Scenario: a platform lets spas and salons list services; customers book appointments and buy beauty vouchers through it; the platform takes commission per transaction. The owner wonders: is this an “e-commerce trading floor” needing registration, or just a service website?
Sales websites vs e-commerce trading floors
Vietnamese e-commerce law distinguishes two website types. E-commerce sales websites: traders’ own sites serving their own goods trading and service provision — e.g., a spa’s website selling its own vouchers. E-commerce trading floors: websites letting other traders, organisations and individuals conduct part or all of goods-trading or service-provision processes on them — e.g., a platform where hundreds of independent spas list and take bookings. The core distinction: trading floors host multiple independent sellers transacting through the platform; sales websites have a single seller — the site owner. In the scenario above, a platform hosting many spas and taking per-transaction commission is an e-commerce trading floor.
Trading floors: registration duties and liability
Trading floors face the strictest regulation in the e-commerce ecosystem. Under e-commerce rules (Decrees 52/2013/ND-CP and 85/2021/ND-CP — expired 1 July 2026 — now the E-Commerce Law 122/2025/QH15 effective 1 July 2026 with Decree 248/2026/ND-CP), trading-floor operators must complete notification and registration with the Ministry of Industry and Trade and observe extensive duties: building and publishing operating regulations; verifying seller identities (VNeID verification under Law 122/2025/QH15); monitoring and requiring seller legal compliance; removing violating content and goods upon discovery; storing transaction information; cooperating with authorities. Operating an unregistered “floor” draws administrative fines and forced termination — while still bearing floor-level liability.
Service-floor specifics: bookings and vouchers
Service floors (medical bookings, spas, dining and travel vouchers) need tailored operating regulations: services are intangible, quality depending on providers — regulations must define provider liability, rating and complaint mechanisms; vouchers are future-service instruments — needing rules on validity periods and refunds when vouchers expire or providers close; bookings involve personal data (health information for medical bookings) — requiring data-protection compliance. Many booking platforms dodge the “floor” label by calling themselves “management software” — but regulators examine activity substance, not labels.
Frequently asked questions
An appointment app for one’s own spa chain — a trading floor?
No, where serving only that trader’s own sales and services — that is an e-commerce sales website or app with simpler procedures (sales-website notification). Only hosting other independent sellers’ transactions makes a floor.
A platform only lists ads, no on-platform payments?
It may still be a floor where it lets parties conduct part of transaction processes (listing, booking are process parts). Commission or membership fees are not the sole criterion — the substance of “letting others transact on the platform” decides.
Must service floors check providers’ licences?
Yes, within reasonable scope: for conditional services (healthcare, education, transport), floors must require provider licences and refuse unqualified listings — otherwise facing potential joint liability in incidents.
This article has been quality-reviewed by the FLAW AI Legal Council.