A Compliance Deadline With Real Teeth
On June 15, 2026, Vietnam's three largest mobile carriers — Viettel, VinaPhone, and MobiFone — cut outbound calling and texting for roughly 10.6 million subscriptions that had not completed facial-biometric verification through the national VNeID app, under Circular 08/2026/TT-BKHCN. Viettel alone restricted more than 5 million accounts; VinaPhone suspended nearly 3 million; MobiFone reported about 2.6 million (SGGP). Two weeks earlier, a deputy director at Vietnam's Telecommunications Authority had put the number of still-unconfirmed subscriptions at roughly 25 million, urging citizens to verify before the deadline (Chính phủ).
The circular, issued by the Ministry of Science and Technology and effective since April 15, 2026, requires every mobile subscriber to confirm four data points — national ID number, full name, date of birth, and a live facial scan — matched against the national population database (Chính phủ, full text; MIC). Article 8, which took effect June 15, adds a second trigger: swap a SIM into a new device, and the carrier has two hours to detect the change, suspend outbound service, and demand a fresh facial re-scan.
Subscribers cut off on June 15 aren't disconnected outright. They keep incoming calls and data, and have 60 days — until August 15, 2026 — to verify before a full two-way suspension, followed by five more days before the number is revoked entirely (SGGP).
The Case for It
The rationale is not manufactured. SIM-swap fraud — hijacking a phone number to intercept OTP codes and drain linked bank accounts or e-wallets — is a genuine and rising threat across markets with mobile-first banking, and Vietnam's digital payments footprint has grown fast enough to make telecom identity a real attack surface. A subscriber base padded with "garbage" SIMs — registered to fake or stolen identities, sold pre-activated, or abandoned without deactivation — is a documented enabler of scam-call and phishing operations, which Vietnamese authorities cite as the direct motivation for the circular. Anchoring subscriber identity to biometric verification closes an obvious loophole: a lost or stolen SIM nobody bothers to cancel becomes, under the old rules, an open door.
The Cost of Centralizing the Fix
But the design carries a structural risk, not just a rollout hiccup. Every verification event under Circular 08 runs through VNeID, the same national digital-identity platform increasingly underpinning banking, tax, and other government-linked identity checks in Vietnam. Concentrating facial-biometric records for effectively the entire mobile-using population inside one state-run database doesn't just centralize convenience — it centralizes the failure mode. A breach or unauthorized access to VNeID would expose the same identity layer that gates phone service, financial access, and government interaction simultaneously, without an independent data-protection authority in Vietnam empowered to audit how that data is used once collected.
"Prohibitions of anonymity unduly and arbitrarily restrict human rights and fundamental freedoms" and can "facilitate State communications surveillance," with "a chilling effect, dissuading the free expression of information and ideas."
That is Access Now's assessment of Vietnam's parallel push to mandate real-identity verification for social media accounts — a separate but structurally related measure — arguing blanket identity mandates fail the proportionality test under the International Covenant on Civil and Political Rights, which Vietnam has ratified (Access Now). Circular 08 is narrower in stated purpose — fraud prevention rather than content moderation — but it builds the same infrastructure: a biometric record binding a real name to every act of digital communication, in a one-party state with a documented record of prosecuting bloggers and activists.
Proportionality, Not Prohibition
None of this argues against subscriber verification as a concept — KYC-style rules for telecom are standard practice in mature markets, and Vietnam's problem of mass unregistered SIMs enabling fraud is real enough to justify some response. The proportionality question is narrower: does closing that gap require a two-hour suspension trigger feeding a single centralized biometric store, or would a federated model — carriers holding verification data under audited security standards, checked against the national ID database without a permanent facial-image copy sitting in VNeID — achieve the same fraud reduction with a smaller surveillance footprint? The scale of the June 15 suspensions suggests the rollout leaned toward blunt enforcement over public education: a 25-million-subscription backlog two weeks before a hard deadline reads less like a fraud crackdown catching bad actors and more like an awareness failure that happened to catch them too, alongside millions of ordinary subscribers.
Vietnam's regulators have a legitimate fraud problem to solve. They chose the version of the fix that maximizes state visibility into who is calling whom, rather than the version that would have minimized the biometric data footprint required to get there — and 10.6 million suspended lines are the visible cost of that choice.