September 2026 Legal Update: Key Regulatory Developments affecting businesses and business activities in Vietnam.
BFSC’s October 2026 Legal Bulletin summarizes legal instruments promulgated or authenticated in September 2026, focusing on areas of law directly relevant to investment, business operations and corporate governance.
The legal developments recorded in September 2026 reflect continued regulatory refinement in a number of important areas, particularly trade and foreign investment, bidding, banking and credit, securities and corporate bonds, insurance, minerals, construction and infrastructure, real estate, taxation and corporate management.
Note: The following summary is based on BFSC’s October 2026 Legal Bulletin and covers legal instruments falling within the areas selected by BFSC. It is not intended to constitute a comprehensive list of all legal instruments promulgated in September 2026.
1. OVERVIEW: KEY LEGAL AND REGULATORY AREAS IN SEPTEMBER 2026
The legal instruments compiled by BFSC may generally be classified into the following principal groups:
| Sector / Business Activity | Key Regulatory Focus |
| Trade and Foreign Investment | Trading and distribution activities of foreign investors and foreign-invested economic organizations; foreign trade management; commodity exchanges; import and export activities |
| Bidding and PPP | Contractor selection, direct appointment of contractors, bidding dossiers, investor selection and public-private partnerships |
| Banking and Credit | Credit information, credit growth, guarantees, letters of credit, refinancing, lending, foreign exchange and interest-rate support |
| Securities and Corporate Bonds | Securities service fees, securities databases, data infrastructure and private placement of corporate bonds |
| Insurance | Agricultural insurance and related insurance policies and mechanisms |
| Minerals and Geology | Geological investigation, mineral exploration, reserves, exploitation, recovery, mine closure, mineral information and data |
| Construction and Infrastructure | Railways, inland waterways, aviation, roads, technical infrastructure, water supply and drainage, construction cost management |
| Real Estate, Housing and Urban Development | Project investor selection, urban development investment, housing support, construction management and infrastructure development |
| Corporate and State Capital Management | Restructuring of State capital, conversion of public service units into joint-stock companies, enterprise management and enterprise registration databases |
| Taxation and Financial Management | Natural resources tax, special consumption tax, tax administration, customs, ODA, public debt and Government guarantees |
| Data and Digital Transformation | Enterprise databases, securities databases, data management and administrative penalties in the data sector |
2. TRADE, IMPORT-EXPORT ACTIVITIES AND FOREIGN INVESTMENT
This is one of the key regulatory groups with direct implications for businesses engaged in trading, import-export activities and foreign-invested enterprises.
2.1. Trading Activities of Foreign Investors
Of particular importance is Decree No. 342/2026/ND-CP, which provides detailed regulations under the Law on Commerce and the Law on Foreign Trade Management concerning the purchase and sale of goods and activities directly related to the purchase and sale of goods by foreign investors and foreign-invested economic organizations in Vietnam. The Decree was promulgated on 3 September 2026 and takes effect on 18 October 2026.
This regulatory framework is particularly relevant to foreign-invested enterprises engaged in import, export, distribution and other activities directly related to the trading of goods.
2.2. Foreign Trade Management
Circular No. 48/2026/TT-BCT provides detailed regulations under the Law on Foreign Trade Management and Decree No. 292/2026/ND-CP.
Import-export enterprises should review the updated requirements concerning dossiers, procedures and regulatory requirements applicable to their foreign trade activities.
2.3. Commodity Exchanges
Circular No. 47/2026/TT-BCT addresses dossiers for establishment of commodity exchanges, reporting requirements and data connectivity in the trading of goods through commodity exchanges.
These regulations are relevant to entities participating in, or providing services relating to, organized commodity markets.
2.4. Rice Export and Import Business
Decree No. 365/2026/ND-CP regulates rice export and import business and is directly relevant to enterprises engaged in agricultural commodity trading and international trade.
In addition, consolidated instruments concerning HS-code-based lists of imported and exported goods were updated, providing a regulatory basis for classification and management of import and export goods.
3. BIDDING, CONTRACTOR SELECTION AND PUBLIC-PRIVATE PARTNERSHIPS
The bidding framework continued to be amended and supplemented in September 2026, covering both contractor selection and investor selection.
3.1. Contractor Selection
Decree No. 349/2026/ND-CP amends and supplements a number of Government decrees providing detailed regulations on contractor selection under the Law on Bidding.
The Decree was promulgated and took effect on 9 September 2026.
At the same time, Circular No. 134/2026/TT-BTC provides detailed forms and requirements concerning request dossiers for direct contractor appointment, evaluation reports, appraisal reports, inspection and supervision, and reports on the implementation of bidding activities.
These changes are relevant to:
- enterprises participating in bidding processes;
- contractors supplying goods and services;
- procuring entities;
- project owners;
- bidding consultants; and
- enterprises implementing projects subject to the Law on Bidding.
3.2. Bidding Training and Professional Certificates
Consolidated Instrument No. 43/2026/VBHN-TT-BTC consolidates regulations concerning training and professional development, examinations, and the issuance and revocation of professional certificates in bidding.
3.3. Investor Selection and PPP Projects
Consolidated Instrument No. 45/2026/VBHN-TT-BTC concerns bidding forms for investor selection in investment projects implemented under public-private partnership arrangements and investment business projects.
These provisions are particularly relevant to project developers, infrastructure investors and enterprises participating in PPP projects.
4. BANKING, CREDIT AND FINANCIAL ACTIVITIES
The banking and credit sector accounts for a significant portion of the September 2026 legal instruments compiled by BFSC. The instruments cover credit information, guarantees, refinancing, lending, interest-rate support and foreign exchange activities.
4.1. Credit Information
Circular No. 46/2026/TT-NHNN amends regulations on credit information activities.
This is relevant to credit institutions, borrowers and entities whose information is collected and processed within the credit information system.
4.2. Credit Growth
Official Letter No. 8509/NHNN-CSTT addresses credit growth in 2026.
4.3. Guarantees, Letters of Credit and Refinancing
The September list includes a number of consolidated instruments concerning:
- bank guarantees;
- letters of credit;
- refinancing;
- restructuring of repayment periods;
- lending backed by credit guarantee funds; and
- sector-specific credit support mechanisms.
4.4. Credit for Production, Agriculture and Supporting Industries
Several consolidated instruments update credit policies applicable to:
- agriculture and rural development;
- production forestry and livestock farming;
- fisheries;
- supporting industries;
- agricultural loss reduction;
- interest-rate support for production and business activities; and
- medium- and long-term loans for production and business investment.
4.5. Foreign Exchange and Foreign Borrowings
The September 2026 legal update also covers:
- foreign exchange transactions between the State Bank of Vietnam and credit institutions;
- foreign exchange market transactions; and
- management of foreign borrowings and repayment obligations of enterprises that are not guaranteed by the Government.
These regulations are particularly relevant to enterprises conducting cross-border transactions, maintaining foreign-currency payment obligations or obtaining foreign loans.
5. SECURITIES AND CORPORATE BONDS
The securities-related instruments mainly address service fees, securities databases, data connectivity and securities-market management infrastructure.
Notable instruments include:
- consolidated regulations on State-regulated securities service fees;
- consolidated regulations on the economic and technical characteristics of securities services;
- Decision No. 2491/QD-BTC concerning the architecture, connectivity, integration and data-sharing requirements of the specialized securities management platform/database; and
- Decision No. 2492/QD-BTC concerning the scope of use, users, operations, services, functions and features of the specialized securities management platform/database.
With respect to corporate bonds, Circular No. 138/2026/TT-BTC provides guidance on certain provisions of Decree No. 200/2026/ND-CP governing the offering and trading of privately placed corporate bonds in the domestic market and the offering of corporate bonds to the international market.
Corporate bond issuers should pay particular attention to requirements concerning documentation, issuance procedures, trading and ongoing compliance and disclosure obligations under the updated regulatory framework.
6. INSURANCE
The insurance-related developments in September 2026 primarily concern agricultural insurance.
Decree No. 346/2026/ND-CP amends and supplements a number of provisions of Decree No. 58/2018/ND-CP on agricultural insurance. The official Government legal database identifies Decree No. 346/2026/ND-CP as the instrument promulgated on 5 September 2026, rather than treating Decree No. 58/2018/ND-CP itself as a new September 2026 decree.
In addition, Consolidated Instrument No. 38/2026/VBHN-ND-BTC consolidates regulations governing agricultural insurance.
These instruments are directly relevant to insurance enterprises, agricultural businesses and other parties participating in agricultural insurance programs.
7. MINERALS AND GEOLOGY
Minerals and geology represent one of the most extensively regulated areas in the September 2026 BFSC legal update.
Resolution No. 66.25/2026/NQ-CP addresses difficulties and obstacles relating to State management functions, duties and powers concerning industrial parks, geology and minerals.
At the same time, the Ministry of Industry and Trade issued a series of circulars covering almost the entire mineral business cycle:
7.1. Geological and Mineral Investigation
- Circular No. 51/2026/TT-BCT;
- Circular No. 53/2026/TT-BCT.
7.2. Mineral Exploration and Reserve Assessment
- Circular No. 57/2026/TT-BCT;
- Circular No. 59/2026/TT-BCT.
7.3. Mineral Exploitation and Recovery
- Circular No. 54/2026/TT-BCT;
- Circular No. 58/2026/TT-BCT on mineral exploitation costs and forms.
7.4. Applications, Licences and Reports
- Circular No. 52/2026/TT-BCT;
- Circular No. 55/2026/TT-BCT.
7.5. Mine Closure
Circular No. 56/2026/TT-BCT regulates mine closure plans and schemes.
7.6. Mineral Information and Data
Circular No. 60/2026/TT-BCT regulates geological and mineral information and data.
Accordingly, from a business-process perspective, the September 2026 mineral regulations cover a broad chain: geological investigation → exploration → reserve assessment → licensing → exploitation → recovery → mine closure → mineral data management → natural resources tax.
8. CONSTRUCTION, INFRASTRUCTURE AND TRANSPORT
The construction and infrastructure regulatory framework was further updated across a number of areas, including railways, inland waterways, aviation, roads, technical infrastructure, water supply and construction investment cost management.
8.1. Railways
The September 2026 instruments address:
- management and operation of railway transport;
- management and operation of railway infrastructure;
- overall technical design of railway projects; and
- cost management for the Lao Cai – Hanoi – Hai Phong railway project.
Decree No. 352/2026/ND-CP amends regulations concerning overall technical design and special mechanisms applicable to certain railway projects.
Circular No. 70/2026/TT-BXD provides guidance on cost management for the Lao Cai – Hanoi – Hai Phong railway project.
8.2. Aviation and Airport Infrastructure
Circular No. 68/2026/TT-BXD regulates costs associated with the operation and exploitation of aviation infrastructure.
This is relevant to the determination and management of costs associated with State-invested and State-managed aviation infrastructure assets.
8.3. Water Supply and Urban Drainage
Circular No. 69/2026/TT-BXD regulates the information system for clean water supply and urban drainage.
8.4. Technical Infrastructure
Consolidated Instrument No. 81/2026/VBHN-TT-BXD concerns the National Technical Regulation on technical infrastructure systems.
8.5. Road Transport and Vehicles
The September legal update also covers:
- motor vehicle inspection;
- technical safety certification;
- environmental protection requirements for vehicles;
- manufacture and assembly of vehicles; and
- import of vehicles and vehicle components.
9. REAL ESTATE, HOUSING AND URBAN DEVELOPMENT
Although the September 2026 list does not consist exclusively of real estate regulations, a number of construction and infrastructure instruments have direct implications for real estate project development.
9.1. Urban Development Investment
Consolidated Instrument No. 88/2026/VBHN-TT-BXD concerns the determination and management of costs relating to urban development investment.
9.2. Project Investor Selection
Consolidated Instrument No. 78/2026/VBHN-TT-BXD concerns investor selection for investment and business projects involving rest-stop facilities.
9.3. Housing
Consolidated Instrument No. 86/2026/VBHN-TT-BXD provides guidance on determining entities eligible for housing support loans under Resolution No. 02/NQ-CP.
9.4. Construction Management
Consolidated Instrument No. 91/2026/VBHN-ND-BXD provides detailed regulations under the Law on Construction concerning construction activity management.
In addition, Resolution No. 66.26/2026/NQ-CP addresses livelihood support, stabilization of living conditions and resettlement for land users where the State recovers land for implementation of a nuclear power project.
These provisions may affect project implementation schedules, investor selection, investment costs, housing and land clearance and resettlement activities.
10. CORPORATE MANAGEMENT, STATE CAPITAL AND CORPORATE GOVERNANCE
Several September 2026 instruments focus on the management and restructuring of enterprises involving State capital.
10.1. Restructuring of State Capital
Decree No. 357/2026/ND-CP regulates the management and use of revenues generated from the restructuring of State capital in enterprises and the conversion of public service units into joint-stock companies.
10.2. Debt Management and Debt Trading
Decree No. 358/2026/ND-CP regulates the operational and financial management mechanisms applicable to the Vietnam Debt Trading Company.
Decree No. 359/2026/ND-CP regulates the establishment, organization, operation and financial mechanisms of the Vietnam Asset Management Company for credit institutions.
10.3. Enterprise Database
Decision No. 2624/QD-BTC establishes regulations concerning the scope, operations, services, functions and features of the National Enterprise Management Platform, i.e. the National Enterprise Registration Database.
These developments are relevant to corporate governance, enterprise registration, corporate restructuring and enterprise information management.
11. TAXATION, CUSTOMS AND FINANCIAL MANAGEMENT
11.1. Natural Resources Tax
Circular No. 135/2026/TT-BTC amends regulations on natural resources tax.
In addition, Consolidated Instrument No. 33/2026/VBHN-TT-BTC consolidates regulations guiding the implementation of natural resources tax.
These provisions are particularly relevant to enterprises engaged in mineral exploitation and other activities subject to natural resources tax.
11.2. Special Consumption Tax
Circular No. 136/2026/TT-BTC amends regulations concerning the implementation of certain provisions of the Law on Special Consumption Tax.
11.3. Tax Administration
Decision No. 2551/QD-BTC corrects Circular No. 89/2026/TT-BTC concerning tax administration and Decree No. 252/2026/ND-CP.
11.4. Customs
Circular No. 142/2026/TT-BTC amends customs procedures applicable to exported, imported and transit goods sent through postal services and international express delivery services.
11.5. ODA and Public Debt
The September list also includes consolidated instruments concerning:
- official development assistance (ODA);
- foreign concessional loans;
- public debt management; and
- Government guarantees.
12. DATA, DIGITAL TRANSFORMATION AND INFORMATION SYSTEMS
Another notable trend in September 2026 is the continued development of data infrastructure and data-management mechanisms.
The instruments compiled by BFSC address:
- specialized securities databases;
- the National Enterprise Management Platform;
- data-related activities, products and services;
- administrative penalties in the data sector;
- data connectivity and sharing in commodity exchange activities; and
- environmental databases in the industry and trade sector.
Decree No. 363/2026/ND-CP provides regulations on administrative penalties in the data sector, while decisions and circulars issued by the Ministry of Finance and the Ministry of Industry and Trade continue to develop, standardize and connect specialized databases.
For enterprises, this trend increasingly requires attention to data governance, information standardization, system connectivity, data sharing and compliance with applicable data-management requirements.
13. OTHER SECTORS AND BUSINESS ACTIVITIES COVERED
In addition to the principal areas discussed above, BFSC’s October 2026 Legal Bulletin also updates a number of other sectors, including:
- education and vocational education;
- tourism;
- energy and electricity;
- Vietnamese employees working for foreign organizations and individuals;
- science, technology and innovation;
- cybersecurity and civil cryptography;
- environmental protection;
- maritime activities; and
- healthcare.
These developments demonstrate that the September 2026 regulatory agenda was not limited to any single business sector, but covered a broad range of matters affecting the investment and operating environment for enterprises.
14. FROM A BUSINESS PERSPECTIVE: WHAT SHOULD ENTERPRISES REVIEW?
Based on the legal instruments summarized above, enterprises may prioritize their compliance review according to their actual business activities rather than merely by the issuing authority.
For Trading and Import-Export Enterprises
Enterprises should review regulations concerning:
- trading rights and conditions applicable to foreign investors;
- export and import activities;
- foreign trade management;
- HS codes;
- customs procedures; and
- commodity exchange activities.
For Foreign-Invested Enterprises
Particular attention should be paid to:
- the scope of permitted business rights;
- purchase and sale of goods;
- distribution activities;
- import and export activities; and
- conditions and procedures applicable to commercial activities.
For Enterprises Participating in Bidding
Enterprises should update their understanding of:
- contractor selection;
- direct contractor appointment;
- request dossiers;
- evaluation reports;
- appraisal reports;
- bidding training and professional certificates;
- investor selection; and
- PPP projects.
For Banks and Borrowing Enterprises
Key areas for review include:
- credit information;
- guarantees;
- letters of credit;
- refinancing;
- restructuring of repayment periods;
- sector-specific credit policies;
- interest-rate support;
- foreign exchange transactions; and
- foreign borrowings.
For Securities Firms and Corporate Bond Issuers
Enterprises should review:
- securities service fees;
- securities databases;
- data connectivity and sharing;
- corporate bond issuance and trading; and
- capital-market compliance and disclosure obligations.
For Mineral Exploitation Enterprises
Particular attention should be paid to the entire operational chain:
geological investigation → exploration → reserve assessment → licensing → exploitation → recovery → cost management → mine closure → mineral data management → natural resources tax.
For Construction and Infrastructure Investors
Enterprises should update regulations concerning:
- construction cost management;
- technical design;
- railway projects;
- PPP projects;
- aviation infrastructure;
- railway infrastructure;
- technical infrastructure;
- water supply and drainage;
- transport vehicles; and
- construction activity management.
For Real Estate Enterprises
Enterprises should review issues relating to:
- investor selection;
- urban development investment;
- construction activity management;
- investment costs;
- housing;
- technical infrastructure; and
- land clearance and resettlement in projects subject to State land recovery.
15. CONCLUSION
The legal instruments compiled by BFSC for September 2026 indicate several notable regulatory trends.
First, the legal framework governing trade and foreign investment continues to be refined, particularly in relation to the trading of goods by foreign investors and foreign-invested economic organizations.
Second, the legal framework for bidding and PPP continues to be developed, with particular attention to contractor selection, direct contractor appointment, bidding dossiers and investor selection.
Third, banking and credit regulations continue to evolve across a broad range of areas, including credit information, guarantees, refinancing, sector-specific lending, interest-rate support and foreign exchange.
Fourth, mineral regulations underwent significant development, with a series of circulars covering almost the entire operational chain from geological investigation and exploration to exploitation, mine closure and mineral data management.
Fifth, construction and infrastructure regulations continued to be refined, particularly in relation to railways, aviation, technical infrastructure, transport and investment cost management.
Sixth, the capital markets and insurance sectors continued to receive regulatory updates, including securities, corporate bonds and agricultural insurance.
Overall, the September 2026 regulatory developments may have significant implications for business conditions, investment procedures, corporate governance, financing, international trade, project development and compliance obligations.
Enterprises should not limit their legal review to instruments whose titles directly refer to their registered business lines. Instead, they should assess the entire business operation chain, covering investment, licensing, finance, contracts, bidding, construction, operations, taxation and compliance reporting.
Source: BFSC’s October 2026 Legal Bulletin – a compilation of legal instruments promulgated or authenticated in September 2026 within the areas selected by BFSC. The Bulletin is not intended to constitute a comprehensive list of all legal instruments promulgated during September 2026.
DISCLAIMER
BFSC’s monthly legal bulletin only summarizes selected legal instruments relevant to the sectors and areas of practice covered by BFSC. It does not constitute a complete compilation of all legal instruments promulgated during the relevant month.
The information provided in this article is for reference purposes only and should not be regarded as legal advice. Where a specific legal or compliance issue arises, clients should provide BFSC with the relevant facts and applicable legal documents so that an accurate and up-to-date legal review can be conducted.
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