Legal Updates by GBA Members | February 2026

As part of our ongoing effort to keep members informed, we are pleased to share the most relevant updates in Vietnam across Legal, Tax, Accounting, Banking, and HR. These insights are contributed by our GBA members, bringing practical expertise and market perspectives to support the business community in navigating regulatory developments and economic trends.

  1. Legal Update: New Procedures for Pilot Cryptocurrency Asset Market Introduced

The Ministry of Finance has introduced three new administrative procedures related to organizing the cryptocurrency asset trading market. The Ministry of Finance on January 20 issued Decision No. 96/QD-BTC (Decision 96), announcing new administrative procedures to pilot the cryptocurrency asset market under its management.

Under the decision, three new administrative procedures relating to issuing, adjusting and revoking a license to provide services for organizing the cryptocurrency asset trading market have been introduced. Organizations and individuals interested in these administrative procedures can apply for from January 20, and find detailed information in the appendix attached to Decision 96.

The State Securities Commission is the agency directly responsible for receiving and processing applications, while the Ministry of Finance plays the leading role in appraising and deciding on licensing, in coordination with the State Bank of Vietnam and the Ministry of Public Security on matters related to anti-money laundering and system security.

According to Government Resolution No. 05/2025/NQ-CP on piloting the cryptocurrency asset market in Vietnam, organizations registering to provide services for organizing the cryptocurrency asset trading market must meet the following conditions: Firstly, the registering organization must be a Vietnamese enterprise, established and operating under the provisions of the Law on Enterprises. Secondly, the charter capital must be contributed in Vietnamese dong (VND), with a minimum amount of VND10,000 billion. Thirdly, regarding shareholder structure, at least 65% of the charter capital must be contributed by organizations; of which, over 35% of the charter capital must be contributed by at least two organizations, including commercial banks, securities companies, fund management companies, insurance companies, or technology enterprises. Each organization or individual is only allowed to contribute capital to one organization providing cryptocurrency asset services licensed by the Ministry of Finance. Fourthly, the registering organization must have a legal working office, ensuring full facilities, equipment, and technology systems suitable for providing services. Fifthly, regarding personnel, the General Director (Director) must have at least 2 years of experience in finance, securities, banking, insurance, or fund management. The Chief Technology Officer or equivalent position must have at least 5 years of experience in information technology. Additionally, the organization must have at least 10 technology personnel with network security certificates and at least 10 personnel with securities practice certificates working in related business departments. Sixthly, there must be risk management, information security processes; processes for providing a platform for issuing cryptocurrency assets; processes for custody, managing customer assets; transaction, payment processes; etc. Seventhly, the information technology system of the organization providing cryptocurrency asset services must meet level 4 information system security standards according to legal regulations on information security before being put into operation and exploitation.

Sourced by: Dr. Oliver Massmann, Partner & General Director of Duane Morris Vietnam LLC

  1. Tax Update: Vietnam’s Tax System Goes Digital – What Businesses Need to Know

“Now is the time to upgrade systems, processes, and compliance mindsets before the tax authorities bring this new reality to you.”

Vietnam is abolishing the lump-sum tax regime, signaling a decisive shift toward a modern, digital tax administration. For many businesses, this marks a fundamental change in how tax compliance is handled. Under the new approach, companies must comply with formal tax declarations, including electronic invoicing, digital bookkeeping, and enhanced documentation requirements. Tax authorities will increasingly rely on system-based data and cross-checks, reducing tolerance for informal or manual processes.

For foreign-invested enterprises, this change requires early operational readiness. Accounting systems must be aligned with Vietnamese digital tax standards, finance teams need appropriate training, and internal controls should ensure consistency between invoices, contracts, and tax filings.  Companies that previously operated under simplified regimes should review their compliance setup now. Investment in compliant IT systems and clear internal procedures is essential to avoid disruption during audits or inspections.

While the transition may create short-term challenges, the reform ultimately promotes greater transparency, consistency, and predictability. Digital tax compliance is no longer optional; it is becoming a core requirement for doing business in Vietnam.

Sourced by: Leif D. Schneider, Country Head of Luther Vietnam Law LLC

  1. Accounting Update: Circular 99/2025/TT-BTC: A Key Milestone Toward IFRS Adoption in Vietnam

From the 2026 financial year, enterprises in Vietnam are required to apply Circular 99/2025/TT-BTC, which is considered an important transitional step toward the adoption of IFRS in Vietnam. This Circular introduces several fundamental changes to the accounting framework, aiming to better align Vietnamese accounting practices with international standards.

One notable change is the renaming of financial statements, for example, the “Balance Sheet” is now referred to as the “Statement of Financial Position.” In addition, Circular 99 introduces new accounts, such as biological assets relevant for businesses dealing in agriculture or also global minimum tax expenses, to ensure consistency with IFRS concepts.

More fundamentally, Circular 99 represents a shift from a rule-based accounting regime to a more principle-based and flexible approach. While enterprises may refer to the standard templates for the chart of accounts, accounting vouchers, and accounting books provided under Circular 99, they are permitted to design, supplement, or modify these systems to better reflect their specific business characteristics and operational needs. However, such adjustments must be formally documented through internal accounting policies and regulations, clearly outlining the rationale and methodology for these changes to ensure transparency, consistency, and compliance.

Furthermore, the application of foreign currency in accounting and financial reporting has been significantly liberalized. Previously, enterprises were required to notify the tax authorities if they wished to use a foreign currency as their accounting currency. Under Circular 99, this notification requirement has been removed, offering greater flexibility for enterprises with foreign-related transactions.

In conclusion, while Circular 99 provides enterprises with more flexibility and alignment with IFRS, it also places greater responsibility on companies to establish robust internal accounting policies and governance frameworks to ensure compliance and consistency in practice.

Sourced by: Michael Wekezer, Country Manager of  Rödl Vietnam Legal

  1. Banking and Finance Update: Vietnam 2026: Strong Growth Outlook amid FX Vulnerabilities

Vietnam enters 2026 with one of Asia’s strongest macro backdrops. GDP growth reached 8% in 2025, driven by a surge in manufacturing, construction, resilient consumption, and a landmark year for infrastructure investment. With 560 projects launched, including the North–South high speed railway, public investment exceeded VND 5 quadrillion, setting the stage for sustained momentum. DB Research maintains a 7.7% GDP forecast for 2026, with upside risks stemming from continued infrastructure rollout, robust FDI and export diversification efforts.

For FX markets, however, Vietnam still faces meaningful near term vulnerabilities. The latest DB forecast (3 Feb 2026) expects USDVND to drift from 26,013 today toward 26,900 by end 2026, consistent with a controlled, macro driven depreciation path rather than disorderly weakness. FX risks remain centered on import led pressures, shallow reserve buffers, and the lingering effects of US tariff measures, which have elevated Vietnam’s sensitivity to trade and capital flow shocks. Infrastructure driven domestic demand also implies higher import needs, narrowing the trade surplus and reducing FX cushioning capacity.

Overall, while Vietnam continues to have one of APAC’s strongest growth profiles, FX volatility remains an important risk, reinforcing the need for disciplined hedging strategies around tenor, layering, and onshore/offshore execution.

Despite these pressures, Vietnam’s structural story remains resilient. Ongoing institutional reforms and strong FDI prospects should support medium term FX stability, although near term volatility is likely as global rates remain elevated and trade flows rebalance.

Sourced by: Quang Huynh, Chief Country Officer of Deutsche Bank Vietnam

  1. HR Update: Salary Development Trends in Vietnam 2026 across Key Industrial Sectors

Wage levels in Vietnam continue to rise in 2025, driven by sustained FDI inflows, industrial expansion, and ongoing shortages of experienced mid to senior professionals across technical disciplines.

Advanced manufacturing and automotive sectors recorded average salary increases of approximately 8% to 12%, particularly for production managers, automation engineers, and plant leadership roles.

Pharmaceuticals and life sciences saw stronger upward pressure of around 10% to 15%, especially in regulatory affairs, quality management, and technical commercial functions.

Logistics and supply chain experienced salary growth of roughly 7% to 10%, with high demand for procurement managers, warehouse automation specialists, and cross border operations professionals.

Electronics and industrial engineering remain talent constrained sectors, pushing compensation for senior engineers and operations leaders up by around 10% in key industrial hubs such as HCMC, Binh Duong, Dong Nai, Hanoi, and Bac Ninh.

Beyond base salary, companies increasingly compete through retention bonuses, accelerated promotion tracks, structured leadership development, and stronger employer branding initiatives.

Sourced by: Sebastian Schlitter, Partner of Vietnam Desk JP contagi

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The views expressed in each section reflect the professional assessment of the respective contributors and are shared for general informational purposes. Members are encouraged to consult directly with the contributing firms for tailored advice and further clarification where needed.