LEGAL UPDATE RELATING TO FINANCE AND CREDIT (MONTHLY LEGAL UPDATE – 01/2026)

1. Legal documents are issued in 12/2025

1.1. Consolidated Document No. 28/VBHN-NHNN on payment agency activities

• Name of legal document: Consolidated Document No. 28/VBHN-NHNN issued on 08/12/2025 by the State Bank of Vietnam on payment agency activities.
• Consolidation date: 08/12/2025.

The content should be noted: This document consolidates Circular No. 07/2024/TT-NHNN dated 21/6/2024 of the Governor of the State Bank of Vietnam on payment agency activities; Circular No. 06/2025/TT-NHNN dated 30/5/2025 of the Governor of the State Bank of Vietnam amending and supplementing Clause 7 Article 7 of Circular No. 07/2024/TT-NHNN dated 21/6/2024 on payment agency activities; and Circular No. 44/2025/TT-NHNN dated 18/11/2025 of the Governor of the State Bank of Vietnam amending and supplementing a number of articles of Circular No. 07/2024/TT-NHNN on payment agency activities.

1.2. Consolidated Document No. 29/VBHN-NHNN on the provision of intermediary payment services

• Name of legal document: Consolidated Document No. 29/VBHN-NHNN issued on 08/12/2025 by the State Bank of Vietnam on the provision of intermediary payment services.
• Consolidation date: 08/12/2025.

The content should be noted: This document consolidates Circular No. 40/2024/TT-NHNN issued on 17/07/2024 of the Governor of the State Bank of Vietnam on the provision of intermediary payment services and Circular No. 41/2025/TT-NHNN issued on 05/11/2025 of the Governor of the State Bank of Vietnam amending and supplementing a number of articles of Circular No. 40/2024/TT-NHNN on the provision of intermediary payment services.

1.3. Decision No. 1814/QD-KTNN on promulgating guidance on the risk-based audit approach and the determination of materiality in audits of banks’ financial statements

• Name of legal document: Decision No. 1814/QD-KTNN issued on 16/12/2025 by the State Auditor General on promulgating guidance on the risk-based audit approach and the determination of materiality in audits of banks’ financial statements (hereinafter referred to as “Decision No. 1814/QD-KTNN”).
• Effective date: 16/12/2025.

The content should be noted: Identification and assessment of the risks of material misstatement.

Specifically, Article 3 of the Guidance on the risk-based audit approach and the determination of materiality in audits of banks’ financial statements promulgated together with Decision No. 1814/QD-KTNN provides as follows: “Article 3. Identification and assessment of the risks of material misstatement

1. Based on information on banks and other credit institutions (hereinafter collectively referred to as banks) collected from the survey outline for information collection and other information-gathering methods (interviews, requests for document submission, discussions with the audited entity, mass media, etc.), information from other relevant entities (banking regulators, customers having credit relationships with banks, etc.), and information from previous audits (if any), State Auditors shall assess inherent risk and control risk in accordance with the banks’ operational conditions in order to design appropriate audit procedures to achieve audit objectives.
2. State Auditors shall identify and assess the risks of material misstatement at the level of banks’ financial statements and at the assertion level (transaction classes, account balances, and disclosures). State Auditors shall refer to the method for determining the level of risks of material misstatement provided in Appendix No. 01/RRTY-NH enclosed with this Guidance to draw conclusions on the risks of material misstatement. Certain risk indicators to be noted in the assessment include:a) Risks of material misstatement at the financial statement level

• • Risks arising from banks’ fields of operation; or changes in organizational structure and operational characteristics of banks, such as restructuring/reorganization of banks, or changes in the scope and fields of operation of banks;
  • New legal regulations and policies related to banking operations, such as preferential credit programs, capital mobilization regulations, interest rate subsidy programs, regulations on loan classification and provisioning for credit risk, or risks arising from the external business environment (objective and force majeure factors such as natural disasters and epidemics affecting banks’ operations and services);
  • Complex internal control systems and geographically dispersed operations; changes or shortages in senior management personnel; supervisory, control, and internal audit staff lacking appropriate professional qualifications; inspection and control activities that are infrequent or ineffective; management override of internal controls (interference with information technology systems, data collection and processing, accounting and preparation of banks’ financial statements, adjustment of ratios and amounts of credit risk provisions); information technology governance creating vulnerabilities or being inconsistent with banks’ characteristics and business processes;b) Risks of material misstatement at the assertion level

• • Income items: Recognition of income in incorrect periods (under-recognition of accrued interest, failure to allocate guarantee fees/letters of credit issuance fees, etc.); failure to recognize income from payment services; income relating to liabilities with unidentified creditors;
  • Expense items: Inappropriate calculation and recognition of provision expenses due to loan reclassification, increase/decrease in ratios/values of deductible collateral; payment of interest on mobilized capital and operating expenses not in compliance with regulations;
  • Tax and amounts payable to the State: Under-declaration and under-recognition of taxes and amounts payable to the State (incorrect application of tax rates, improper declaration of deductible VAT, failure to exclude non-business-related expenses incurred during the period when calculating corporate income tax);
  • Financial investment items: Failure to maintain detailed tracking of each type of security and each capital contribution investment by banks in finance companies/other enterprises; provisioning not in accordance with regulations;
  • Customer loan items: Improper loan classification and credit risk provisioning in violation of State Bank of Vietnam regulations and banks’ internal regulations; inappropriate determination of ratios/values of deductible collateral; improper debt handling;
  • Fixed assets (FA) and tools and equipment (TE): Recognition of fixed assets that do not meet recognition criteria; untimely capitalization of fixed assets; inaccurate depreciation; inappropriate classification between fixed assets and tools and equipment; improper allocation of tool and equipment costs.”

1.4. Decision No. 3925/QD-NHNN on the standardization of the list of administrative procedures within the scope of the State Bank of Vietnam’s management functions

• Name of legal document: Decision No. 3925/QD-NHNN issued on 16/12/2025 on the standardization of the list of administrative procedures within the scope of the State Bank of Vietnam’s management functions.
• Effective date: 16/12/2025.

The content should be noted: Abolition of the procedure for reporting newly issued card service fee schedules or amendments and supplements thereto, as listed in the Appendix on the list of abolished administrative procedures in the fields of banking establishment and operation, monetary activities, credit activities, and payment activities within the scope of the State Bank of Vietnam’s management functions promulgated together with Decision No. 3925/QD-NHNN.

1.5. Decision No. 3937/QD-NHNN on the promulgation of the list of administrative procedures under the management scope of the State Bank of Vietnam eligible for online public service provision on the National Public Service Portal

• Name of legal document: Decision No. 3937/QD-NHNN issued on 17/12/2025 by the State Bank of Vietnam on the promulgation of the list of administrative procedures under the management scope of the State Bank of Vietnam eligible for online public service provision on the National Public Service Portal.
• Effective date: 17/12/2025.

The content should be noted: Promulgation of the procedure for application for issuance of a bank card issuer identification number (hereinafter referred to as the “BIN”), as listed in the Appendix on the list of administrative procedures under the management scope of the State Bank of Vietnam eligible for online public service provision on the National Public Service Portal promulgated together with Decision No. 3937/QD-NHNN.

1.6. Decree No. 324/2025/ND-CP on financial policies applicable to international financial centers in Vietnam

• Name of legal document: Decree No. 324/2025/ND-CP issued on 18/12/2025 by the Government on financial policies applicable to international financial centers in Vietnam (hereinafter referred to as “Decree No. 324/2025/ND-CP”).
• Effective date: 18/12/2025.

The content should be noted: Financial regime applicable to Members operating in the banking sector.

Specifically, Article 12 of Decree No. 324/2025/ND-CP provides as follows: “Article 12. Financial regime applicable to Members operating in the banking sector

Single-member limited liability commercial banks and branches of foreign banks that are Members may, at their option, apply the financial regime currently applied under the policies of the owner or the parent bank, or implement the financial regime in accordance with Decree No. 135/2025/ND-CP dated 12/6/2025 of the Government on the financial regime applicable to credit institutions and branches of foreign banks and on financial supervision and evaluation of the effectiveness of state capital investment in credit institutions wholly owned by the State and credit institutions with state capital, and the amending, supplementing, or replacing documents thereof (if any).”

1.7. Decree No. 329/2025/ND-CP on licensing of the establishment and operation of banks, foreign exchange management, anti-money laundering, counter-terrorist financing, and countering the financing of the proliferation of weapons of mass destruction at international financial centers in Vietnam

• Name of legal document: Decree No. 329/2025/ND-CP issued on 18/12/2025 by the Government on licensing of the establishment and operation of banks, foreign exchange management, anti-money laundering, counter-terrorist financing, and countering the financing of the proliferation of weapons of mass destruction at international financial centers in Vietnam (hereinafter referred to as “Decree No. 329/2025/ND-CP”).
• Effective date: 18/12/2025.

The content should be noted: Responsibilities of member banks in protecting customers’ rights and interests.

Specifically, Article 5 of Decree No. 329/2025/ND-CP provides as follows: “Article 5. Responsibilities of member banks in protecting customers’ rights and interests

Facilitating customers in depositing and withdrawing funds; ensuring full and timely payment of the principal and interest of deposits in accordance with agreements and in compliance with applicable laws; and not being required to participate in deposit insurance in accordance with the Law on Deposit Insurance of Vietnam. Other responsibilities of member banks in protecting customers’ rights and interests shall be implemented in accordance with Article 10 of the Law on Credit Institutions.”

1.8. Consolidated Document No. 30/VBHN-NHNN consolidating Circulars on banking card activities

• Name of legal document: Consolidated Document No. 30/VBHN-NHNN issued on 19/12/2025 by the State Bank of Vietnam consolidating Circulars on banking card activities (hereinafter referred to as “Consolidated Document No. 30/VBHN-NHNN”).
• Consolidation date: 19/12/2025.

The content should be noted: This document consolidates Circular No. 18/2024/TT-NHNN issued on 28/06/2024 of the Governor of the State Bank of Vietnam on banking card activities and Circular No. 45/2025/TT-NHNN issued on 19/11/2025 of the Governor of the State Bank of Vietnam amending and supplementing a number of articles of Circular No. 18/2024/TT-NHNN on banking card activities.

1.9. Decision No. 3955/QD-NHNN on the promulgation of newly issued administrative procedures in the field of banking information technology activities implemented at the one-stop shop under the management authority of the State Bank of Vietnam

• Name of legal document: Decision No. 3955/QD-NHNN dated 19/12/2025 of the State Bank of Vietnam on the promulgation of newly issued administrative procedures in the field of banking information technology activities implemented at the one-stop shop under the management authority of the State Bank of Vietnam.
• Effective date: 15/01/2026.

The content should be noted: Promulgation of the Procedure for requesting the establishment, modification, or termination of connection to the computer network of the State Bank of Vietnam, as listed in Section I.A.1 of the newly issued administrative procedures in the field of banking information technology activities under the management authority of the State Bank of Vietnam promulgated together with Decision No. 3955/QD-NHNN.

1.10. Circular No. 49/2025/TT-NHNN providing for dossiers and procedures for approval of changes of non-bank credit institutions

• Name of legal document: Circular No. 49/2025/TT-NHNN dated 23/12/2025 of the State Bank of Vietnam providing for dossiers and procedures for approval of changes of non-bank credit institutions (hereinafter referred to as “Circular No. 49/2025/TT-NHNN”).
• Effective date: 06/02/2026.

The content should be noted: Increase of charter capital of limited liability non-bank credit institutions.

Specifically, Article 9 of Circular No. 49/2025/TT-NHNN provides as follows: “Article 9. Increase of charter capital of limited liability non-bank credit institutions

1. Application dossier shall include:a) A written request for approval of the increase of charter capital and for amendment and supplementation of the License in relation to the increase of charter capital of the non-bank credit institution;b) A document of the competent authority approving the charter capital increase plan of the non-bank credit institution, which shall at least include the following contents:

(i) Reasons for and necessity of the charter capital increase;

(ii) Current charter capital and proposed amount of additional charter capital;

(iii) Expected phases of charter capital increase during the year and sources for increasing charter capital;

(iv) Expected timeline for completion of the charter capital increase;

(v) Expected balance sheets and business performance statements for three (03) consecutive years following the charter capital increase; expected plan for use of the increased charter capital in business operations;

(vi) Capacity for governance, management, and risk control corresponding to the new charter capital scale;

c) An explanatory document of the non-bank credit institution, certified by an auditing organization, regarding the impact of qualified audit opinions on the conditions for capital increase (in cases where the audited financial statements contain qualified opinions);

d) In case the charter capital is increased through additional capital contribution by the owner or capital-contributing members, in addition to the dossiers specified at Points a, b, and c of this Clause, the non-bank credit institution shall submit the following additional documents:

(i) A commitment on the use of lawful funds of the owner or capital-contributing members for additional capital contribution;

(ii) A written confirmation from a Vietnamese commercial bank certifying the contributed capital amount of the owner or capital-contributing members or capital contribution from new capital-contributing members;

(iii) Audited financial statements of the owner or capital-contributing members for the fiscal year immediately preceding the year of application for charter capital increase, audited by an independent auditing organization in accordance with law (except where the owner or capital-contributing member is a Vietnamese credit institution). Where audited financial statements are not yet available at the time of dossier submission, unaudited financial statements shall be submitted and audited financial statements shall be submitted immediately after issuance by the auditing organization, and the applicant shall be responsible for the contents of the submitted financial statements;

đ) In case the charter capital is increased through capital contribution by new capital-contributing members, in addition to the dossiers specified at Points a, b, c, d(i), and d(ii) of this Clause, the non-bank credit institution shall submit the dossier of the new capital-contributing members in accordance with the requirements applicable to founding members establishing a non-bank credit institution under relevant laws;

e) In case the charter capital is increased from undistributed profits and other funds in accordance with law, in addition to the dossiers specified at Points a, b, and c of this Clause, the non-bank credit institution shall provide information on the reserve fund for charter capital supplementation, undistributed profits, and other funds as determined based on the independent audit results; and information on the amounts from such funds used for the charter capital increase.

2. Approval procedures:

a) The non-bank credit institution shall prepare and submit the dossier to the State Bank of Vietnam. Where the dossier is incomplete or invalid, within ten (10) days from the date of receipt, the State Bank of Vietnam shall issue a written request for supplementation of the dossier;

b) Within thirty (30) days from the date of receipt of a complete and valid dossier, the State Bank of Vietnam shall issue a decision to amend and supplement the License; in case the License is not amended or supplemented, the State Bank of Vietnam shall issue a written response stating the reasons.”

1.11. Circular No. 50/2025/TT-NHNN providing for dossiers and procedures for approval of certain changes of commercial banks and branches of foreign banks

• Name of legal document: Circular No. 50/2025/TT-NHNN dated 24/12/2025 of the State Bank of Vietnam providing for dossiers and procedures for approval of certain changes of commercial banks and branches of foreign banks (hereinafter referred to as “Circular No. 50/2025/TT-NHNN”).
• Effective date: 07/02/2026.

The content should be noted: Change of name of commercial banks and branches of foreign banks.

Specifically, Article 5 of Circular No. 50/2025/TT-NHNN provides as follows: “Article 5. Change of name

1. Application dossier shall include:a) A written request, which shall at least include the following contents:

(i) Current name;

(ii) Proposed new name, ensuring compliance with relevant laws and regulations on naming;

(iii) Reasons for the change of name;

(iv) Number and date of the resolution or decision of the General Meeting of Shareholders, in respect of a joint stock commercial bank, approving the change of the bank’s name;

b) A resolution or decision of the Members’ Council, in respect of a limited liability commercial bank, approving the change of the bank’s name; a written approval of the parent bank approving the change of name of the branch of a foreign bank in Vietnam.

2. Approval procedures:

a) The commercial bank or branch of a foreign bank shall prepare the dossier in accordance with Clause 1 of this Article and submit it to the State Bank of Vietnam. Where the dossier is incomplete or invalid, within seven (07) working days from the date of receipt, the State Bank of Vietnam shall issue a written request for supplementation and completion of the dossier;

b) Within twenty-five (25) working days from the date of receipt of a complete and valid dossier, the State Bank of Vietnam shall approve the change of name of the commercial bank or branch of the foreign bank and issue a decision amending the License; in case of refusal, the State Bank of Vietnam shall issue a written response clearly stating the reasons.”

1.12. Decree No. 340/2025/ND-CP providing for administrative sanctions in the field of monetary and banking activities

• Name of legal document: Decree No. 340/2025/ND-CP dated 25/12/2025 of the Government providing for administrative sanctions in the field of monetary and banking activities (hereinafter referred to as “Decree No. 340/2025/ND-CP”).
• Effective date: 09/02/2025.

The content should be noted: Violations of regulations on licenses issued by the State Bank of Vietnam and prohibited acts

Specifically, Article 7 of Decree No. 340/2025/ND-CP provides: “Article 7. Violations of regulations on licenses issued by the State Bank of Vietnam and prohibited acts

1. A fine ranging from VND 20,000,000 to VND 40,000,000 shall be imposed for using the organizational name stated on documents and papers in operations that is inconsistent with the organizational name stated in the license.
2. A fine ranging from VND 40,000,000 to VND 50,000,000 shall be imposed for failure to meet or maintain full compliance with the requirements for commencement of operations of domestic branches or transaction offices of credit institutions.
3. A fine ranging from VND 50,000,000 to VND 100,000,000 shall be imposed for failure to fully comply with the conditions for commencement of operations as prescribed in the Law on Credit Institutions.
4. A fine ranging from VND 100,000,000 to VND 150,000,000 shall be imposed for one of the following violations:a) Borrowing, lending, leasing, subleasing, purchasing, selling, or transferring a license, except for the case prescribed at Point b Clause 4 Article 31 of this Decree;b) Erasing or altering a license resulting in changes to its contents without reaching the threshold for criminal prosecution, except for the case prescribed at Point b Clause 4 Article 31 of this Decree.
5. A fine ranging from VND 150,000,000 to VND 200,000,000 shall be imposed for one of the following violations:a) Fraudulent acts in documents proving eligibility for license issuance in the application dossier without reaching the threshold for criminal prosecution, except for the cases prescribed at Clause 2 Article 22 and Point a Clause 4 Article 31 of this Decree;b) Conducting operations inconsistent with the contents stated in the license, except for the cases prescribed at Clause 1, Point b Clause 6 of this Article; Clause 6 Article 21; Point c Clause 8 Article 27; Point c, Point d Clause 5, Point a Clause 6 Article 28; Point d Clause 4 Article 31 of this Decree;c) A transaction office carrying out activities that it is not permitted to perform under the law on the operational network of commercial banks.
6. A fine ranging from VND 300,000,000 to VND 400,000,000 shall be imposed for one of the following violations:a) Continuing operations after a competent authority has applied restrictive, suspension, or temporary suspension measures in accordance with the Law on the State Bank of Vietnam;b) Conducting banking activities or other business activities beyond the scope stated in the license, except for the case prescribed at Point d Clause 4 Article 8 of this Decree.
7. A fine ranging from VND 400,000,000 to VND 500,000,000 shall be imposed for one of the following violations:a) Conducting banking activities without a license, except for the cases prescribed at Point c Clause 8 Article 27; Point d, Point e Clause 5, Clause 8 Article 28; Clause 6 Article 31 of this Decree;b) Violating regulations on the use of terms related to banking activities in accordance with the Law on Credit Institutions;c) Illegally interfering in banking activities or other business activities of credit institutions or foreign bank branches;d) Violating regulations on tying the sale of non-mandatory insurance products to the provision of banking products or services in any form in accordance with the Law on Credit Institutions.
8. Remedial measures:a) Mandatory remittance to the state budget of illicit profits obtained from violations prescribed at Clause 4, Points a and b Clause 5, Clause 6, and Point a Clause 7 of this Article;b) Requesting competent authorities to revoke licenses for violations prescribed at Points a and b Clause 5 and Point a Clause 6 of this Article;c) Considering, proposing, or requesting competent authorities to apply suspension measures from 01 month to 03 months or to dismiss individuals from managerial, executive, or supervisory positions; prohibiting individuals from holding managerial, executive, or supervisory positions at credit institutions or foreign bank branches for violations prescribed at Clause 4, Points a and b Clause 5, Clause 6, and Point a Clause 7 of this Article.

Considering and requesting credit institutions or foreign bank branches to dismiss individuals and apply other handling measures in accordance with law for individuals under the authority of the credit institutions or foreign bank branches.

d) Requiring the return of licenses that have been erased or altered, resulting in distorted contents, to the competent authority that issued the license for violations prescribed at Point b Clause 4 of this Article;

đ) Requiring the implementation of measures to terminate contracts and bearing all costs and damages arising from the termination of insurance product supply contracts in cases where customers request contract termination for violations prescribed at Point d Clause 7 of this Article.”

1.13. Decision No. 4033/QD-NHNN on the correction of Circular No. 52/2025/TT-NHNN dated 25/12/2025 of the Governor of the State Bank of Vietnam amending and supplementing a number of articles of Circular No. 39/2016/TT-NHNN dated 30/12/2016 of the Governor of the State Bank of Vietnam regulating lending activities of credit institutions and foreign bank branches to customers

• Name of legal document: Decision No. 4033/QD-NHNN dated 25/12/2025 of the State Bank of Vietnam on the correction of Circular No. 52/2025/TT-NHNN dated 25/12/2025 of the Governor of the State Bank of Vietnam amending and supplementing a number of articles of Circular No. 39/2016/TT-NHNN dated 30/12/2016 of the Governor of the State Bank of Vietnam regulating lending activities of credit institutions and foreign bank branches to customers (hereinafter referred to as “Decision No. 4033/QD-NHNN”).
• Effective date: 25/12/2025.

The content should be noted: Technical correction.

Specifically, Article 1 of Decision No. 4033/QD-NHNN provides: “Article 1. Correction of a technical error in Article 1 of Circular No. 52/2025/TT-NHNN dated 25/12/2025 of the Governor of the State Bank of Vietnam amending and supplementing a number of articles of Circular No. 39/2016/TT-NHNN dated 30/12/2016 of the Governor of the State Bank of Vietnam regulating lending activities of credit institutions and foreign bank branches to customers, as follows:

The phrase “working day” is corrected to “day”.”

1.14. Circular No. 51/2025/TT-NHNN amending and supplementing a number of articles of Circular No. 16/2021/TT-NHNN dated 10/11/2021 of the Governor of the State Bank of Vietnam regulating the purchase and sale of corporate bonds by credit institutions and foreign bank branches

• Name of legal document: Circular No. 51/2025/TT-NHNN dated 25/12/2025 of the State Bank of Vietnam amending and supplementing a number of articles of Circular No. 16/2021/TT-NHNN dated 10/11/2021 of the Governor of the State Bank of Vietnam regulating the purchase and sale of corporate bonds by credit institutions and foreign bank branches (hereinafter referred to as “Circular No. 51/2025/TT-NHNN”).
• Effective date: 25/12/2025.

The content should be noted: Amendments and supplements to internal regulations.

Specifically, Article 1 of Circular No. 51/2025/TT-NHNN provides: “Article 1. Amendment and supplementation of Clause 4 Article 6

“4. Based on the provisions of this Circular and other relevant laws, within 10 (ten) working days from the date the credit institution promulgates, amends, or supplements its internal regulations on the purchase and sale of corporate bonds:

a) The credit institution shall submit its internal regulations to the State Bank of Vietnam (the Agency for Banking Supervision and Inspection), except for the case specified at point b of this Clause;

b) Credit institutions subject to micro-prudential inspection and supervision by the regional branches of the State Bank of Vietnam shall submit their internal regulations to the respective regional branches of the State Bank of Vietnam.”.”

1.15. Circular No. 59/2025/TT-NHNN regulating the provision and use of specialized electronic signatures and specialized electronic signature certificates of the State Bank of Vietnam

• Name of legal document: Circular No. 59/2025/TT-NHNN dated 29/12/2025 of the State Bank of Vietnam regulating the provision and use of specialized electronic signatures and specialized electronic signature certificates of the State Bank of Vietnam (hereinafter referred to as “Circular No. 59/2025/TT-NHNN”).
• Effective date: 01/03/2026.

The content should be noted: Contents of electronic signature certificates.

Specifically, Article 5 of Circular No. 59/2025/TT-NHNN provides: “Article 5. Contents of electronic signature certificates

Electronic signature certificates issued by the State Bank of Vietnam include the following contents:

1. Name of the State Bank of Vietnam.
2. Name of the subscriber.
3. Identification of the subscriber.
4. Serial number of the electronic signature certificate.
5. Validity period of the electronic signature certificate.
6. Data used to verify the electronic signature of the agency, organization, or individual granted the electronic signature certificate.
7. Electronic signature of the State Bank of Vietnam.
8. Purpose and scope of use of the electronic signature certificate.
9. Legal responsibilities of the State Bank of Vietnam.”

1.16. Decision No. 4062/QĐ-NHNN regulating the promulgation of amended and supplemented administrative procedures in the field of establishment and banking operations implemented at the one-stop-shop unit within the scope of management functions of the State Bank of Vietnam

• Name of legal document: Decision No. 4062/QĐ-NHNN dated 30/12/2025 of the State Bank of Vietnam regulating the promulgation of amended and supplemented administrative procedures in the field of establishment and banking operations implemented at the one-stop-shop unit within the scope of management functions of the State Bank of Vietnam.
• Effective date: 29/01/2026.

The content should be noted: Amendment and supplementation of the procedure for approval of overseas listing of shares on foreign securities markets of joint-stock credit institutions as listed in Part I.A.1 of the amended and supplemented administrative procedures in the field of establishment and banking operations within the scope of management functions of the State Bank of Vietnam promulgated together with Decision No. 4062/QĐ-NHNN.

1.17. Circular No. 61/2025/TT-NHNN regulating the operational network of commercial banks

• Name of legal document: Circular No. 61/2025/TT-NHNN dated 31/12/2025 of the State Bank of Vietnam regulating the operational network of commercial banks (hereinafter referred to as “Circular No. 61/2025/TT-NHNN”).
• Effective date: 15/02/2026.

The content should be noted: Competence to approve matters related to the operational network of commercial banks.

Specifically, Article 4 of Circular No. 61/2025/TT-NHNN provides: “Article 4. Competence to approve the operational network of commercial banks

1. The Governor of the State Bank of Vietnam shall consider and approve the establishment, termination of operations, dissolution (except for voluntary termination of operations) of domestic branches; the establishment of overseas branches, representative offices, and subsidiary banks; and the conversion of the legal form of overseas subsidiary banks of commercial banks.
2. The Director General of the Agency for Banking Supervision and Inspection shall consider and approve the establishment, termination of operations, dissolution (except for voluntary termination of operations) of domestic transaction offices, representative offices, and public service units of commercial banks.
3. The Director of the Regional Branch of the State Bank of Vietnam shall consider and approve:a) Change of location of branch headquarters and transaction offices;b) Voluntary termination of operations of branches and transaction offices.
4. In certain specific cases, the Governor of the State Bank of Vietnam shall consider and decide to approve:a) The establishment of domestic branches, representative offices, public service units, and transaction offices; and overseas branches, representative offices, and subsidiary banks of commercial banks, based on dossiers and procedures as prescribed in this Circular and in accordance with actual conditions in order to:

(i) Serve objectives of economic, social, political, security, national defense, diplomatic development and monetary policy administration in each period;

(ii) Support commercial banks in participating in the restructuring of people’s credit funds subject to special control;

b) The conversion of a domestic transaction office into a branch of a commercial bank, based on dossiers, conditions, order and procedures for establishment of domestic branches prescribed in this Circular, in accordance with actual conditions in order to implement an approved credit institution restructuring plan;

c) Matters related to the operational network of commercial banks to implement the approved restructuring plan of commercial banks subject to special control, based on dossiers and procedures prescribed in this Circular.”

2. Legal documents are effective in 01/2026

2.1. Law on Personal Data Protection No. 91/2025/QH15

• Name of legal document: Law on Personal Data Protection No. 91/2025/QH15 promulgated on 26/6/2025 by the National Assembly of Vietnam (hereinafter referred to as “Law No. 91/2025/QH15”).
• Effective date: 01/01/2026.

The content should be noted: Personal data protection in finance, banking, and credit information activities.

Specifically, Article 27 of Law No. 91/2025/QH15 provides: “Article 27. Personal data protection in finance, banking, and credit information activities

1. Organizations and individuals operating in finance, banking, and credit information activities shall:a) Comply with regulations on the protection of sensitive personal data and safety and confidentiality standards in finance and banking according to the law;b) Refrain from using personal data subject matters’ credit information to mark, rank, evaluate credit information, or assess creditworthiness without their consent;c) Only collect personal data necessary for credit information activities from sources in conformity with this Law and relevant laws;d) Issue notices to personal data subject matters in case of leakage or loss of information on bank accounts, finance, credit, or credit information.
2. Organizations and individuals engaging in credit information activities shall comply with this Law; apply measures to prevent unauthorized access, use, disclosure, and modification of clients’ personal data; adopt measures to restore clients’ personal data in case it is lost; ensure confidentiality during the collection, provision, and processing of clients’ personal data in service of credit information assessment.
3. The Government of Vietnam shall elaborate on this Article.”

2.2. Circular No. 45/2025/TT-NHNN on amendments to certain Articles of Circular No. 18/2024/TT-NHNN on bank card operations

• Name of legal document: Circular 45/2025/TT-NHNN issued on 19/11/2025 by the State Bank of Vietnam on amendments to certain Articles of Circular No. 18/2024/TT-NHNN on bank card operations (hereinafter referred to as “Circular No. 45/2025/TT-NHNN”).
• Effective date: 05/01/2026.

The content should be noted: Amending and supplementing the total cash withdrawal limit of credit cards

Specifically, Article 6 of Circular No. 45/2025/TT-NHNN provides: “Article 6. Amendments to clause 3 of Article 13

“3. Total monthly cash withdrawal limit for a cardholder by BIN of a credit card is 100 (one hundred) million VND.”.

2.3. Decision No. 4062/QD-NHNN on the promulgation of amended and supplemented administrative procedures in the field of establishment and operation of banks implemented at the one-stop-shop under the management functions of the State Bank of Vietnam

• Name of legal document: Decision No. 4062/QD-NHNN dated 30/12/2025 issued by the State Bank of Vietnam on the promulgation of amended and supplemented administrative procedures in the field of establishment and operation of banks implemented at the one-stop-shop under the management functions of the State Bank of Vietnam.
• Effective date: 29/01/2026.

The content should be noted: Amendment and supplementation of the Procedure for approval of overseas listing of shares on foreign securities markets of joint-stock credit institutions as listed in Section I.A.1 of the amended and supplemented administrative procedures in the field of establishment and operation of banks under the management functions of the State Bank of Vietnam promulgated together with Decision No. 4062/QD-NHNN.