Control of economic concentration in digital platform markets under Vietnamese competition law

Digital platform markets operate under economic characteristics fundamentally different from traditional markets, including multi-sided structures, network effects, and the central role of data. However, merger control under Vietnam’s 2018 Competition Law and Decree No. 35/2020/ND-CP continues to rely primarily on outcome-based quantitative indicators such as market share, turnover, total assets, and transaction value. This mismatch may leave potentially anticompetitive platform transactions outside effective regulatory scrutiny. The study argues that the core legal criterion for identifying and assessing economic concentration in digital platform markets should shift from market share toward the ability to control data and gateways to user access. On this basis, it proposes four groups of recommendations for further improving Vietnamese competition law.