Key words: VIFC, IFC, International Financial Center, foreign investment, investment, establish

 

On December 18, the Government announced the establishment of the International Financial Centre (IFC) of Vietnam, adopting the “One Centre – Two Destinations” model with parallel operations in Ho Chi Minh City and Da Nang.

In the context of accelerating economic globalization and deeper financial integration, the development of IFCs has become an increasingly common global trend. Beyond serving as hubs for financial institutions such as banks, securities firms, and insurance companies, IFCs represent distinctive institutional spaces with a high level of competitiveness, designed to attract international capital flows, advanced technologies, and high-quality global resources.

 

1. INTRODUCTION

Competition from established IFCs like Singapore, Hong Kong, or even emerging centers like Bangkok or Kuala Lumpur is intense. Therefore, the importance of studying and building the first IFC for Vietnam from the experiences of around the world, both successes and failures, is an undeniable mission.

To Viet Nam, the IFC is positioned as a gateway for attracting international capital, contributing to sustainable economic growth and deep integration into the global financial system. According to clause 1, Article 3 Decree No.323/2025/NĐ-CP, IFC is a unified legal unit (thực thể pháp lý thống nhất in Vietnamese). However, Vietnamese law does not have a definition of a legal unit (thực thể pháp lý).

In addition, according to clause 2, Article 3 Decree No.323/2025/NĐ-CP, “a unified legal unit” will be placed at two separate destinations, placing it under the management of multiple authorities, and assigning each location a distinct set of development priorities; the ability to ensure unified operations of VIFC remains open to question. Specifically, the “Viet Nam International Financial Center in Ho Chi Minh City (VIFC-HCMC)” is used for the IFC placed in HCMC, and the “Viet Nam International Financial Center in Da Nang City (VIFC-DN)” is used for the IFC placed in Da Nang City.

Both the Operating Authority and the Supervisory Authority of the VIFC are granted legal person status under the regulatory framework (Article 10). This implies that these authorities bear legal rights and obligations independent from those of the VIFC itself, potentially blurring lines of accountability and further complicating the notion of a unified legal and operational structure.

 

2. DEVELOPMENT DIRECTION

Under this special model, the two cities are combined to optimise their respective advantages. HCM City is positioned to become a large-scale financial hub, with a planned area of about 898 hectares (clause 1, Article 5), concentrating on core activities such as stock and bond markets, banking, fund management, and international listing services.

On January 28, 2026, the Executive Body of the International Financial Center in HCMC - the Ho Chi Minh City Institute for Development Studies (HIDS) organized a consultation workshop on the Strategy to develop the Vietnam International Financial Center (VIFC) in HCMC. In the workshop, Dr. Truong Minh Huy Vu, Director of HIDS and Chairman of the VIFC-HCMC Executive Body, emphasized that VIFC-HCMC will focus on spearhead product groups, including: International capital markets, Trade finance, Digital banking and Fintech, along with niche areas such as Maritime finance, Green finance, and Venture capital funds in accordance with international practices.

Da Nang, by contrast, with a planned area of about 300 hectares (clause 2, Article 5), plays a strategic supporting role. Da Nang will place a strong emphasis on innovation, with a focus on the application of strategic technologies such as the innovation ecosystem, digital technology, and sustainable finance, establishing a regulatory sandbox for new financial models, pioneering the roll-out and expansion of digital asset products, digital payments, trading platforms, and specialized exchanges; promoting supply chain finance, third-party services, and non-deposit-taking lending institutions to complement and support the traditional financial market, forming specialized, flexible, and innovative financial products.

The specific investment sectors of VIFC-HCM and VIFC-DN to be prioritized and corresponding incentive polices shall be determined by the Operating Authority of the IFC at the local level (Article 10).

 

3. PRIORITY BUSINESS LINES

According to Article 6, Decree No.323/2025/NĐ-CP provide Appendix of List of business lines, sectors, products, and services prioritized for development at the IFC.

In general, the list contains 6 groups as follows:

• Infrastructure development for VIFC;
• Green finance and ESG finance (notably including carbon credit market);
• Market of goods, derivatives goods and international trade finance (notably including sandbox for commercial finance products using blockchain);
• Fintech and innovation (notably including new finance products like asset tokenization and stablecoin);
• Investment fund and asset management services; and
• Professional support services and other areas.

 

4. OPERATIONAL FRAMEWORK OF THE VIFC

The operations of the VIFC are administered by three principle bodies, namely the Operating Authority, the Supervisory Authority, and Dispute Resolution Authority (clause 2, Article 2):

[1] The Operating Authority

The Operating Authority comprises the Executive Council and the central Operating Authorities located in Ho Chi Minh City and Da Nang City.

The Executive Council is empowered to promulgate the Operational Regulations or other equivalent instruments to provide detailed rules on the organization and operation of the IFC, provided that such regulations are not contrary to the Constitution, international treaties to which Vietnam is a party, and that they comply with international practices and standards, while ensuring consistency with the fundamental principles and policies set out in Resolution No. 222/2025/QH15 and its implementing and guiding instruments.

The Operating Authorities in Ho Chi Minh City and Da Nang City are respectively placed under the Ho Chi Minh City People’s Committee and the Da Nang City People’s Committee.

 

[2] The Supervisory Authority

Pursuant to Article 11 of Decree No. 323/2025/NĐ-CP, the Supervisory Authority of the VIFC shall be established, headquartered in, and placed under the management of the Ho Chi Minh City People’s Committee. The Supervisory Authority may establish branch offices in Da Nang City.

The Chairperson of the Supervisory Authority is vested with the authority to decide on the establishment, organizational structure, functions, and duties of such branches, and to ensure their independent, regular, and continuous operation in the performance of the assigned powers and responsibilities.

The Supervisory Authority is responsible for conducting inspection, examination, supervision, prevention, and handling of violations within the VIFC, in accordance with its powers and duties as prescribed in clauses 2 and 3, Article 12 of the Decree, as well as other relevant legal instruments. These activities are aimed at ensuring that the operations of members, investors, organizations, and individuals within the VIFC comply with applicable laws and regulations.

[3] Dispute Resolution Authority

The dispute resolution mechanism within the Vietnam International Financial Centre (VIFC) comprises a Specialized Court and an International Arbitration Centre under the VIFC (Clause 1, Article 14).

Unlike the model of specialized courts that operate independently from the national judicial system, as seen in Dubai, Astana, or Abu Dhabi, the Specialized Court of the VIFC follows the model adopted in China, Hong Kong, and the United Kingdom. Under this approach, the Specialized Court is integrated into and operates as part of the national court system.

Specifically, Clause 1, Article 4 of the Law on Specialized Courts at the International Financial Centre (Law No. 150/2025/QH15) expressly provides that: “The Specialized Court at the International Financial Centre is a court within the People’s Court system, organized and operating in accordance with this Law, and having jurisdiction to adjudicate and resolve cases arising at the International Financial Centre”. In addition, the procedural rules applicable to proceedings before the Specialized Court shall be promulgated by the Supreme People’s Court in accordance with Clause 2, Article 4 of the Law.

 

5. MEMBER OF THE VIFC

According to clause 1, Article 2, Members of the IFC (“Members”) are investors, organizations, and individuals involved in investment and business and dispute resolution within the VIFC.

According to Clause 2, Article 3 of Resolution No. 222/2025/QH15:

“2. Members of the International Financial Centre (hereinafter referred to as ‘Members’) are entities that are recognized as Members of the International Financial Centre through registration, recognition as Members, or the granting of licenses for establishment and operation in accordance with this Resolution and its implementing and guiding instruments, including:

(a) Commercial banks, branches of foreign banks, securities companies, insurance enterprises, and reinsurance enterprises;

(b) Investment funds and asset management entities;

(c) Market infrastructure institutions;

(d) Financial technology and digital asset organizations;

(e) Consulting and support service providers;

(f) Non-financial organizations;

(g) Other entities as prescribed by the Government.”

Accordingly, based on the above provisions, Members of the VIFC may be understood as entities that are recognized as Members through registration, formal recognition as Members, or the issuance of licenses for establishment and operation in accordance with applicable regulations.

Currently, Decree No. 323/2025/NĐ-CP/ND-CP grants the VIFC Operating Authorities in Ho Chi Minh City and Da Nang City the authority to issue, amend, supplement, and revoke Certificates of Member Registration, as well as licenses for establishment and operation in the banking, securities, insurance sectors, and other sectors falling within the competence of the IFC (Point a), clause 5, Article 10)

 

6. FIVE-YEAR REVIEW AND POLICY IMPLICATIONS

Pursuant to Clause 3, Article 4 of Decree No. 323/2025/NĐ-CP/ND-CP, the operation of the Vietnam International Financial Centre (VIFC) is subject to a comprehensive review after five years of implementation. Based on the outcomes of such review, the competent authorities may decide to adjust, restructure, or further refine the organizational and operational model of the VIFC, where necessary.

This provision suggests that the VIFC is being implemented as a pilot institutional framework rather than a finalized and rigid model. The inclusion of a mandatory review mechanism reflects the Government’s cautious and adaptive regulatory approach, allowing room for policy recalibration in response to practical challenges, market feedback, and international developments in financial centre governance.

From an investor and institutional perspective, while the pilot nature of the VIFC may raise concerns regarding regulatory stability and long-term predictability, it also demonstrates a willingness on the part of Vietnamese authorities to proactively address structural shortcomings and align the VIFC framework with international best practices over time. In this sense, the five-year review mechanism can be viewed both as a regulatory risk factor and as an opportunity for iterative improvement and legal refinement - a fundamental condition underpinning the sustainable and long-term development of the VIFC.