Updates on regulations regarding reissuance of bank licenses and supplementation of operational contents to bank licenses under Circular 66/2025/TT-NHNN

On 31 December 2025, the State Bank of Vietnam (the “SBV”) issued Circular 66/2025/TT-NHNN to amend and supplement several provisions of Circular 34/2024/TT-NHNN concerning the reissuance of bank licenses and the supplementation of operational contents to bank licenses.

These amendments are not merely technical adjustments to align with the SBV’s new organizational structure, but also clearly reflect a reform trend in three main directions: (i) reallocation of regulatory authority; (ii) shortening of administrative processing time; and (iii) gradual digitalization of licensing procedures. These changes are expected to improve administrative efficiency while creating more favorable conditions for credit institutions to expand their operations.

1. Adjustment of authority for reissuance of bank licenses and supplementation of operational contents to bank licenses

Previously, for foreign bank branches, the authority to reissue of bank licenses and/or supplement operational contents to bank licenses belonged to the Provincial and Municipal Branches of the SBV.^[1] However, under the new regulations, this authority has been adjusted in line with the reorganization of the SBV into a regional model, and is now transferred to Regional Branches of the SBV.^[2]

This change aims to ensure consistency with the SBV’s new organizational structure, while also reflecting a shift toward regional-based management rather than management based on individual administrative units as before.^[3]

In addition, under Circular 66/2025/TT-NHNN, the authority to approve supplementation of operational contents to bank licenses of commercial banks and foreign bank branches has been transferred from the Chief Banking Inspector and Supervisor to the Director General of the Department for Credit Institutions Management and Supervision.^[4]

This reallocation demonstrates a clearer distinction between inspection and management functions, while enhancing specialization in supervisory activities.

2. Introduction of online application submission and shortening of processing time

2.1. Introduction of online application submission

Circular 66/2025/TT-NHNN allows online submission of applications via the National Public Service Portal for the following procedures: (i) reissuance of bank licenses; (ii) supplementation of operational contents to bank licenses; (iii) simultaneous reissuance of bank licenses and supplementation of operational contents to bank licenses.^[5]

Accordingly, for online submissions, electronic dossiers can be used digital signatures, and documents must be submitted in PDF format scanned from original documents.^[6]

This approach promotes digital transformation and enhances operational flexibility. However, the transition to an electronic environment also imposes new requirements on credit institutions to standardize their IT systems, digital signatures, and internal document management processes.

2.2. Shortening of processing time

In addition to introducing online application submission, the processing time for the above procedures has been reduced from 40 days to 30 days from the date of receipt of a complete and valid dossier.^[7]

This significant reduction in processing time reflects efforts to reform administrative procedures, improve processing efficiency, and shorten the time required for credit institutions to implement licensed activities.

3. Amendments and Supplements to the Dossier Components for Supplementation of Operational Contents to Bank Licenses

With respect to applications for supplementation of operational contents to bank licenses, particularly in cases involving participation in international payment systems, Circular 66/2025/TT-NHNN introduces several amendments and additions as follows:

First, with respect to demonstrating the conditions for the proposed activities to be carried out in Vietnam, the new regulation allows commercial banks and foreign bank branches to use of a “letter of undertaking” instead of being required to submit supporting documentary evidence as previously required. Specifically, commercial banks and foreign bank branches may submit a letter of undertaking from: the owner; a foreign credit institution holding 50% or more of the charter capital of a wholly foreign-owned bank (in the case of wholly foreign-owned banks); or the parent bank (in the case of foreign bank branches), confirming that the proposed additional activities to be added to the license are permitted to be conducted in the jurisdiction where such owner, foreign credit institution, or parent bank is headquartered.^[8]

Second, regarding documents evidencing the legal establishment and operation of the operator of an international payment system abroad, the new regulation allows commercial banks, foreign bank branches to use a copy of the License for the Establishment of a Representative Office or Branch in Vietnam, where such entity has already a presence in Vietnam.^[9]

Third, an additional requirement is introduced for commercial banks, foreign bank branches to submit documentation describing the international payment system for which licensing is sought, including: (i) a description of the technical infrastructure connecting the commercial bank or foreign bank branch to the international payment system; and (ii) a description of operational procedures for transaction processing, switching, clearing, and settlement of payment transactions between the commercial bank or foreign bank branch and the operator of the international payment system.^[10]

Fourth, for international payment systems that are widely used such as those operated by the Society for Worldwide Interbank Financial Telecommunication (SWIFT) or international card organizations (Visa, MasterCard, JCB, Amex, UPI), the new regulations remove the requirement for commercial banks and foreign bank branches to submit: (i) documents evidencing the legal establishment and operation of the system operator; and (ii) documentation describing the international payment system.^[11]

Overall, these changes demonstrate a dual approach of increasing flexibility in certain dossier requirements while simultaneously introducing additional elements to strengthen regulatory oversight.