Vietnam tightens foreign exchange rules for banks

by Citra Widyaningsih • 06 Oct 2026
Vietnam tightens foreign exchange rules for banks
Hands exchanging US and local currency at a bank counter, signifying international finance. Photo: Audy of Course/Pexels

The State Bank of Vietnam has revised its regulations for foreign currency transactions with licensed credit institutions, updating a key framework to streamline operations and tighten enforcement. Effective from November 9, 2026, Circular 48/2026/TT-NHNN replaces and expands upon Circular 26/2021/TT-NHNN, which previously governed these interactions. The changes target three primary areas: transaction registration, payment compliance, and enforcement procedures.

Under the updated rules, credit institutions must now submit registration dossiers exclusively through the State Bank’s online public service portal, eliminating the prior option of physical or postal submissions. The required documentation has been simplified to an application form and updated payment instructions, now detailed in revised appendices attached to the circular. This digital requirement aligns with broader efforts to reduce bureaucratic inefficiencies in Vietnam’s financial sector. The State Bank shall establish foreign currency transaction relations with licensed credit institutions on the basis of the completeness and validity of dossier.

The circular introduces automated penalty calculations for late foreign currency payments, replacing the previous discretionary approach. Delays now trigger fines equal to 150% of the overnight interest rate charged by the receiving bank’s correspondent, applied to both the amount and duration of the delay. For Vietnamese dong transactions, the penalty uses the State Bank’s interbank lending rate instead. The calculation is fully formulaic, removing negotiation or leniency. Previously ambiguous force majeure exemptions have also been clarified: delays caused by unforeseen events, as defined by Vietnam’s Civil Code, will not incur fines, but institutions must prove compliance with legal thresholds through the State Bank’s Foreign Exchange Management Department.

The State Bank of Vietnam shall suspend foreign currency transactions with a licensed credit institution for 03 (three) months in case such institution fails to submit reports or fails to submit reports within the prescribed period under Clause 1, Article 15 of this Circular on 03 (three) or more times within 03 (three) consecutive months, except for the case specified in Clause 3, Article 15 of this Circular.

Banks must also notify the State Bank within two working days of any changes to registered information, such as updated licenses or operational permissions. The circular consolidates oversight functions, replacing the Central Banking Department with the Foreign Exchange Management Department as the sole authority for handling delayed payments and enforcement, aiming to reduce regional fragmentation.

The new rules take effect on November 9, 2026, and annul an earlier provision from Circular 12/2023/TT-NHNN that had allowed some flexibility in state foreign exchange reserve management. Compliance falls under the State Bank’s Office, the Foreign Exchange Management Department, and the heads of all licensed credit institutions. Banks operating under the 2021 rules will need to update internal systems to align with the digital submission process and automated fines. However, the State Bank has not yet published the revised Appendices 1, 2, and 3, which outline updated application forms and payment standards, leaving institutions awaiting further guidance.

Stricter Monthly Reporting Deadlines Trigger Suspensions

These reports must include detailed breakdowns of all transactions-both settled and unsettled-along with supporting documentation for discrepancies. Reports must be filed by the 10th of each month, with no exceptions unless a force majeure event is formally recognized. Failure to meet this deadline triggers the three-month suspension clause, regardless of prior compliance.

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Existing agreements with the State Bank must be reviewed and updated to reflect the new penalty structure and digital requirements. This includes recalculating outstanding payment obligations to ensure compliance with the automated fine system. The Foreign Exchange Management Department will conduct spot checks to verify adherence, with non-compliant banks facing immediate enforcement actions. The department is also developing a standardized template for reporting discrepancies, to be issued as Appendix 4 once finalized.

The circular reshapes the State Bank’s internal oversight structure by dissolving the Central Banking Department and transferring its foreign exchange functions-including delayed payment enforcement-to the Foreign Exchange Management Department. This consolidation eliminates overlaps in authority and ensures centralized handling of penalties, force majeure determinations, and transaction suspensions. Regional branches must now forward enforcement cases directly to the department in Hanoi, removing prior local discretion.

Mandatory Digital Systems and Standardized Payment Rules

Licensed institutions must align internal systems with the updated Appendix 2, which standardizes payment instructions for foreign exchange transactions. Mandatory fields include transaction reference codes, correspondent bank details, and settlement timelines, all requiring pre-approval from the State Bank. Banks failing to update their systems risk transaction rejections or delays, as submissions will be cross-referenced against standardized templates. No grace period is specified, meaning compliance must begin immediately upon the November 9 effective date.

Foreign bank branches operating in Vietnam must now adhere to the same digital submission and reporting rules as domestic institutions. These branches are required to designate a local representative to oversee compliance, including timely dossier submissions and monthly reports. The representative must verify transaction alignment with the State Bank’s updated payment instructions and escalate discrepancies to the Foreign Exchange Management Department within 48 hours of detection.

Finally, the circular annuls Clause 10 of Circular 12/2023/TT-NHNN, which had permitted limited flexibility in state foreign exchange reserve management. Institutions invoking exemptions without authorization will face fines equal to 300% of the overnight lending rate for the duration of the unauthorized delay.

Legal Framework and New Supervisory Authority

The revised circular amends and supplements Circular 26/2021/TT-NHNN under the authority of the Law on the State Bank of Vietnam, the Law on Credit Institutions (as amended by Laws 43/2024/QH15 and 96/2025/QH15), and the Ordinance on Foreign Exchange (as amended by Ordinance 06/2013/UBTVQH13). It also incorporates provisions from Decree 26/2025/ND-CP, which defines the State Bank’s functions, tasks, and organizational structure, with later updates reflected in Decree 198/2026/ND-CP.

Article 19 of the circular updates supervisory requirements for credit institutions, mandating that the State Bank’s Regional branches provide certified copies of licensing documents—such as the License for Establishment and Operation or Foreign Bank Branch approval—within two working days of a written request. Institutions must also notify the Foreign Exchange Management Department immediately if placed under special control, have their licenses revoked, or violate the circular’s provisions. A new Article 19a extends this obligation to the SBV Inspectorate, requiring notification if a licensed institution’s foreign exchange activities are suspended.

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