Circular 80/2025/TT-NHNN: New Regulations on Foreign Loan Registration in Vietnam

On December 31, 2025, the State Bank of Vietnam issued Circular No. 80/2025/TT-NHNN, amending and supplementing a number of articles of Circular 12/2022/TT-NHNN on foreign exchange management regarding foreign borrowing and repayment of enterprises. This Circular takes effect from January 25, 2026, including many new regulations focusing on adjusting regulations related to foreign loan registration Vietnam, the opening and use of foreign borrowing and repayment accounts, money transfers for loan implementation, and related reporting obligations.

Updating Circular 80/2025/TT-NHNN: New points on foreign loan registration

Circular 80/2025/TT-NHNN has many new points on foreign loan registration, specifically:

New points on foreign loan registration

• Amending and supplementing regulations on foreign loans subject to registration;
• Supplementing cases of exemption from registration for changes to foreign loans;
• Increasing the value of foreign loans under the handling authority of the State Bank from 10 million USD to 20 million USD;
• Clearly stipulating the validity period of the commercial bank’s confirmation document in the application for registration of changes to the loan;
• Clearly separating payment accounts in foreign currency and payment accounts in Vietnamese Dong;
• Allowing the borrower to receive disbursement money and transfer debt repayment money from the account of an intermediary organization;
• Requiring reporting if the foreign loan currency is different from the prescribed foreign currency.

Amending and supplementing regulations on foreign loans subject to registration

According to the new regulations in Article 4 of Circular 80/2025/TT-NHNN amending and supplementing regulations on loans subject to registration, which clarifies the case of short-term loans without an extension agreement but still have an outstanding principal balance at the time of one full year from the date of the first capital withdrawal.

Compared to Clause 3, Article 11 of Circular 12/2022/TT-NHNN, the new Circular clearly supplements cases excluded from registration obligations, including the case where the borrower completes the payment of the entire outstanding principal balance, converts the entire outstanding principal balance into shares, capital contribution of the lender, or is forgiven the entire principal repayment obligation within 30 working days from the time of one full year. These changes align with the updated SBV foreign debt regulations outlined in Circular 80/2025/TT-NHNN: New regulations on foreign loan registration in Vietnam.

Supplementing cases of exemption from registration for changes to foreign loans

According to Article 7 of Circular 80/2025/TT-NHNN, enterprises do not have to carry out procedures to register changes to the loan in case of changing the principal repayment amount arising from the forgiveness of the principal debt by the lender, the guarantor performing the guarantee obligation, or the parties handling the collateral to settle obligations according to the guarantee agreement or loan agreement. This simplifies FDI loan compliance for many enterprises.

Accordingly, for this case, it is only necessary to notify the changed content on the Electronic portal. This is a newly amended and supplemented regulation of Clause 2, Article 17 of Circular 12/2022/TT-NHNN.

Increasing the value of foreign loans under the handling authority of the State Bank from 10 million USD to 20 million USD

According to Article 10 of Circular 80/2025/TT-NHNN regulating the authority to confirm registration, registration for changes to foreign loans as follows:

Authority to confirm registration and changes to foreign loans

• Loans over 20 million USD (or other currencies of equivalent value) handled by the State Bank (Foreign Exchange Management Department);
• Loans up to 20 million USD (or other currencies of equivalent value) handled by the State Bank’s Regional branch where the borrower’s head office is located.

Thus, compared to Clause 1, Article 20 of Circular 12/2022/TT-NHNN, the new regulation has increased the value of foreign loans under the handling authority of the State Bank from 10 million USD to 20 million USD. This is one of the notable Vietnam central bank updates 2026.

Clearly stipulating the validity period of the commercial bank’s confirmation document in the application for registration of changes to the loan

• According to Article 9 of Circular 80/2025/TT-NHNN, the confirmation document of the account service provision bank in the application dossier for registration of changes to the loan must be issued within 10 working days before the time the enterprise submits the application for registration of changes to the loan regarding the situation of capital withdrawal, debt repayment (principal and interest) up to the time of registration of changes to the loan for cases of registering changes to the loan amount, capital withdrawal plan, debt repayment plan, or changing the commercial bank providing account services.
• Previously, Clause 6, Article 19 of Circular 12/2022/TT-NHNN only stipulated the confirmation document of the account service provision bank on the situation of capital withdrawal, debt repayment (principal and interest) up to the time of registration of changes to the loan for cases of registering changes to the loan amount, capital withdrawal plan, debt repayment plan, or changing the commercial bank providing account services.

Thus, while Circular 12/2022/TT-NHNN only required a bank’s confirmation document on the situation of capital withdrawal and debt repayment without clearly stipulating the time of issuing the document, Circular 80/2025/TT-NHNN has specifically set: this document must be issued within 10 working days before the time of submitting the application.

When preparing the application, enterprises are forced to calculate the time to request the bank’s confirmation so that it matches the time of submitting the application. If exceeding the 10-working-day time limit, the confirmation document may no longer be valid, leading to the risk of the application being requested for supplementation or rejected. Such strict timelines highlight the importance of understanding Circular 80/2025/TT-NHNN: New regulations on foreign loan registration in Vietnam.

Clearly separating payment accounts in foreign currency and payment accounts in Vietnamese Dong

Circular 80/2025/TT-NHNN regulating the contents of collection and spending on foreign borrowing and repayment accounts is amended towards clearly separating payment accounts in foreign currency and payment accounts in Vietnamese Dong. Specifically:

Foreign borrowing and repayment accounts are payment accounts in foreign currency

Article 28 of Circular 80/2025/TT-NHNN supplements and clarifies revenues from buying foreign currency at permitted credit institutions to perform the obligation to repay principal, interest, and fees of foreign loans as well as repaying debt acknowledgment amounts arising between the borrower and the guarantor according to regulations. This further details the SBV foreign debt regulations regarding currency controls.

At the same time, it specifically regulates the sale of foreign currency to permitted credit institutions, including the case of selling foreign currency to perform the obligation to repay foreign loans in Vietnamese Dong.

Foreign borrowing and repayment accounts are payment accounts in Vietnamese Dong

For foreign borrowing and repayment accounts that are payment accounts in Vietnamese Dong, Article 29 of Circular 80/2025/TT-NHNN amends the regulations towards clearly identifying legal sources of revenue, including revenue from transfers from the borrower’s payment account in Vietnamese Dong or revenue from selling foreign currency to permitted credit institutions. These clear distinctions make foreign loan registration Vietnam processes more transparent.

Besides, the Circular clarifies the transfer to the lender’s payment account in Vietnamese Dong to pay the principal and interest of the loan; simultaneously supplements regulations on debt payment in case the foreign loan is not eligible for registration confirmation or the registration confirmation document, registration for changes is terminated due to fraudulent information or forged documents in the application.

Allowing the borrower to receive disbursement money and transfer debt repayment money from the account of an intermediary organization

Regarding money transfers to implement foreign loans, Article 14 of Circular 80/2025/TT-NHNN supplements the regulation allowing the borrower to receive disbursement money and transfer debt repayment money from the account of an intermediary organization in case of early debt repayment through repurchasing international bonds according to the conditions, terms of the bonds, and regulations of the market where the bonds are listed and traded.

Besides, the Circular clarifies the principle of transferring money for debt repayment in Vietnamese Dong in cases where the loan is not eligible for registration confirmation or the registration confirmation document is terminated, accompanied by specific regulations on the applicable exchange rate and the requirement of a written agreement between the borrower and the lender. All these provisions are key elements of Circular 80/2025/TT-NHNN: New regulations on foreign loan registration in Vietnam.

Requiring reporting if the foreign loan currency is different from the prescribed foreign currency

Article 16 of Circular 80/2025/TT-NHNN supplements regulations on reporting obligations. Accordingly, besides the monthly periodic online reporting of short, medium, and long-term loans, in case the foreign loan currency is different from the foreign currency prescribed in the reporting instructions, the borrower uses the accounting exchange rate announced most recently by the Ministry of Finance at the time of reporting to convert and report according to regulations. This reporting adjustment reflects the latest Vietnam central bank updates 2026.

Noting changes to some registration forms related to foreign loans

Some forms of Circular 12/2022/TT-NHNN have been replaced by the forms of Circular 80/2025/TT-NHNN as follows:

• Appendix I – Application for registration of foreign loans not guaranteed by the Government
• Appendix II – Confirmation document of foreign loan registration by the State Bank
• Appendix III – Application for registration of changes to foreign loans not guaranteed by the Government
• Appendix IV – Report on the implementation situation of short-term foreign borrowing and repayment not guaranteed by the Government.

Circular No. 80/2025/TT-NHNN officially takes effect from January 25, 2026, contributing to cutting procedures, reducing compliance costs for enterprises, while ensuring the efficiency of foreign exchange management and the stability of the financial market. This promotes better FDI loan compliance and overall economic stability.

Above is the update on new points regarding foreign loan registration. If clients have related questions or need consultation on the procedures for registering foreign loans, please contact Viet An Law Firm for the best advice and support!