Resolution 222 Explained: The Law That Created Vietnam's International Financial Centre

What is Resolution 222?#

Resolution No. 222/2025/QH15 is a resolution of Vietnam's National Assembly — the country's highest legislative body — dated 27 June 2025, on the establishment of International Financial Centres in Vietnam. It took effect on 1 September 2025.

In Vietnam's legal hierarchy, a National Assembly resolution sits just below the Constitution. This matters because Resolution 222 explicitly provides that where its provisions conflict with other Vietnamese laws (except the Constitution), the resolution prevails. This "override" principle is what gives the VIFC its special legal character and is the mechanism by which Vietnam can offer a genuinely distinct regulatory environment without amending dozens of existing statutes.

Think of Resolution 222 as the constitutional charter of the VIFC. It does not contain operational detail — that is left to eight implementing decrees issued by the government in December 2025. But it establishes the legal authority, the policy boundaries, and the institutional architecture on which everything else is built.

Why a resolution and not a law?#

Vietnam's legislative system distinguishes between laws (luật) and resolutions (nghị quyết) of the National Assembly. A resolution can be enacted more quickly and is commonly used to authorise pilot programmes, special mechanisms, or time-bound policy experiments.

For the VIFC, a resolution was the pragmatic choice. It allowed the National Assembly to move fast — from the Politburo's policy directive in November 2024 to a legislative instrument in seven months — while still carrying the full legal weight of the country's highest institution. The government has signalled that the resolution-plus-decree framework will eventually be consolidated into a dedicated IFC law once the regime has proven itself in practice.

The "one centre, two locations" model#

Resolution 222 defines the VIFC as a single entity operating across two geographically defined areas:

• Ho Chi Minh City — the comprehensive financial hub, focused on capital markets, banking, insurance, asset management, trade finance, and traditional financial services.
• Da Nang — the innovation and fintech hub, oriented toward digital assets, regulatory sandboxes, new financial models, and technology-driven services.

The resolution explicitly defines the VIFC as consisting of specific geographic areas within these two cities, with members entitled to special policies. This is not a metaphorical designation — the VIFC has physical boundaries, and the special regulatory treatment applies only within them.

In Ho Chi Minh City, the designated area covers approximately 898 hectares spanning Saigon Ward, Bến Thành Ward, and the Thủ Thiêm New Urban Area. In Da Nang, the designated area covers approximately 300 hectares across multiple sites, including Ân Hải Ward, Software Park No. 2, and a planned coastal reclamation zone.

What the resolution covers#

Resolution 222 is a framework instrument. It establishes principles and authorises the government to issue detailed rules. Its major provisions fall into several categories.

Membership and access#

The VIFC operates on a membership model. Entities must be registered, recognised, or licensed to access the centre's special regulatory treatment. Resolution 222 defines the categories of entities eligible for membership:

• Commercial banks, foreign bank branches, securities companies, insurance and reinsurance enterprises
• Investment and asset management funds
• Market infrastructure organisations (exchanges, clearing houses, depositories)
• Fintech and digital asset organisations
• Professional service providers (law firms, audit firms, consultancies)
• Non-financial organisations
• Other entities as prescribed by the government

Membership can be obtained through registration (the standard pathway) or recognition (a fast-track pathway for entities that meet certain prestige criteria, such as appearing on the Fortune Global 500 list or being among Vietnam's top-10 financial institutions by charter capital).

Each member receives a unique identification number and is recorded in the VIFC member register. Membership is the gateway — without it, the special policies do not apply.

Foreign exchange liberalisation#

One of the resolution's most consequential provisions is the liberalisation of foreign exchange rules for VIFC members. Under Vietnam's general framework, the Vietnamese đồng is the required currency for domestic transactions, with limited exceptions. Resolution 222 changes this fundamentally for the VIFC:

• Members may transact, list prices, and settle obligations in foreign currency when dealing with other members or offshore counterparties.
• Wholly foreign-owned members are exempt from foreign exchange control procedures — they can borrow, lend, and invest across borders subject only to declaration and reporting obligations rather than prior registration.
• A dual-track account system separates capital transactions from operational transactions, enabling transparency without bureaucratic friction.

The practical significance is substantial. For an international bank or asset manager accustomed to operating in US dollars or euros, the ability to conduct business in foreign currency within the VIFC removes one of the most commonly cited friction points of doing business in Vietnam.

Banking and financial services#

Resolution 222 authorises a specialised banking regime within the VIFC. Members may establish and operate single-member limited liability banks and foreign bank branches with the ability to apply international accounting standards, debt classification rules, risk provisions, and prudential ratios according to the owner's policies rather than Vietnam's domestic banking regulations.

This is a significant departure. Vietnam's general banking framework is prescriptive — the State Bank of Vietnam sets detailed prudential requirements. Within the VIFC, the approach shifts toward a more internationally familiar model where well-capitalised institutions can apply their parent group's standards, subject to oversight.

Capital markets and new products#

The resolution provides the legal basis for a range of financial products and services, including stocks, bonds, fund certificates, financial derivatives, fund management, insurance, reinsurance, green finance, carbon credits, and digital assets.

It also authorises the creation of new trading platforms for commodity trading and derivatives, carbon credits, cultural and artistic products (including NFTs), rare metals, and green financial instruments. The resolution envisions a capital market for innovative startups, including crowdfunding mechanisms and private placement platforms.

Tax incentives#

Resolution 222 establishes a preferential tax regime designed to be competitive with other international financial centres in the region:

• Corporate income tax: 10% for 30 years for projects in prioritised sectors, or 15% for 15 years for projects in other sectors.
• Personal income tax: Exemption until 2030 for the earned income of highly qualified personnel working in the VIFC.

For context, Vietnam's standard corporate income tax rate is 20%, and personal income tax rates for high earners can reach 35%. The VIFC rates are designed to compete directly with centres such as the DIFC (0% corporate tax) and GIFT City (various incentives), while still generating revenue for the Vietnamese state.

Immigration and residency#

To attract and retain international talent, the resolution introduces special immigration policies:

• Visas and temporary resident cards valid for up to 10 years for important investors, experts, managers, and other qualified professionals.
• Permanent resident cards for certain categories of senior personnel.
• Work permit exemptions for foreign workers within the VIFC.
• Exemption from requirements for foreign labour demand reporting.

These provisions are designed to address one of the most persistent complaints of foreign professionals in Vietnam — the complexity and unpredictability of the work permit and visa system.

Labour and employment#

Resolution 222 allows market-rate salaries for public servants in the VIFC's executive and supervisory agencies — a departure from Vietnam's civil service pay scales that is intended to attract capable administrators. It also permits foreign workers to opt into Vietnam's social insurance and unemployment programmes rather than being subject to separate arrangements.

Dispute resolution#

Perhaps the most symbolically important provision for international investors: Resolution 222 allows VIFC members to resolve disputes through multiple venues, including foreign arbitration, international arbitration, the VIFC's own International Arbitration Centre, Vietnamese arbitration, foreign courts, and Vietnamese courts.

The resolution also establishes specialised courts within the VIFC and permits, in defined circumstances, the application of foreign governing law. A separate Law on Specialised Courts at the IFC, effective 1 January 2026, incorporates common-law principles and enables the appointment of foreign judges.

English — or English with Vietnamese translation — is the official language for transactions, administrative procedures, dispute resolution, and all financial and technical documentation within the VIFC.

Land and environment#

Resolution 222 provides priority allocation and lease of land for VIFC projects, with land tenure of up to 70 years for prioritised sectors. It also streamlines administrative procedures for construction and environmental compliance — a recognition that infrastructure development speed is a competitive factor.

Sandbox mechanism#

The resolution introduces a regulatory sandbox for fintech technologies, products, services, and business models not yet prescribed by existing Vietnamese law. Participants in the sandbox are exempt from compliance with certain standards and technical regulations, and are exempt from liability for damage to the state during experimentation. The criteria, conditions, and procedures for sandbox participation are further specified by the IFC Executive Council.

Institutional architecture#

Resolution 222 establishes a multi-layered governance structure for the VIFC:

The Steering Committee — chaired by the Prime Minister, with the Permanent Deputy Prime Minister as Standing Deputy Head, and including ministers, state bank governors, and party secretaries of Ho Chi Minh City and Da Nang. The Ministry of Finance serves as the standing agency. This is the highest-level coordinating body.

The Executive Council — chaired by the Permanent Deputy Prime Minister, responsible for approving strategies, roadmaps, and operational regulations, and resolving coordination issues between the two VIFC locations.

City-level Management Authorities — specialised administrative bodies under the People's Committees of Ho Chi Minh City and Da Nang, responsible for licensing, member registration, infrastructure development, one-stop administrative procedures, and day-to-day management.

The Supervisory Authority — an independent oversight and enforcement body, based in Ho Chi Minh City with an optional branch in Da Nang, responsible for inspection, supervision, compliance monitoring, and risk management.

Dispute resolution bodies — specialised courts and the International Arbitration Centre, forming a dual-track dispute resolution framework.

What Resolution 222 does not do#

It is equally important to understand what the resolution leaves unaddressed:

• Operational detail. The resolution sets policy direction; the eight implementing decrees (Decrees 323–330, all issued 18 December 2025) provide the regulatory specifics. See our guides to Decree 329 + Circular 72 and Decree 330 for the banking/FX and commodity exchange frameworks respectively.

• Operating rulebooks. The rules that will govern day-to-day market behaviour — trading rules, surveillance protocols, sandbox admission criteria, supervisory reporting formats — have not yet been issued. These will come from the IFC Executive Council and Management Authorities.

• Activity-specific licences. Even with IFC-wide permissions, each regulated activity (banking, securities, insurance, commodity exchange operation, digital asset services) still requires a specific licence, recognition, or sandbox authorisation.

• Legislative consolidation. Resolution 222 is designed as a fast-track enabling instrument. The government has indicated that it expects to eventually consolidate the IFC regime into a dedicated law — but no timeline has been set for this.

How Resolution 222 relates to the eight decrees#

The relationship is hierarchical. Resolution 222 provides the legal authority; the decrees operationalise it:

All eight decrees were issued on 18 December 2025 and took effect immediately (except Decree 327 on immigration, which took effect on 17 January 2026).

Timeline of key events#

• November 2024 — Politburo issues Notice No. 47-TB/TW directing the establishment of international financial centres.
• December 2024 — Prime Minister issues Decision No. 1718/QĐ-TTg appointing himself as head of the steering committee for the IFC.
• January 2025 — Ministry of Planning and Investment drafts the initial resolution outline.
• June 2025 — National Assembly adopts Resolution 222/2025/QH15 (27 June). Effective date: 1 September 2025.
• August 2025 — PM signs Decision No. 1646/QĐ-TTg establishing the Steering Committee for the IFC (1 August).
• December 2025 — Government issues eight implementing decrees (18 December). PM announces VIFC establishment at Hanoi conference (21 December).
• December 2025 — SBV issues Circular 72/2025/TT-NHNN on foreign exchange framework (31 December).
• January 2026 — Law on Specialised Courts at the IFC takes effect (1 January). VIFC Da Nang officially inaugurated (9 January).
• February 2026 — VIFC-HCMC officially launched at 8 Nguyễn Huệ, Saigon Ward (11 February).

What this means for international firms#

Resolution 222 represents the most significant structural opening of Vietnam's financial sector since the country joined the WTO in 2007. For international firms evaluating the VIFC, three features matter most:

The override principle makes the VIFC a genuinely distinct legal space within Vietnam. You are not navigating Vietnam's general regulatory framework with a few exemptions bolted on — you are operating under a separate regime that prevails where it differs from existing law. This is the same structural approach used by the DIFC, AIFC, and GIFT City.

The membership model means access is gated. The special treatment applies only to registered or recognised members operating within the designated geographic areas. Firms need to plan their entry pathway — registration versus recognition — and understand the obligations that come with membership.

The phased implementation means the regime is still being built. The resolution and decrees are in place, but operating rulebooks, sandbox criteria, and supervisory reporting formats are still forthcoming. Early movers will have the opportunity to shape these frameworks through engagement with the IFC authorities, but they will also need to manage the uncertainty inherent in a new regime.

"The resolution-plus-decree framework creates legal authority. But circulars, institutional decisions, operating rulebooks, and licensing are what make the IFC actually functional. We are in the transition between the two."

For a deeper look at the specific regulatory layers that remain to be completed, see our analysis of Decree 323 and the VIFC's governance structure. For the practical question of how to get started as a VIFC member, see our Getting Started guide.

This guide was last updated on 14 February 2026. Resolution 222 is a living framework — the government has indicated that implementing instruments will be periodically reviewed and amended based on practical experience. We will update this guide as new instruments are issued. For the latest developments, see our Regulation section.