Vietnam's Paperless Hospital Deadline: What Happens to the Records Before 2027
From 1 January 2027, hospitals across Vietnam stop using paper medical records. Most have an electronic system in place. The question now is what happens to the years of history that came before it.
Suhina Singh
Founder & CEO, Jonda Health
October 26, 2026
·
9 min read
Key takeaways
All public and private hospitals in Vietnam are to stop using paper medical records from 1 January 2027.
Other inpatient, day and outpatient facilities must implement electronic medical records by 31 December 2026.
More than 75% of hospitals have announced EMR implementation, though the Ministry of Health notes some have not yet met quality requirements.
Health data is sensitive personal data under the Personal Data Protection Law, in force since 1 January 2026.
New records start digital. Historical records need their own plan if the EMR is to hold a complete, useful history.
Vietnam is in the final stretch of one of the region's most ambitious moves to electronic medical records. Within a few months, paper medical records will no longer be used in the country's hospitals, and every other treatment facility will be expected to run on electronic records too.
For most hospitals, the system itself is already chosen and running. The harder, quieter question sits behind it. A patient who has been treated for years arrives with a history held in paper files, scanned documents and older systems. When clinicians open the new EMR, how much of that history will be there, and how much can they trust?
This guide explains what the rules require, how the data protection law adds to them, and how hospitals and clinic groups can bring historical records across safely. It draws on our experience at Jonda Health, where our work is turning health records from many different sources, in more than ten languages, into structured, standardised information that clinicians and systems can actually use.
Figure 1. Vietnam's move to electronic medical records.
What is changing
Circular 13/2025/TT-BYT, issued by the Ministry of Health in June 2025 and in force from 21 July 2025, guides the implementation of electronic medical records across all public and private medical examination and treatment facilities. It set a deadline of 30 September 2025 for hospitals, and 31 December 2026 for other inpatient, day and outpatient facilities (Circular 13/2025/TT-BYT).
The Minister of Health has since directed all hospitals to complete EMR implementation by 31 December 2026, so that from 1 January 2027 no public or private hospital uses paper medical records. The Ministry reports that more than 75% of hospitals have announced EMR implementation, while acknowledging that some have not yet met quality requirements or fully replaced paper (Ministry of Health, via vietnam.vn).
Requirement
What it means
Electronic by default
Records are created, updated, signed, stored and accessed electronically.
Linked to identity
Records link to the personal identification number of Vietnamese citizens, and of foreigners with electronic identification accounts.
Signed electronically
Staff and patients can authenticate records through electronic signatures, biometrics or other lawful methods.
Retrievable
Data must support restoration and retrieval for treatment, research and health management.
Existing paper records
Records created before 21 July 2025 may continue to be used or be converted to digital form.
Vietnam's Personal Data Protection Law, Law 91/2025/QH15, came into effect on 1 January 2026. It treats health information as sensitive personal data, requires a data processing impact assessment to be filed within 60 days of processing starting, and a separate assessment for cross-border transfers. It also bans trading in personal data, and fines for breaches of the cross-border rules can reach 5% of the previous year's revenue (Rouse).
For hospitals, this changes how a records project should be planned. Knowing what data you hold, where it sits, who processes it and where it goes is no longer only good practice. It is part of the assessments the law expects, and it should be settled before historical records are moved or processed by anyone outside the hospital.
Going paperless is two jobs, not one
It helps to separate the two tasks every facility faces. New records, from go-live onwards, are captured directly in the EMR, signed and linked to the patient's identity. Historical records follow a different path entirely.
Figure 2. Going paperless is two jobs, not one.
Circular 13 gives facilities flexibility over older paper records. That flexibility is sensible, but it means each hospital has to decide for itself what to convert, how far back to go, and to what standard. A scanned image of a paper file satisfies the requirement to have it digitally. It does not let a clinician see a patient's kidney function trend, or let the hospital report on outcomes, until the content inside it has been structured and checked.
What makes historical records hard
In the records we work with across the region, the same patterns appear again and again, and Vietnam is no exception.
Handwritten and scanned documents. Much of the history exists only as paper or images, which need careful reading before anything can be structured.
Different conventions between departments and facilities. Laboratory tests are named and abbreviated differently, with different units and reference ranges.
Medicines under many names. Brand names, generic names and local product names all appear for the same medicine.
Mixed languages. Records often combine Vietnamese with English or French medical terms, and results from overseas providers add more.
Matching to the right patient. Older records may predate linking to personal identification numbers, so matching needs care to avoid merging or splitting histories.
None of this reflects poor practice. It is simply how records build up over decades of busy care. AI can do a great deal of this work at speed, and we use it extensively ourselves, but in a clinical setting it needs clinical review and quality checks behind it. That is why we argue that healthcare AI will not work without trusted data infrastructure.
Who this affects
Organisation
Where to focus
Public hospitals
Meeting quality requirements, fully replacing paper, and deciding what history to convert.
Private hospital groups
Consistent records across sites, identity linking, and data protection impact assessments.
Clinics and outpatient facilities
Implementing EMRs by 31 December 2026, often with fewer in-house resources.
Provincial health departments
Supporting facilities to meet the deadline and reporting progress to the Ministry.
EMR vendors
Helping clients bring historical records across without delaying go-live.
A practical checklist
Confirm your EMR is live across all departments, and identify where paper is still in use.
Decide how far back historical records need to go for safe care, and for which patient groups first.
Pull a sample of historical records and assess them honestly: how much is handwritten, scanned or in older systems?
Review how laboratory tests, medicines and diagnoses are named across departments and sites.
Plan how older records will be matched to patients' personal identification numbers.
Complete your data processing impact assessment before historical records are moved or processed externally.
Build clinical review into conversion, not only scanning or automated extraction.
How Jonda Health can support you
At Jonda Health, we have spent years working with health records across languages, formats and health systems, and we know how much of a records project only becomes visible once the work begins. Depending on where your organisation is today, there are three ways we can help.
If you are not sure how ready your records are
A data readiness assessment
Through Jonda Health Services, we look at a sample of your records and give you a clear picture of the gaps, with a practical plan for what to convert, in what order, before and after the 2027 deadline.
If much of your history is on paper or in PDFs
JondaX
JondaX turns paper records, scans and PDFs, as well as HL7 and CSV files, into structured, standardised data. It handles records in more than ten languages, reconciles variant test names and units, maps local codes to medical coding standards, and puts clinical review and quality assurance behind the output. JondaX is ISO 27001 certified and designed to comply with HIPAA, GDPR and PDPA.
If you are changing or upgrading your EMR
Migration support
We work alongside your EMR vendor to check, clean and move patient history, and agree with you at the outset where data is processed and stored, so the work fits your obligations under Vietnam's data protection law.
Frequently asked questions
When do Vietnamese hospitals have to stop using paper medical records?
Under a Ministry of Health directive, all public and private hospitals are to complete electronic medical record implementation by 31 December 2026 and stop using paper medical records from 1 January 2027.
What does Circular 13/2025/TT-BYT require?
Circular 13 guides electronic medical record implementation for all public and private medical examination and treatment facilities. It took effect on 21 July 2025, set a hospital deadline of 30 September 2025 and a deadline of 31 December 2026 for other inpatient, day and outpatient facilities, and requires records to be linked to the patient's personal identification number.
What happens to paper records created before the EMR?
Circular 13 allows paper records created before 21 July 2025 to continue to be used or to be converted to digital form, in line with government data conversion requirements.
How does Vietnam's Personal Data Protection Law affect health data?
Law 91/2025/QH15, in effect from 1 January 2026, treats health information as sensitive personal data. It requires data processing impact assessments, controls cross-border transfers, bans trading in personal data, and sets significant penalties.
Is an EMR alone enough to be ready?
An EMR is the foundation, but the records inside it also need to be consistent and complete. Historical records, results from other facilities and data kept in older systems all need a plan if they are to be useful in the new system.
Book a free 30-minute data readiness conversation
Tell us about your hospital or clinic group, where your records sit today and what you want the EMR to hold, and we will talk through where you stand and the most sensible next step before 2027. There is no obligation, and you will leave with a clearer picture either way.
Ministry of Health, Circular 13/2025/TT-BYT (via LuatVietnam); Ministry of Health directive on electronic medical records (via vietnam.vn); Law 91/2025/QH15 on Personal Data Protection (via Rouse); Healthcare IT News. This article is for general information and is not legal advice.
