New Gold Bar Trading License under Circular 34/2025 in Vietnam

The business of buying and selling gold bars is a conditional business line, subject to strict management by the State Bank of Vietnam. Recently, Circular 34/2025/TT-NHNN, guiding some provisions of Decree 24/2012/ND-CP, amended and supplemented by Decree 232/2025/ND-CP, was issued, officially bringing the gold market into operation under a new mechanism, including many new regulations on licenses for buying and selling gold bars. This Circular replaces Circular 16/2012/TT-NHNN (which has been amended and supplemented many times) and takes effect from October 10, 2025. Below, Viet An Law will update some notable new regulations on the new gold bar trading license under Circular 34/2025 in Vietnam.

Regulations on the application dossier for a new gold bar trading license under Circular 34/2025 in Vietnam

According to Article 4 of Circular 34/2025/TT-NHNN, the application dossier for a gold bar trading license includes:

• Application form for issuance of licenses to trade gold bars using Form specified in Appendix 02 attached Circular 34/2025/TT-NHNN
• List of locations registered as business locations for sale and purchase of gold bars (headquarters, branches, business locations).
• Certificate of registration of branch operation (for enterprises); document showing the location registered as a business location for sale and purchase of gold bars according to the list in Clause 2 of this Article that has been notified to the competent business registration authority in accordance with law.
• Confirmation from the tax authority on the amount of tax paid for gold business activities in the previous 2 (two) consecutive years for the enterprise.

Therefore, this new regulation in Circular 34/2025/TT-NHNN is similar to the previous regulation in Article 9 of Circular 16/2012/TT-NHNN (which has been amended and supplemented many times). However, customers should note that they need to update the application form for a license to trade in gold bars to the latest version according to Appendix No. 02 issued with Circular 34/2025/TT-NHNN.

Instructions for submitting an online dossier for a gold bar trading license

Previously, Circular 16/2012/TT-NHNN (which has been amended and supplemented several times) only stipulated online submission for the procedures of granting temporary import permits for raw gold for re-export and the procedures for adjusting temporary import permits for raw gold for re-export. However, the new regulation in Article 12 of Circular 34/2025/TT-NHNN provides guidance on online submission of dossiers for gold bar trading license, specifically:

• The application may be submitted Online via the National Public Service Portal or the National Single-window Portal (if any);
• For case of online submission via the National Public Service Portal or the National Single-window Portal (if any), the electronic application (e-application) may use a digital signature in accordance with the laws on online administrative procedures;
• Where the National Public Service Portal or the National Single-window Portal encounters a malfunction or error that prevents the reception or exchange of electronic information, the declaration, submission, receipt, return of results, exchange, and response of information shall be carried out by post or directly at the Single-window Division of the SBV or Single-window Division of the SBV’s regional branch.
• Documents in the e-application shall be electronic scans from the original/original copy (in PDF format).
• The result of administrative procedure resolution shall be delivered to organizations via online methods or by post or direct delivery at the Single-window Division of the SBV or its Regional Branch.

Thus, the new regulations in Circular 34/2025/TT-NHNN have created more favorable conditions for enterprises in carrying out procedures to apply for gold bar trading licenses, helping to save time and costs and promoting digital transformation in the field of gold trading management.

The procedure for obtaining a new gold bar trading license under Circular 34/2025 in Vietnam has been shortened to 20 days

According to Article 16 of Circular 34/2025/TT-NHNN, the procedure for granting a license to trade in gold bars is as follows:

• The applicant for issuance of a License to trade gold bars who is an enterprise/credit institution shall submit 01 application to the SBV.
• After receiving a complete application, the SBV shall inform its local Regional Branch to inspect the legal documents proving ownership or lawful use rights of the business premises (for enterprises) and the condition of equipment necessary to carry out gold bar trading activities at the registered business location.
• Within 7 (seven) working days from the date of receiving the notification from the SBV, its Regional Branch shall report the inspection results to the SBV (Foreign Exchange Management Department).
• Within 20 (twenty) working days from the date of receiving a complete and valid application as prescribed in Article 4 hereof, the SBV shall issue or refuse to issue (clearly stating the reason) a gold bar trading license.

Previously, Clause 4, Article 15 of Circular 16/2012/TT-NHNN (which has been amended and supplemented many times) stipulated the time limit for issuing a gold bar trading license as “Within 30 (thirty) working days from the date of receiving a complete and valid application from the enterprise or credit institution”.

Thus, the new regulations in Circular 34/2025/TT-NHNN have shortened the time for issuing gold bar trading licenses from 30 working days to 20 working days. This shows that the State Bank of Vietnam is accelerating administrative procedure reforms, aiming to increase transparency, efficiency, and timeliness in the licensing process, while creating more favorable conditions for enterprises and credit institutions participating in the gold market.

New regulations on revoking gold bar trading licenses

Previously, Circular No. 16/2012/TT-NHNN referred to this as the procedure for “termending the business of buying and selling gold bars” while the new regulation in Article 23 of Circular No. 34/2025/TT-NHNN calls it the procedure for “revoking the gold bar trading license”.

Accordingly, the revocation of a gold bar trading license is divided into two cases as follows:

In case the enterprise/credit institution voluntarily terminates gold bar trading

The enterprise/credit institution shall submit to the SBV an application including:

• Application form for voluntary termination of gold bar trading clearly stating the reason;
• Original copy of the License to trade gold bars and original copies of documents that are inseparable parts of the gold bar trading license of the enterprise/credit institution (if any);

Within 10 (ten) working days from the date of receiving a complete and valid application, the Governor of the SBV shall issue Decision on revocation of the gold bar trading license.

In case the enterprise/credit institution is required to terminates gold bar trading

• Due to dissolution or bankruptcy under the law;
• Upon request of a competent state agency, the Foreign Exchange Management Department shall request the Governor of the SBV to issue a Decision on revocation of the gold bar trading license.

Within 5 (five) working days from the date of receiving the Decision on termination of gold bar trading of the SBV, the enterprise/credit institution must return the original copy of the License to trade gold bars and the original copies of documents that are inseparable parts of the License to trade gold bars (if any) and immediately cease gold bar trading.

Compared to previous regulations, the new regulations have shortened the processing time for voluntary termination of gold trading activities from 15 days to 10 days. At the same time, they specify two cases in which gold trading activities will be required to cease.

By December 31, 2025 at the latest, businesses trading in gold bars must publicly list gold bar prices and connect their data

According to Article 29 of Circular 34/2025/TT-NHNN, enterprises and credit institutions engaged in the business of buying and selling gold bars have the following responsibilities:

• On a daily basis or as necessary, enterprises and credit institutions granted a License to trade gold bars shall submit a report to the SBV on the trading quantity of gold bar ;
• Enterprises and credit institutions granted a License to trade gold bars that have changes in information on the business license (including changes in company name, address of gold bar business locations, additions of new business locations, or termination of gold bar trading at licensed locations) shall send quarterly report on these changes occurring during the reporting period;
• Enterprises and credit institutions granted Licenses to trade gold bars by the State Bank of Vietnam must publicly post the buying and selling prices of gold bars at their business locations or on their websites, and connect to the SBV to provide information on the posted prices as guided by the SBV.

Accordingly, the deadlines for submitting periodic reports are as follows:

• For daily periodic reports: no later than 2 PM on the next working day following the reporting date.
• For quarterly periodic reports: no later than the 15th (fifteenth) of the first month of the quarter following the reporting quarter.

Thus, the new regulations have added the responsibility to publicly display the buying and selling prices of gold bars at business locations, gold trading points, or on websites, and to connect and provide information on the listed prices to the State Bank of Vietnam.

Accordingly, Clause 5, Article 33 of Circular 34/2025/TT-NHNN stipulates that the latest deadline for completing the listing and data connection of gold prices is December 31, 2025. After this date, any failure to comply will be considered a violation of State management regulations in the field of gold trading.

The above is an update on some notable new regulations regarding new gold bar trading license under Circular 34/2025 in Vietnam. If you have any related questions or require advice on procedures and documentation in the gold trading sector, please contact Viet An Law for the best support!