Objectives: The objective of this paper is to provide an analysis of the medicine pricing policies in Vietnam. These policies are reflected in legislation and associated governmental administrative instruments. Methods: All the legislation and sub-legislation such as laws, ordinances, decrees, and circulars relating to medicine pricing policies in the period of health reform from 1989 to March 2008 and the policy context were examined using a documentary analysis. The analysis was constructed around the three components of the policy cycle: policy formulation, implementation and accountability. Results: The Vietnamese Government has sought to limit inappropriate increases in medicine prices through legislation designed to ensure public access to essential medicines. The principal legislative mechanism has been one of transparent declaration and publication of medicine prices. The most progressive regulation has been Joint Circular No.11/2007/TTLT-BYT-BTC-BCT, which controls the wholesale mark-ups in the medicine supply chain through the declaration of a reasonable wholesale price to the Ministry of Health. These marked legislative changes have yet to reach their full potential because some administrative prerequisite elements have yet to be implemented. Conclusions: Analysis of the regulatory reforms demonstrates that Vietnam medicine pricing regulations have become increasingly sophisticated. While appropriate legislation is pivotal to control medicine prices, it is an insufficient mechanism alone to achieve the level of change required. Enforcement of legislation at the administrative level is also of critical importance, as is ongoing monitoring of legislative effects including the socio-economic factors affecting prices. More work is needed to ensure reasonable prices of medicines in Vietnam.