These findings emerge from a comparative study of seven jurisdictions, offering insights into sequencing priorities as Vietnam opens airspace that is under 1,000 meters for drones, logistics, and urban air mobility.

The "low-altitude economy" encompasses economic activities in airspace below 1,000 meters, ranging from drone deliveries, agricultural monitoring, and search-and-rescue operations to passenger air taxis - currently pursued by numerous governments as an emerging industry.

In Vietnam, this concept gained significant traction across policy forums in late 2025. The comparative study, which aligned domestic legal-technical frameworks with actual deployment data as of July 2026, said that treating foreign models as "fully matured standards ready for duplication" represents an oversimplification that could lead Vietnam to misstep in its sequencing.

No model is fully mature

On December 27, 2025, China passed the amended Civil Aviation Law comprising 16 chapters and 262 articles, including a dedicated chapter on promoting the “low-altitude economy.” The law took effect on July 1, 2026.

However, the unified legislation came only days after domestic media had described China's drone regulatory system as a patchwork of fragmented provincial regulations.

In the US, as of mid-2026, the draft Part 108 rule had missed two deadlines set by law and an executive order and is still undergoing final review, with issuance expected in late 2026 or 2027.

Europe provides the clearest example of the gap between regulatory design and implementation. The EU adopted U-space regulations in 2021, establishing a tiered risk-based model for services. Yet five years later, only one officially operational U-space area existed across Europe, in San Salvo, Italy.

Looking across all seven jurisdictions, the study identified a common pattern: regardless of wealth or institutional capacity, actual implementation by mid-2026 was slower than each jurisdiction's own roadmap, with five of the seven cases falling at least one year behind schedule. 

Vietnam roadmap

Vietnam's regulatory framework for low-altitude airspace has developed rapidly but in a fragmented manner. In just 13 months, from the People's Air Defense Law taking effect on July 1, 2025, to Decree 288/2025 on unmanned aircraft management, Decree 33/2025 on controlled mechanisms (sandbox) and the amended Civil Aviation Law taking effect on July 1, 2026, low-altitude airspace governance has been distributed across at least four major legal documents overseen by at least three ministries, reflecting different institutional origins: national defense, science, technology and innovation, and civil aviation.

Vietnam's foundational framework originated from the People's Air Defense Law rather than civil aviation law, as is the case in most comparator jurisdictions. And under the amended Civil Aviation Law, the Vietnam Aviation Authority (under the Ministry of Construction) - the state management agency equivalent to CAAS in Singapore or CAAT in Thailand - officially separates from the Aviation Security Authority (under Ministry of Public Security). This is a different starting point, entailing more complex civil-security coordination requirements.

Vietnam has recorded an encouraging practical development. On June 23, 2026, the Dien Bien provincial People's Committee issued the country's first sandbox approval for a UAV application in the low-altitude economy, targeting around 6,000 test flights through May 2027 in four areas: agriculture, logistics in remote areas, medical transportation, and digital mapping, with a safety target of more than 99 percent. Nearly 10 other localities subsequently expressed willingness to adopt a similar model.

Based on the comparative evidence, researchers have proposed a three-stage roadmap for Vietnam rather than copying any single country's model wholesale.

Stage 1: Narrow, high-value pilots (short term): Prioritize applications with clear demand, low investment requirements and relatively low regulatory complexity, such as agriculture, medical logistics and search-and-rescue operations, before moving to passenger air taxis. This is essentially the approach already chosen by Dien Bien. The next step is to formalize and deliberately scale up the model, while learning from Singapore's gradual expansion of licensing.

Stage 2: Build data infrastructure (medium term): Establish a shared information service or centralized data center for the whole sector, alongside a clear inter-ministerial coordination mechanism involving the Ministry of Construction, Ministry of National Defense, Ministry of Public Security, and Ministry of Science and Technology. This should address gaps in third-party liability insurance.

Stage 3: Risk-managed urban air mobility (long term). Passenger air-taxi corridors should be treated as a long-term investment commitment only after sufficient safety and financial evidence has been established through the first two stages. This would be similar to South Korea's decision to prioritize cargo transportation over passenger services for safety reasons.

Ho Tuan Sy