New child car seat regulations effective from July 01 2026

Effective from 1 July 2026, Vietnam’s regulations on child restraint systems in automobiles will officially take effect and may directly impact companies operating employee shuttle vehicles or transportation services for employees’ children. Many business owners are asking whether company vehicles are required to be equipped with child seats and, where transportation services are outsourced, which party bears the legal responsibility for compliance. 

This article provides practical guidance on the legal obligations applicable to different categories of vehicles, helping businesses accurately determine their compliance responsibilities, proactively prepare for implementation, and minimize the risk of regulatory violations. 

1. Details of the new regulations on child restraint systems in automobiles  

Vietnam’s legal framework on road traffic safety continues to evolve in line with international standards, particularly with respect to the protection of vulnerable road users such as children. 

Specifically, pursuant to Clause 3 Article 10 of the Law on Road Traffic Order and Safety 2024, as amended by Clause 3 Article 7 of the Law Amending Ten Laws Relating to Security and Public Order 2025, a new mandatory requirement for drivers will take effect from 1 July 2026: 

• Applicable subjects: Children under 10 years of age and under 1.35 meters in height when travelling in an automobile. 

• Driver’s obligation: Drivers must use, and instruct the proper use of, appropriate child restraint systems or other suitable child safety devices. 

• Exemption: This requirement does not apply to automobiles used for passenger transport business operations. 

Accordingly, from the effective date of the law, transporting a child under 10 years of age and under 1.35 meters in height in a vehicle that does not fall within the passenger transport business category without providing and using an appropriate child safety device may constitute a violation of the law and may be subject to the applicable administrative penalties. 

2. What constitutes a legally compliant child restrain system? 

To facilitate the implementation of the above requirement, the Ministry of Transport has issued detailed technical standards to clearly identify the types of child safety devices that qualify under the law. Pursuant to Section 1.3.1 of QCVN 123:2024/BGTVT (National Technical Regulation on Child Restraint Systems for Use in Motor Vehicles), a child restraint system is defined as a device designed to ensure the safety of a child while seated or lying down in a motor vehicle. 

. The purpose of such a device is to minimize the risk of injury in the event of a traffic collision or sudden braking/deceleration by restraining the movement of the child’s body. 

From a technical perspective, child restraint systems generally fall into the following categories: 

• Child Restraint System (CRS): A conventional child restraint system designed to secure a child in place and attached to the vehicle seat using seat belts or dedicated anchorage points. 

• Enhanced Child Restraint System (ECRS): An advanced child restraint system that typically incorporates modern anchorage technologies, such as ISOFIX, to improve positioning stability and provide enhanced protection, particularly in side-impact collisions. 

In practice, devices that comply with the technical requirements prescribed under QCVN 123:2024/BGTVT are commonly referred to as “child car seats” or “child safety seats.” When purchasing and installing such equipment, both businesses and individuals should verify that the products possess the required conformity certifications and comply with the applicable technical standards to ensure legal compliance. 

3. Assesment of compliance obligations for companies shuttle vehicles  

For companies operating vehicles to transport employees and/or employees’ children, whether child restraint systems must be installed depends on the legal nature of the vehicles being used. In practice, the analysis generally falls into the following scenarios: 

3.1. Scenario 1: Vehicles owned and operated internally by the company  

This scenario applies where the company purchases vehicles itself, or lawfully leases vehicles from another organization or individual, for the sole purpose of transporting employees and their children as part of the company’s internal transportation arrangements, without charging fares or generating transportation revenue. 

To lawfully operate under this model, the company must comply with the requirements set out in Clause 1 Article 24 of Decree No. 158/2024/ND-CP regarding internal passenger transportation by automobile. Among other requirements, the vehicles must clearly display the words “INTERNAL VEHICLE” on both the front and rear windshields. 

• Legal implication: Once properly identified and operated as internal vehicles, such vehicles do not fall within any category of passenger transport business as defined under Clause 6 Article 56 of the Law on Roads 2024. 

• Compliance obligation: As these vehicles do not qualify for the statutory exemption, from 1 July 2026, where they transport children falling within the prescribed category (i.e., children under 10 years of age and under 1.35 meters in height), the company will be required to install and use child restraint systems that comply with the technical requirements set out in QCVN 123:2024/BGTVT. 

3.2. Scenario 2: The company outsources transportation services to a third-party transport operator 

As part of cost-optimization strategies, many companies choose to engage a professional transportation provider under a service contract to transport employees and their children. 

• Legal implication: The third-party transportation provider must be a duly established legal entity holding a valid license for passenger transportation by automobile issued by the competent authority. In addition, the vehicles used for such services must be issued with a “CONTRACT VEHICLE” badge. In this case, the vehicles are clearly classified as passenger transport business vehicles in accordance with Article 7 of Decree No. 158/2024/ND-CP. 

• Compliance obligation: Based on the exemption set out in Clause 3 Article 10 of the Law on Road Traffic Order and Safety 2024, passenger transport vehicles operating under transportation service contracts are not required to install child restraint systems. Accordingly, a company that engages such transportation services would generally not bear a legal obligation to equip the vehicles with child car seats or other dedicated child restraint systems. 

Conclusion:  

Compliance with the new requirements on child restraint systems in automobiles, effective from 1 July 2026, is both a mandatory legal obligation and an important safety measure that businesses should address proactively. Companies should review their current transportation arrangements to determine whether the new requirements apply to their operations. 

Where a company operates its own internal vehicles, it should promptly plan the necessary budget and implement the installation of child restraint systems that comply with QCVN 123:2024/BGTVT. Taking timely action will not only help ensure compliance with applicable laws but also enhance the safety of employees’ children during transportation. 

Conversely, where transportation services are outsourced to a third-party provider, companies should carefully verify the provider’s legal status, transportation business licenses, and operational qualifications. Conducting appropriate due diligence on transportation partners can help protect the company’s interests and minimize potential legal and operational risks arising from the provision of such services. 

Submission date: 20/06/2026

See more: Equipping Child Safety Devices on School Shuttle Buses: New Regulations 2026

Disclaimers:

This article is for general information purposes only and is not intended to provide any legal advice for any particular case. The legal provisions referenced in the content are in effect at the time of publication but may have expired at the time you read the content. We therefore advise that you always consult a professional consultant before applying any content.

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Apolat Legal is a law firm in Vietnam with experience and capacity to provide consulting services related to Business and Investment and contact our team of lawyers in Vietnam via email info@apolatlegal.com.

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