Decree 248/2026/ND-CP: What contents must be disclosed by e-commerce platforms? (Part 2)

Following the content mentioned in Part 1 related to the contents that e-commerce platforms are required to disclose according to the new regulations stipulated by the Law on E-commerce and Decree 248/2026/ND-CP, in Part 2, CDLAF will inform enterprises of other contents that need to be disclosed based on each function of the commercial electronic platform. Because when the platform allows the conclusion of electronic contracts through the ordering function, the obligation to disclose is significantly expanded.

Source: Pexel

Table of contents:

1. Pricing Policy

For an e-commerce platform with an online ordering function, the platform must clearly show whether the price of goods or services includes taxes, shipping costs, and other incurred expenses.

For fees collected from merchants, the platform must disclose the fee schedule, calculation method, time of application, and each type of fee, such as account opening, account maintenance, order processing, or other support services.

If the fee policy changes, the new content must be made public at least 20 days before the time it applies.

This is a point that has a direct impact on the business model of e-commerce platforms. Enterprises should not only edit the fee schedule on the website but also build a mechanism to store versions, notify sellers, and prove when the new policy is announced.

2. Conditions or restrictions on the provision of goods and services

In case an e-commerce platform with the function of online ordering has conditions and limitations on the provision of goods or services applicable to sellers and buyers on its platform, the platform owner must publicize all such conditions and restrictions. Conditions and restrictions (if any) must include at least the following:

Limitations on the time of supply: time frames, days of the week or specific periods of the year in which goods and services are provided or restricted;
Limitations on geographical scope: specific areas, territories, and localities where goods and services are delivered or restricted from supply;
Restrictions on customers: conditions on age and specific living areas to access goods and services;
Quantity limits: the maximum number of goods and the minimum per transaction or per customer;

Conditions on the availability of services: cases in which goods and services may be discontinued or interrupted due to technical, maintenance, or force majeure events.

3. Payment, refund, and reward points policy

An e-commerce platform with an online ordering function must clearly explain the accepted payment methods and how to get a refund when returning goods or terminating services. If there is a mechanism for accumulating points, refunding points, or incentives with redemption value, the policy must clarify how points are formed, conditions for use, scope of application, conversion rate and limit, and responsibilities of the parties. Points are not designed to be cashed out.

With platforms with a member ecosystem, reward points are no longer just a marketing tool. This is a component of the trading conditions and should be governed as a commitment to the client.

4. Display priority policy

One of the most notable points of Decree 248 is the transparency of the main criteria used to restrict or prioritize the display of goods and services. Accordingly, in case the e-commerce platform uses algorithms or measures to limit or prioritize the display of goods and services, it must publicize all the main criteria used, including:

The relevance of the search keywords (including the names of goods and services and descriptions of goods and services);
Paid to display;
Search and transaction history of buyers on the platform;
Buyer reviews and feedback;
Number of successful orders;
Factors related to the user’s locality, country, territory;
Delivery and payment methods;
Other key criteria.

In particular, products that are sponsored, paid, or prioritized because of commercial relations should not be presented in a way that misleads users into believing that they are purely natural search results. If the user is given the right to choose or adjust the sorting criteria, the platform must also instruct how to do so.

5. Sales livestream regulations

Platforms with sales livestream features must develop and publicize a separate regulation.

The regulation should determine the rights and obligations of the parties; the process of identifying livestreamers; conditions for opening an account; in case of stopping live streaming, removing information or links; how to display warnings for goods and services that pose a risk of affecting life, health, or property; and a mechanism for receiving complaints during and after the livestream.

Livestreams should not be seen as a communication feature that is separate from trading. When viewers can place orders directly, broadcast content, appearances, featured products, and arising orders must be connected in the same risk management system.

6. Specific policies for goods trading platforms

Platforms with the function of ordering online and buying and selling goods must publicize additional delivery, return, and refund policies.

The delivery policy should define the delivery method, shipping unit, estimated time, geographic restrictions, responsibility for providing order tracking information, and an inspection policy.

The return policy should clarify which goods are returned, the time limit for the request, the processing process, the method of return, and the party bearing the cost.

One content that is often disputed is the difference between the policy published by the exchange and the seller’s own policy. The platform needs to clearly specify which cases apply to the general policy, where sellers are allowed to set their own conditions for, and the principles of handling when the two policies conflict.

7. Specific policies for service-providing platforms

For services used directly on the platform, enterprises must disclose the expiration date, type of compatible devices, the number of devices allowed to be used simultaneously, how to use them, key features, and technical limitations.

For services booked but used in a different location, the platform must disclose the conditions of use, the form of confirmation, the duration, conditions for exchange or cancellation, and the fees incurred.

In addition, the platform must publicize its termination of service and refund policy. The policy should determine the instance of termination, legal consequences, when the contract expires, how the fee is calculated, the process for sending notices, and the deadline for responding.

Decree 248 stipulates a noteworthy consequence: if the platform does not clearly disclose the time of termination of the contract when the buyer actively terminates it, the time when the buyer sends a notice can be considered as the time of termination of the contract. This regulation is especially important for subscription-based software, digital content services, paid memberships, reservations, ticketing, online education, and auto-renewing services.

What should enterprises do to ensure that e-commerce platforms are operated in accordance with the law?

An effective compliance review should be done from the actual operation of the platform rather than starting from the existing policy templates. With CDLAF’s experience, we find that:

First of all, enterprises need to determine the legal model of the platform: direct business, intermediaries, social networks with e-commerce activities or integrated platforms.
Next, it is necessary to define the exact functionality: whether the platform allows ordering, whether there is a seller fee, whether there is accumulation of points, whether the display priority algorithm is used, whether there is a livestream for providing goods or services, and whether or not it is auto renewed.
After that, enterprises need to compare each function with the content that must be disclosed and check the consistency between policies and interfaces, contracts, operation processes, and data storage.
Finally, the policy must be tested as part of the product: can the user find it? Is it readable on a mobile device? Can a complaint be submitted? Can a request for deletion of data be made? Is consent recorded by the system?

The Law on E-commerce and Decree 248 took effect on July 1, 2026. For websites or e-commerce applications that have been confirmed to be notified or registered before July 1, 2026, the platform may continue to operate according to the confirmed content until the end of June 30, 2027. During this transition period, the platform manager must amend and supplement the dossier according to the new regulations. The transition period should not be interpreted as enterprises being able to wait until mid-2027 to start reviewing. Updates can be related simultaneously to legal terms, application interfaces, data processes, complaint systems, payment mechanisms, and partner contracts. For a large platform, this is a cross-departmental compliance project, not a content editing job within a few days.

Time of writing: July 13, 2026

The article contains general information which is of reference value. In case you want to receive legal opinions on issues you need clarification on, please get in touch with our Lawyer at info@cd.az9s.com

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