Tiếng Việt
中文Short answer: Procedures and dossiers for applying to the State Bank for a License are now carried out under Circular 39/2025/TT-NHNN (effective 15/12/2025), replacing Circular 20/2015/TT-NHNN. All citations of Circular 20/2015 now have only historical reference value.
Current legal framework
- Law on Credit Institutions No. 32/2024/QH15 (effective 01/7/2024) — provisions on conditions and licensing authority for establishment and operation Licenses of credit institutions and foreign bank branches;
- Circular 39/2025/TT-NHNN (effective 15/12/2025) — provisions on dossiers, order, and procedures for License issuance; replacing Circular 20/2015/TT-NHNN and amending documents.
Dossier for License application
The dossier for License application is prepared under Circular 39/2025/TT-NHNN, including the main document groups:
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- Application for License issuance in the prescribed form;
- Establishment scheme and business operation plan (organizational model, business plan, internal control system, risk management);
- Documents proving the financial capacity of founders, capital-contributing members/founding shareholders;
- List of expected managerial, executive, and supervisory personnel with dossiers proving they meet the standards and conditions under the Law on Credit Institutions 2024;
- Draft charter of the credit institution;
- Other documents as detailed in Circular 39/2025/TT-NHNN corresponding to each type of credit institution.
Implementation order
- Prepare and file the dossier with the State Bank as prescribed;
- Dossier appraisal: the State Bank reviews the completeness and validity of the dossier; where the dossier is incomplete, it issues a written request for supplementation;
- Consideration of in-principle approval and related contents on expected personnel and charter;
- License issuance upon full satisfaction of the conditions under the Law on Credit Institutions 2024 and Circular 39/2025/TT-NHNN.
Key notes
- License issuance conditions (minimum charter capital, ownership structure, personnel standards, etc.) are prescribed in the Law on Credit Institutions 2024 and guiding documents of the Government and the State Bank — they should be fully checked before filing;
- As Circular 39/2025/TT-NHNN only took effect on 15/12/2025, detailed forms and processes should be checked directly against the original text when implementing.
How ANT Legal can assist
ANT Legal advises on conditions and dossiers for bank operation License applications, drafts establishment schemes, and represents clients in working with the State Bank. For advice on your specific case, please contact our lawyers at 0966.475.966.
