Submarine Cables in the South China Sea: Across-Domain & Across-Level Vulnerabilities
 
Submarine cables’ relevance to Vietnam
 
Vietnam’s current national interests[1], as defined in the 14th National Party Congress, can be summarized in three points according to popular strategic thinking[2], all of which are potentially related to Vietnam’s submarine cables system in the South China Sea.
 
First, Vietnam wants to preserve its independence, sovereignty, and territorial integrity. Vietnam’s geography requires taking regional submarine cables into security considerations, as Vietnam is situated along a major east-west sea line of communications in the South China Sea, linking Northeast Asia to the Indian Ocean via the Malacca Strait[3].  The current South China Sea disputes and big powers’ competitions, leading to the growing trends of “decoupling” in technology, unilateralism, and gray-zone tactics, can put Vietnam under increasing security risks (to be addressed), subsequently reinforcing Vietnam’s need to protect its submarine cables.
 
Second, Vietnam aims to maintain a peaceful environment conducive for national development. In the long term, Vietnam, with a coastline of over 3,000 km, is gearing towards becoming a maritime economy with a comprehensive approach to maritime governance, visibly seen via its Resolution 36-NQ/TW (October 22, 2018) on the Strategy for the Sustainable Development of Vietnam’s Marine Economy[4] and Resolution 139/2024/QH15 on the National Marine Spatial Plan[5]. Submarine cables, running through Vietnam’s waters and landing on its coastlines, and as a part of marine infrastructure in Vietnam’s marine spatial planning, are indispensable in this regard.
 
In the short term, Vietnam is aiming for an 8% GDP growth in 2025, in which all Blue Economy-related industries reportedly occupy over 40%[6]. Vietnam also aims to become a digital nation by 2030, with the digital economy contributing 30% of GDP (and reaching 50% of GDP by 2045), and digitalization being the main driver for its modernization and industrialization[7]. With the vast majority of intercontinental data traffic, up to more than 90%, is transmitted through submarine cables[8], securing regional submarine cables is foundational for Vietnam to achieve these economic targets.
 
Third, Vietnam seeks to promote its international standing, reinforcing its image as a responsible and active stakeholder in international affairs, promoting the rule of law, multilateralism, and peaceful dispute resolution.  These priorities can be demonstrated via its principles in the South China Sea disputes management[9] and the Vietnam Law of the Sea[10] (2012), based on UNCLOS 1982, which in turn help contribute to the international legal framework that helps govern submarine cables. Vietnam can also use international forums dedicated to submarine cables, such as the International Cable Protection Committee (ICPC) or ASEAN’s working groups on cables[11], to show its activeness in foreign affairs.
 
Vulnerabilities from multiple fronts
The writing employs a three-level analysis framework to describe the risks, both materalized and potential ones, to Vietnam’s submarine cables in the South China Sea.
 
First, at the system level, the strategic-technical risks can stem from big powers’ rivalry, which intensifies the so-called “decoupling” or “derisking” in the economic domain. This trend can result in further pressure of taking side for smaller countries like Vietnam, including with submarine cables. For instance, the U.S.’ executive branch, including the Trump 2.0 administration, has been reportedly making efforts to “disconnect” its cable network from China’s by promoting its own “Clean Network” initiative[12], intervening to outbid China’s operators in cable projects like SeaMeWe-6[13], or introducing new Federal Communications Commission (FCC)’s rule to prevent cables connected to “adversaries” from landing in the U.S or to disqualify any cable projects related to “adversaries”[14]. The U.S.’s legislative branch is on par, with its House of Representative introducing multiple submarine cables-related acts from 2023 to 2025, aiming at separating U.S. cables and services from those of “foreign adversaries”[15] (mostly referring to China and Russia). From China’s side, China has been allegedly tightening licensing for international cable projects as a way to gain leverage over competitors in the maritime domain[16]. Such deepening U.S.–China separation in submarine cables can push smaller countries, especially when those whose cables are connected to both China and the U.S., closer to cable/technological isolation and dependence if they have to take one side over another[17].
 
The risks at system level also arise from the existing international law framework. The current legal framework on submarine cables itself is not complete. The United Nations’ Convention on the Law of the Sea (UNCLOS) 1982, often cited as the “Constitution” of the oceans, does cover submarine cables and installations[18], granting all states the freedom/right to lay and repair cables. However, in practice, cables are usually repaired by private companies[19] instead of states, the subject of UNCLOS. In addition, Vietnam’s submarine cables are transnational, running across different maritime zones of different coastal states[20], which UNCLOS does not address and might require extra international coordination, hindering the protection duty on the ground. For example, when Vietnam’s Asia Pacific Gateway (APG) cable was disrupted in 2023 (on the branch S6 going to Hong Kong), the original repair plan was postponed partly due to the fact that the cable routes and repair ships all belonged to different operators in different countries and territories[21].
 
In terms of legal compliance, many troubles can be counted for in general, including in the South China Sea. Submarine cable offences are difficult to prosecute. Coastal states have only limited jurisdiction in the areas beyond territorial sovereignty, where breakages usually happen. The flag states can exercise that authority but are usually reluctant to do so[22]. Some have pointed to the International Cable Protection Committee (ICPC) as an organization to help enforce UNCLOS and protection of cables, but ICPC only provides guidance, best practices and suggestions[23], thereby not able to ensure compliance. Others have pointed to the 1884 Paris Convention for the Protection of Submarine Telegraphic Cable, as the Convention applies to all maritime areas beyond territorial waters[24], but there have only been 36 parties to the Convention, excluding Vietnam, and the Convention itself is outdated.  
 
Second, at the state level, from the strategic side, the South China Sea disputes can exacerbate cable risks. As the disputes have become increasingly complex, naval activities there have increased on the surface, raising chances of accidents or miscalculation[25], including the scenarios of communication channels being cut off. Under the surface, destroying critical infrastructure, such as submarine cables, has been labeled as a part of the potential “gray zone” or mixed warfare tactics[26]. In the past few years, the cases of cable disruptions near Yemen during the Red Sea crisis[27], in Baltic Sea during the Russia-Ukraine conflict[28], or around Taiwan[29], etc. can be said to be examples of probable cable sabotage for political purposes, which can be replicated in the South China Sea.
 
Additionally, “gray zone” tactics can also be conducted in a less confrontational method. Reportedly, China has been tightening licensing for international cables as a way to reinforce its authority in the “nine-dash line” claim[30], potentially linking to the years-long delays of some Vietnam-linked projects, such as the Southeast Asia-Japan 2 (SJC2) and the Asia Direct Cable (ADC) routes.
 
From the legal side, coastal states’ different regulation practices can hinder cable connectivity. There has not been a universal definition of “critical infrastructure” in international law itself, consequently leading to a lack of universal protection. A survey has concluded that among 194 actors (193 UN members and Taiwan), 94 have not defined this concept[31]. In Vietnam’s case specifically, Vietnam’s Ministry of Construction has introduced Circular No. 06/2021/TT-BXD, which classifies multinational telecommunications lines as the construction of highest level of importance[32], but the country has not defined which infrastructure it considers critical officially. For the countries who have done so, another study shows that there are still 5% who do not consider information and communications technology, including submarine cables, as critical[33].
 
Third, at the below state or business level, from the technical perspective, Vietnam lacks the needed capacity. Capacity obstacles to Vietnam’s cables include co-ordination issues with foreign partners of cable operators (especially when all Vietnam’s cables are international, many of which are getting old), a lack of domestic repair service and repair dependence on foreign consortium. These limits were visible in the repair delay during the Asia-Africa-Europe 1 (AAE-1) shunt case in 2022[34] and the IA route disruption case in 2023[35]. Moreover, Vietnam has also faced oversight issues, notably in the Thailand-Vietnam-Hong Kong (TVH) route theft case in 2007 (around 100 km went missing)[36]. The Asia-America Gateway (AAG) route disruption case in 2014 also reportedly pointed to Vietnam’s lack of surveys in the cable designing stage, according to an industry expert[37].
 
Moreover, rising geopolitical tensions can make it harder for foreign businesses to cooperate with Vietnamese ones on cable connectivity. Several big tech companies, such as Google and Meta, have allegedly diverted their route planning from the South China Sea due to the maritime disputes, notably with the Apricot and Bifrost cable projects[38]. This trend might have political implications as well, if it leads to a reduced strategic interest/attention in the South China Sea or an implicit acknowledgement of a certain party’s maritime claims.
 
The above-mentioned threats across the three levels do not exist independently but can also intertwine. The big powers’ decoupling can be more concrete with undersea cables in the future, in parallel with the increasing weaponization of infrastructure, when the legal and technical limits in cable governance are exploited. Indirectly, a “grand bargaining” in the Pacific, related to the Trump administration’s reference to the “Donroe Doctrine” in its 2026 National Defense Strategy and recent military operations in other hot spots, or a conflict scenario in the South China Sea due to China – Philippines clashes on the ground, regardless of their likelihood, can also be damaging to regional stability in general and cable security in particular.
 
The way forward
 
It is worth mentioning that there are a few “mitigating factors” to take into consideration. To start, the impact of US-China competition on Vietnam’s cables may not be too severe in the short term, as the decoupling legislations could be symbolic gestures (with some of them dating back to 2022-23 and still pending). Other ASEAN countries, such as Singapore, Indonesia, and Malaysia, and even some U.S. allies are all pursuing cooperation projects with both big powers. For example, South Korea's largest submarine cable company, KT, still maintains cable routes with China[39]. Additionally, as cables become more “securitized”, connectivity initiatives led by the “third option” also emerges. For example, Australia has announced its Cable Connectivity & Resilience Centre, or the European Union has transformed its Enhancing Security Cooperation in & with Asia (ESIWA) program into the ESIWA+ to include submarine cable cooperation. Thirdly, there have been more efforts to “commonize” cable governance within ASEAN, including Malaysia’s 2024 relaxation of its “cabotage law”, and the ASEAN Digital Masterplan 2025 (which refers to the 2019 Guidelines on Submarine Cables). At last year’s Sharing-La Dialogue, officials from New Zealand, France and Japan, etc. all spoke on the importance of undersea cables, indicating growing awareness on this frontier.
 
Regardless, Vietnam has been pursuing multiple lines of efforts in the submarine cables domain, which might help mitigate the abovementioned risks.
 
On the political-strategic side, Vietnam promotes diversification of cable partnerships in all stages of cable operation, including planning/routing and maintenance/repairing, etc. For example, Vietnam launched its plan for the 6th international cable route in 2024 (with Singapore), aiming for 10 international cables in total by 2030[40]. The Vietnam – Singapore project is also the first bilateral project for Vietnam, indicating Vietnam’s desire for stronger domestic capacity.
 
On the legal-governance side, Vietnam relies on international law/the rule of law to preserve its maritime interests in the South China Sea, indirectly warding off cable instability. For example, bilaterally, Vietnam has creatively sought delimitation, settlement and cooperation where possible with disputing parties, yielding practical results, such as: the Gulf of Tonkin delimitation and shared fishing zone with China[41]; the JOMSRE cooperation with the Philippines[42]; the delimitation of the Gulf of Thailand[43]; the EEZ agreement with Indonesia[44]; the joint continental shelf submission with Malaysia[45], etc. Within the ASEAN, Vietnam actively supports subforums like ADMM and ADMM-Plus, promoting maritime confidence-building, joint drills, and defense dialogues in line with international law. Vietnam also supports the full and effective implementation of the DOC and the negotiation of a substantive COC not affecting third parties’ interests[46].
 
More directly, Vietnam promotes common cable governance and best practices. With partners, Vietnam proposed mechanisms such as the ASEAN Guidelines for Strengthening Resilience and Repair of Submarine Cables in 2019[47], and has joined the ICPC (although the membership is still limited). Additionally, International Telecommunication Union (ITU) recommendations regarding cable are carefully observed by Vietnam agencies.
 
Internally, Vietnam pursues a more streamlined cable licensing and protection process, helping Vietnam strengthen its own capacity, in line with its independence foreign policy tradition. As mentioned, Vietnam has not designated submarine cables as “critical infrastructure”, but multinational telecommunications lines, including cables, have been classified in domestic regulations as the construction of highest level of importance. Vietnam laws also suggest that enterprises are encouraged or have the “priority” to install and operate telecom projects on the seabed. Moreover, Vietnam adopts a whole-of-government approach by involving multiple agencies in the processes of issuing permits, laying, maintenance and protection of submarine cables. Main stakeholders include the Ministry of Information and Communications (MIC), the Ministry of National Defense (MND), the Ministry of Foreign Affairs (MFA), the Ministry of Public Security (MPS), the Ministry of Natural Resources (MONRE), etc[48]. In response to potential undersea cable disruptions, Vietnam has been introducing new domestic laws, including: (i) simplifying landing procedures to make connection and repairment easier[49]; (ii) encouraging digital innovation to improve data transmission[50]; (iii) expanding the number of cable routes, partners and landing stations; (iv) introducing tighter legal frameworks to criminalize offences to cables or put cables in the top infrastructure priorities[51].
 
In conclusion, submarine cables play an important role to Vietnam’s national interests, including economic development, territorial integrity protection and international reputation enhancement, among others. However, Vietnam’s cable system in the South China Sea is susceptible to threats across the system, state and below-state levels, stemming from strategic competition, limits in current legal frameworks, increasingly complex maritime disputes and gray-zone tactics, as well as restrained technical capability. To help address this problem, Vietnam’s efforts include cable diversification, resilience strengthening, and governance promotion in line with the rule of law, with international cooperation being a key component across the board.
 
Hoang DO
School of Political Science & International Studies, the University of Queensland
This article was first published in the Council for Security Cooperation in the Asia Pacific's 2026 Regional OutlookAll views expressed herewith are solely of the author
 
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[12] https://2017-2021.state.gov/announcing-the-expansion-of-the-clean-network-to-safeguard-americas-assets/index.html
[13] https://www.reuters.com/investigates/special-report/us-china-tech-cables/.
[14] https://docs.fcc.gov/public/attachments/DOC-413550A1.pdf
[15] https://www.congress.gov/bill/118th-congress/house-bill/1189/text; https://www.congress.gov/bill/119th-congress/house-bill/2503
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[18] To be specific, first, in maritime zones within territorial sovereignty, coastal states have the right to enact regulations to protect cables, including the right to regulate innocent passage to protect its cables. Additionally, archipelagic states should allow the maintenance (which can aid protection) of cables passing through their archipelagic waters but laid by other states, according to Article 51.2. Second, in the EEZ, cable protection is not a legal obligation of states, but states laying cables in another state's EEZ shall comply with the laws and regulations adopted by the coastal state (including regulations aimed at protecting coastal states’ infrastructure). Article 58 says that all states also enjoy the freedoms associated with the operation of cables, which can include cable protection. Third, in the continental shelf, coastal states may not impede the maintenance of cables when conducting exploration. Fourth, in the high seas, states shall have “due regard” to cables already in position and avoid prejudicing possibilities of repairing existing cables or pipelines. Article 113 requires states to adopt laws and regulations to regulate the breaking or injury of submarine cables.
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[22] https://hrcak.srce.hr/file/457744
[23] https://www.iscpc.org/information/frequently-asked-questions/
[24] The 1884 Paris Convention defines what can be considered an “offence” to cables outside the territorial waters of states in its Article 2. To prevent such offences, the Convention puts forward multiple solutions, such as asking parties to use proper safety measures on granting a concession for landing cables in Article 3, asking cable’s owner to bear the cost of damage in Article 4, asking vessels to avoid collisions or keep fishing nets at safe distance from cable-repairing ships in Article 5, etc.
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[28] https://www.theguardian.com/world/2024/nov/18/telecoms-cable-in-baltic-sea-may-have-been-severed-says-finnish-owner.
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