Prohibited conduct in Public Bidding: A Comparative Legal analysis of Vietnam and Japan

Public bidding is a core mechanism of public procurement that promotes efficient resource allocation, transparency, and competition. However, bidding processes are highly vulnerable to corruption, collusion, and other prohibited practices that distort market outcomes and erode public trust. This study conducts a comparative legal analysis of the regulation of prohibited acts in bidding activities in Vietnam and Japan. Using doctrinal and comparative legal methodologies, it examines statutory frameworks, enforcement mechanisms, and institutional practices under Vietnam’s Law on Bidding 2023 and Japan’s competition-oriented regime, particularly the Anti-Monopoly Act and the Act on Elimination and Prevention of Involvement in Bid Rigging. The findings reveal that Vietnam adopts a detailed, enumerative legislative approach, while Japan relies on principle-based competition law supplemented by specialized anti-collusion statutes and independent enforcement authorities. Although both systems seek to ensure bidding integrity, their regulatory differences reflect distinct legal traditions and governance priorities