Regulatory Policies for The Sharing Economy in The Digital Era: International Experience and Lessons for Vietnam

Abstract: The development of digital platforms has transformed the sharing economy from a mechanism for matching underutilized assets or capacity into a market structure in which platform enterprises can establish rules, process data, set prices, allocate transactions, rank participants, and restrict access. This study addresses three questions: which combinations of regulatory instruments are employed in the selected jurisdictions; what are the advantages, limitations, and institutional conditions of each combination; and which elements Vietnam may adopt after the 2025 Law on E-Commerce entered into force. The study applies a structured institutional comparison to the European Union, the United States, China, Singapore, and Australia. Its sources comprise selected academic studies, official legal and policy documents, and statistical evidence reviewed through 12 July 2026. The findings identify five combinations of regulatory instruments: multilevel regulation based on rights, risks, and data; decentralized experimentation at state and municipal levels; direct administrative regulation of data and algorithms; targeted protection linked to social security; and the establishment of minimum standards through industrial-relations institutions. The study further demonstrates that no model is optimal in every context; transferability depends on data capacity, decentralization, labour relations, and mechanisms for constraining public and private power. Its contribution lies in integrating sharing-economy regulation, platform governance, digital labour, data, algorithms, and competition within a comparative matrix. For Vietnam, the study proposes a three-tier policy architecture comprising general platform obligations, sector-specific regulation, and evaluated adaptive mechanisms, implemented through six groups of measures directly linked to the identified gaps.