffic dispatch

Applicable only where the artificial intelligence system:

– Be directly connected to a road traffic control center or a railway traffic dispatch system and be authorized to automatically modify traffic signals, control cycles, traffic flow arrangements, route configurations, train paths, or vehicle dispatch;

– Operate without independent approval by a competent person;

– Have the capability to directly affect road traffic safety, railway operational safety, and the safety of road users.

X

3

Artificial intelligence system managing and controlling the operation of transport infrastructure and critical technical infrastructure

Applicable only where the artificial intelligence system:
– Have the authority to access and directly intervene in the operational control and monitoring systems of road tunnels, major bridges, expressways, transport hubs, or critical technical infrastructure, including water supply, drainage, and urban lighting systems;

– Outputs of artificial intelligence system are immediately executed or alter the physical operating status of infrastructure.

X

4

Artificial intelligence system automatically detecting, assessing the risk of incidents, and issuing orders to restrict or suspend the operation of works and infrastructure

Applicable only where the artificial intelligence system:
– Automatically assess the safety status of transport infrastructure, construction works, or critical technical infrastructure, and outputs of system are used directly to decide on operational restrictions, suspension of operation, isolation, or changes in operational status;

– Operate without mandatory independent human verification.

X

5

Artificial intelligence system automatically appraising, scoring, ranking, or classifying dossiers as the basis for final decisions

Applicable only where the artificial intelligence system:
– Be used in state management activities, the provision of public services within the scope of responsibility of the Ministry of Construction, and its outputs are used directly as the basis for approving, rejecting, suspending, restricting, or modifying the validity of dossiers, administrative procedures, licences, certificates, or operating conditions of organizations or individuals;

– Operate without independent review or approval by a competent person.

X

6

Artificial intelligence system automatically detecting violations or performing real-time biometric identification for control and enforcement purposes

Applicable only where the artificial intelligence system:
– Automatically detect violations, identifies subjects, analyses images or sensor data, or performs real-time biometric identification at transport hubs or major public infrastructure, and its outputs are used directly for handling violations, enforcement, security and public order control, restricting access, or applying administrative management measures;

– Operate without independent verification by a competent officer.

X

7

Automated Air Traffic Management (A-ATM) artificial intelligence system making air traffic flow management and flight routing decisions

Applicable only where the artificial intelligence system:
– Automatically issue flight routing instructions, altitude changes, or air traffic flow management commands without the direct supervision and approval of an air traffic controller;
– Do not apply to systems that merely provide recommendations or advisory alerts.

X

8

Artificial intelligence system supporting or replacing air traffic controllers in aircraft separation and take-off/landing clearance decisions (AI-ATC Decision Support System)

Applicable only where:

– The system directly makes or executes decisions on aircraft separation, take-off/landing clearance, or flight routing;
– Operate without independent approval by an air traffic controller.

X

9

Artificial intelligence system predicting aircraft trajectory conflicts and automatically issuing collision avoidance instructions (Trajectory Conflict Prediction & Resolution)

Applicable only where the artificial intelligence system:

– Automatically detect the risk of trajectory conflicts and make or execute aircraft separation measures;

– Operate without approval by an air traffic controller.

X

10

Artificial intelligence system automatically allocating take-off and landing slots and assigning aircraft gates at airports (ATFM/CDM)

Applicable only where the artificial intelligence system:

– Be deployed at international airports handling more than five million passengers per year;
– Automatically allocate and confirm airport slots without any review mechanism by an airport slot coordinator; do not apply to Decision Support Systems (DSS) that merely provide recommendations.

X

11

AI-integrated autonomous flight control system (Autopilot/FMS) capable of making independent flight navigation decisions in abnormal situations

Applicable only where the artificial intelligence system integrated into autonomous flight equipment:

- Artificial intelligence system is capable of automatically adjusting the flight path, altitude, or responding to emergency situations without requiring pilot intervention or confirmation; does not include conventional autopilot systems that were type-certified before the Law on Civil Aviation took effect.

X

12

Next-generation AI-enabled Collision Avoidance System (CAS) for aircraft

Applicable only to AI-enabled CAS capable of automatically maneuvering aircraft to avoid collisions without pilot action; excluding conventional TCAS/ACAS systems that obtained type certification before the Law on Civil Aviation of Vietnam took effect.

X

13

Artificial intelligence system predicting and managing in-flight emergencies (AI Emergency Flight Decision System)

Applicable only where the system:

– Automatically propose or execute decisions on flight diversion or emergency landing;
– Operate without confirmation by the pilot or an air traffic controller.

X

14

Applicable only where the system:

– Automatically decide to close runways or cancel or delay flights;

– Operate without approval by the competent aviation meteorological authority.

X

15

Artificial intelligence system managing aircraft ground movements at airports (ASMGCS Level 3–4)

Applicable only where the system:
– Automatically authorize taxi movements, allocate taxiways, or assign aircraft parking positions within the maneuvering area;

– Operate without confirmation by a ground controller.

X

16

Artificial intelligence system automatically allocating aircraft stands and boarding gates (Stand/Gate Allocation)

Applicable only where the system:
– Automatically determine aircraft stand or gate allocation under actual operational conditions;

– Operate without approval by airport operations personnel.

X

17

Artificial intelligence system controlling autonomous vehicles within the airside area (follow-me vehicles, baggage loading vehicles, and refueling vehicles)

Applicable only where the system:
– Control vehicles operating autonomously within the airside area where there is a risk of collision with aircraft or airport infrastructure;

– Operate without direct human supervision.

X

18

Artificial intelligence system controlling licensed drones/UAVs within controlled airport airspace (U-Space/UTM)

Applicable only where the system:
– Automatically navigate licensed UAVs to operate within controlled airport airspace or near runways;

– Operate without direct supervision by the air traffic control authority;

– Do not apply to systems designed to counter unauthorized UAV intrusions.

X

19

Artificial intelligence system automatically analyzing technical data and deciding whether aircraft are fit for operation (Predictive Maintenance AI)

Applicable only where the system:
– Automatically issue grounding orders or authorize continued aircraft operation based on AI analysis;

– Operate without review and approval by a licensed aeronautical engineer.

X

20

Automated aviation fuel management artificial intelligence system (automatically issuing aircraft refueling instructions)

Applicable only where the system:
– Automatically determine the quantity and timing of aircraft refueling;
– Operate without confirmation by a flight operations engineer regarding the type of fuel.

X

21

Artificial intelligence system analyzing security screening images and automatically detecting and classifying dangerous items in baggage at security checkpoints (Automated Threat Detection)

Applicable only where the system:
– Automatically make threat detection decisions, classify threats, activate alarms, or isolate baggage;

– Operate without mandatory secondary inspection by aviation security personnel, may pose risks in both directions by either failing to detect dangerous items or generating false alarms that disrupt operations.

X

22

Artificial intelligence system analyzing passenger behavior through cameras (Behavior Detection AI) in airport security screening areas

Applicable only where the system:
– Automatically identify suspicious behavior and activate security alerts or intervention measures;

– Operate without initial confirmation by aviation security personnel; directly affecting individual freedom.

X

23

Applicable only where the system:
– Automatically refuse passenger carriage or activate aviation security measures;

– Operate without verification by competent aviation security personnel.

X

24

Artificial intelligence system automatically detecting and countering unmanned aerial vehicles (UAVs/drones) intruding into no-fly zones surrounding airports (Counter-UAV)

Applicable only where the system:
– Automatically execute countermeasures (signal jamming, disabling, or taking control of unlawfully intruding UAVs);

– Operate without a confirmation order from aviation security forces or the competent military authority.

X

25

Artificial intelligence system automatically controlling energy distribution and backup systems at power stations or air traffic control facilities (SCADA/ICS)

Applicable only to systems that:
– Have the authority to directly intervene in the physical control network (SCADA/ICS) of nationally critical aviation infrastructure; and
– Operate without confirmation by an operations engineer.

X

26

Artificial intelligence system monitoring and detecting airside incursions (runway or taxiway incursions)

Applicable only where the system:
– Automatically detect objects, vehicles, or persons intruding into movement areas and activate physical infrastructure control measures (including runway closures or warning lights);

– Operate without confirmation by airport operations personnel.

X

27

Artificial intelligence system monitoring runway conditions and detecting foreign object debris (FOD Detection)

Applicable only where the system:
– Automatically detect foreign object debris or runway safety hazards and activate alerts or operational restrictions;

– Operate without confirmation by airport operations personnel.

X

28

Artificial intelligence system monitoring and controlling airport infrastructure (runway lighting, ILS/GBAS systems, and power supply)

Applicable only where the system:

- Have the authority to directly access and control critical airport technical infrastructure affecting aircraft navigation and landing operations.

X

29

Artificial intelligence system controlling AI-integrated precision landing aids (AI-enabled ILS/GBAS)

Applicable only where the landing guidance system for low-visibility operations incorporates an artificial intelligence component capable of making automated decisions; directly affecting aircraft landing safety.

X

30

Artificial intelligence system assessing security risks in dossiers for aviation security identification cards

Applicable only where the AI assessment result serves as the sole basis for refusing the issuance of an aviation security identification card or restricting an individual’s access to restricted areas without independent review by an assessment committee.

X

31

Artificial intelligence system automatically conducting inspections, examinations and issuing alerts regarding violations of airport obstacle limitation surfaces based on satellite data or aerial imagery

Applicable only where the system:

- Be used as the legal basis for ordering the suspension of works that violate airport obstacle limitation surfaces or imposing administrative penalties without an on-site inspection.

X