The consolidated circular incorporates changes from Circular 46/2026/TT-NHNN above.
Document dated Sep. 22, 2026, received from VIE GVT Sep. 23, summarized Sep. 24.
On Mar. 16, VIE CB proposed update to credit information and data protection.
VIE CB drafted circular updating Circular 15/2023/TT-NHNN to align with new laws.
Including the revised Law on Credit Institutions, Dec 26/2025/ND-CP on VIE CB structure, and Dec 329/2025/ND-CP on International Financial Center framework.
Expands scope to include member banks in Vietnam’s International Financial Centre (IFC) and defines related persons of borrowers for reporting to VIE CIC.
Clarifies that credit information activities serve regulatory/supervisory purposes for credit institutions and business purposes for voluntary organizations.
Strengthens compliance with the 2025 Law on Personal Data Protection, including adding prohibited acts and requirements on lawful data processing.
Revises reporting obligations by requiring IFC member banks to provide credit data to VIE CIC, covering lending, corporate bond investments, entrusted activities, and corporate financial statements (with flexible standards).
Clarifies data sharing rules, stating that customer consent is not required for regulatory use but is required for sharing with non-regulatory entities.
Assigns VIE CIC a central role in data sharing with IFC supervisory authorities and imposes obligations on VIE CIC for data protection compliance, including breach notification and cross-border transfer controls.
Updates VIE CB internal responsibilities and reinforces that credit institutions must comply with data protection and related legal requirements.
Effectiveness
Comments shall be submitted before Mar. 30, 2026.
Apr. 2026 Comments Received
On Apr. 24, 2026, VIE CB published the public comments received and its responses.
Document dated Apr. 24, 2026, received from VIE CB May 6, summarized on May 7.
Sep. 9, 2026 Circular Finalized
On Sep. 9, 2026, VIE GVT issued Circular 46/2026/TT-NHNN, the finalized version of the proposed update to 15/2023/TT-NHNN noted above.
The final circular retains the proposal's scope expansion to IFC member banks and foreign bank branches, and its electronic credit-data-reporting and borrower-consent provisions.
Inspection of credit information activity at IFC member banks will follow the IFC's own inspection regime.
The circular is effective from Nov. 1, 2026.
Document dated Sep. 9, 2026, received from VIE GVT Sep. 11, summarized Sep. 14.
Sep. 11, 2026 Press Release
On Sep. 11, 2026, VIE CB issued a press release on circular 46/2026/TT-NHNN.
Document dated Sep. 11, 2026, received from VIE CB Sep. 15, summarized Sep. 18.
