On 18 December 2025, the Vietnamese government issued Decree 323/2025 on the establishment of Vietnam International Financial Center (VIFC). Decree 323/2025 takes effect immediately and provides guidance for Article 8 and 9 of Resolution 222/2025 of the National Assembly on VIFC. In this post, we discuss some interesting points of Decree 323/2025

1. Single or multiple units

The National Assembly intends that VIFC is one single unit. To confirm this intention, Decree 323/2025 provides that VIFC is a unified legal unit (thực thể pháp lý thống nhất in Vietnamese). However, Vietnamese law does not have definition of legal unit (thực thể pháp lý). In addition, this provision of Decree 323/2025 also seems to contradict with Resolution 222/2025 which defines VIFC as an area with defined geographical boundaries.

However, by locating that single unit into two separate location, putting it under management of multiples authorties, and giving each location a different set of priorities, it is doubtful on how the operation of VIFC can be unified. This is evidenced by:

The VIFC is oddly named as “Viet Nam International Financial Center in Ho Chi Minh City (VIFC-HCMC) and Viet Nam International Financial Center in Da Nang City (VIFC-DN)” which compries two individual names within one single entity name.
The Operating Authority and Supervisory Authority of VIFC have legal person status, which implied that these authorities’ legal responsibility is independent with VIFC’s legal responsibility.

2. Development direction

Decree 323/2025 stipulates different development directions for VIFC-HCMC and VIFC-DN.

Development direction of VIFC-HCMC is to build a comprehensive and diverse financial ecosystem, which can exploit the synergistic effects of different financial services, including but not limited to traditional products, fintech and green finance.

Development direction of VIFC-DN focuses on sandbox for new types of financial services, including but not limited to digital assets and lending by organizations that do not take deposit from the public.

3. Priority business lines

Decree 323/2025 provides a list of priority business lines of VIFC. However, each of VIFC-HCMC and VIFC-DN may have its own list. The general list of priority business lines of VIFC 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. Five-year review

Decree 323/2025 provides that the operation of VIFC will be reviewed after 5 years and a restructuring plan may be implemented if necessary. This indicates that VIFC is still a pilot scheme and amendments are expected.

This post is written by Nguyen Hoang Duy and edited by Nguyen Quang Vu.

Vietnam Business Law