National Assembly Finds Six VIFC Gaps After First Oversight Session

Vietnam's International Financial Centre has nine implementing decrees and a party mandate from the Politburo. What it does not yet have, according to the National Assembly's first formal oversight session, is most of the operational infrastructure those decrees were supposed to produce.

What the Session Found#

The July 29 working session — held at the National Assembly building and reported by Dai Bieu Nhan Dan, the official publication of the National Assembly — brought together Finance Ministry Deputy Minister Tran Quoc Phuong, State Bank of Vietnam Deputy Governor Doan Thai Son, Da Nang Standing Vice Chair Ho Ky Minh (who chairs the Da Nang IFC governing body), and HCMC Vice Chair Nguyen Cong Vinh, among others. Phan Van Mai, Chairman of the NA's Economic and Financial Committee, attended alongside the Vice Chair.

Tran Quoc Phuong's opening position was measured: nine decrees have been issued to implement Resolution 222/2025/QH15 (note: an earlier guide on this site covers eight implementing decrees — the ninth was issued after that guide was written), the 'one centre, two locations' architecture is codified in law, and — in his framing — special policies are being implemented without obstacles.

Nguyen Thi Hong's closing directive told a different story. "There is still much important work that must be accelerated," she said, "especially completing the legal framework and implementing decrees." The session then specified what that work consists of.

Six Gaps That Matter to Investors#

The supervisory body is inactive. Resolution 222 provides for a dedicated supervisory agency for the VIFC. The Vice Chair explicitly directed the Government to "finalise and bring the supervisory agency into operation promptly." For international financial institutions evaluating entry, the supervisory body is the regulatory counterparty for day-to-day oversight — and it does not yet exist. An earlier HCMC directive had set a May 15 deadline to constitute this body; see our coverage of that directive.

Sandbox licensing rules are unwritten. MoF is still drafting the procedures for the VIFC's controlled testing mechanism — the sandbox — alongside both IFC governing bodies. Fintech firms, digital asset operators, and novel product originators who expected to enter the VIFC sandbox cannot do so until those procedures are finalised. No completion deadline was announced at the session.

Licensing and registration procedures are not investor-ready. The Vice Chair directed the Government to finalise licensing, registration, management, supervision, and service-provision procedures across the board. This is a broader gap than the sandbox alone: it touches the entry mechanics for any institution seeking to operate within the VIFC.

IT systems and shared databases are unbuilt. The directive included an explicit instruction to build information technology systems, databases, and shared infrastructure. These are not optional add-ons — they are the connective tissue between VIFC members, regulators, and governing bodies.

No single point for investor inquiries. The Vice Chair called for establishing a single contact point to receive and process requests from investors and members. The absence of such a mechanism is a practical barrier: international institutions conducting due diligence have no defined channel for regulatory queries.

International accounting standards guidance is missing. MoF is still researching regulations to guide VIFC members on applying international accounting standards — the IFRS-equivalent framework that every international bank, asset manager, and insurer will need before they can prepare compliant financial statements inside the centre.

The Coordination Problem#

Alongside these six operational gaps, the Vice Chair also named inter-agency coordination as a specific problem requiring resolution. Her directive was direct: "clear functions, clear tasks, clear authority, clear responsibility" for relationships between central agencies, local agencies, HCMC, Da Nang, IFC governing bodies, and state management and supervisory agencies.

This matters because the VIFC's 'one centre, two locations' structure creates inherent jurisdictional complexity. HCMC and Da Nang each have their own IFC governing body, their own People's Committee, and their own relationship with central ministries. The Vice Chair's directive suggests that who does what, and who answers to whom, is not yet clear in practice — even though Decree 323 defined the governance architecture on paper. The question of how Da Nang and HCMC operate as a unified national platform rather than two competing nodes has not been operationally codified, as the brief covering the two-node architecture noted when the decrees were first issued.

Resolution 222 as an Open Framework#

One structural feature of Resolution 222/2025/QH15 helps explain the current state: the Vice Chair described it at the session as an "open resolution" — a foundational instrument that delegates extensive authority to the Government to issue implementing rules. That delegation was the point. The National Assembly set the policy direction; the Government was to fill in the operational detail.

The nine decrees MoF's deputy minister cited confirm the first layer of that delegation has been executed. But the session made clear that the decrees themselves delegate further — to the governing bodies, to line ministries, to new institutional arrangements that do not yet exist. The framework is complete in outline; the sub-regulatory layer beneath it is not.

What the MoF–NA Tension Signals#

The divergence between the deputy minister's "no obstacles" framing and the Vice Chair's "much important work remains" conclusion is the clearest signal for international institutions watching the VIFC timeline.

MoF's position is defensible on its own terms: the legal framework is in place, the decrees have been issued, the architecture has been established. None of that is untrue. But the Vice Chair's assessment reflects what international financial institutions already know from their own due diligence: the existence of a decree does not mean the mechanisms that decree creates are functional. Sandbox procedures, supervisory body authority, IT infrastructure, and investor inquiry routing — the daily operational mechanics — are what determine whether an institution can actually deploy capital or relocate a team.

The session is the National Assembly's formal record that those mechanics are not yet in place, and that the Government has been directed to fix them.

What Comes Next#

The July 29 session does not appear — based on Dai Bieu Nhan Dan's report — to have produced a formal written directive instrument, either a resolution or a conclusion, with specific deadlines attached. Whether such an instrument follows, and what timelines it sets, will be the next indicator of legislative pressure on the Government's implementation pace.

For institutions tracking VIFC entry, the six gaps identified at the session define the monitoring checklist: activation of the supervisory body, publication of sandbox licensing procedures, finalisation of general licensing and registration rules, launch of the IT and database infrastructure, establishment of the investor inquiry point, and publication of IFRS-equivalent accounting guidance. None of those has a public deadline as of 2 August 2026.

The session is also the first formal input that the VIFC-HCMC advisory board — which includes the former DIFC CEO and WAIFC's chair — now has concrete, legislatively-identified gaps to engage with, rather than a general mandate to advise on strategic development.