Foreign Loan Reporting Services in Vietnam: Latest Updates

In the context of Vietnamese enterprises increasingly expanding their cooperation and raising capital from the international market, foreign loans have become a popular financial solution. According to legal regulations, foreign loans include both government-guaranteed and non-government-guaranteed (self-borrowed, self-paid) foreign loans, implemented in various forms such as loan agreements, deferred payment import contracts, entrusted lending contracts, financial leasing, or issuing debt instruments on the international market. Especially for non-government-guaranteed foreign loans, the borrower is strictly required to implement Foreign loan reporting in accordance with the regulations of the State Bank of Vietnam. To assist enterprises in legal compliance, risk mitigation, and time-saving, Viet An Law Firm provides a comprehensive, accurate, and prompt package of foreign loan reporting services in Vietnam: latest updates.

Foreign loans requiring SBV loan registration

Based on Article 11 of Circular 12/2022/TT-NHNN (Amended and supplemented by Circular 80/2025/TT-NHNN), the loans that must undergo SBV loan registration include:

• Medium and long-term foreign loans.
• Short-term loans with extended principal repayment periods resulting in a total loan term of more than 01 year.
• Short-term loans without extension agreements but still having outstanding principal (including interest converted into principal) at the 1-year mark from the first withdrawal date, unless the borrower completes the payment of the said outstanding principal within 30 working days from the 1-year mark calculated from the first withdrawal date.

Reporting regime for foreign loans in Vietnam

According to Circular 12/2022/TT-NHNN (amended and supplemented by Circular 08/2023/TT-NHNN, Circular 21/2023/TT-NHNN, and Circular 80/2025/TT-NHNN) regarding non-government-guaranteed foreign loans (self-borrowed, self-paid), the borrower is responsible for fulfilling offshore loan compliance and the reporting regime for foreign loans according to the following contents:

Reporting regime for foreign loans

Timing and reporting period

The borrower shall submit a periodic monthly report on the implementation of the foreign loan, including outstanding balance, disbursement, principal repayment, interest, and related fees (if any).

Reporting deadline

The report must be submitted no later than the 5th day of the month immediately following the reporting period through the reporting system of the State Bank.

Types of loans subject to reporting

The borrower is responsible for reporting on all self-borrowed and self-paid foreign loans, including:

• Short-term loans: Maximum loan term of 01 year;
• Medium-term loans: Loan term from over 01 year to 05 years;
• Long-term loans: Loan term of over 05 years.

Reporting format

• The borrower must report the implementation status of short, medium, and long-term loans online on the Website.
• Unlike Circular 03/2016/TT-NHNN where using the Website was not mandatory, under Circular 12/2022/TT-NHNN, the borrower is strictly required to register an account on the State Bank’s Website and submit their foreign loan reporting to the State Bank through this Website.
• In case the Website encounters technical errors preventing report submission, the borrower shall submit a written report using the form in Appendix 05 issued alongside this Circular.

Report processing

• Within 10 working days from the receipt of a valid report from the borrower on the website (or a written report in case of technical errors), the State Bank branch shall inspect, approve the report, and store the information in the foreign borrowing and repayment management database.
• If the reported information is complete and accurate, the borrower will be notified via email of the fulfillment of their reporting obligation.
• If the reported information is inaccurate or needs clarification, the State Bank branch will notify via email for the borrower to adjust and supplement data as required.

Additionally, in unexpected cases or when necessary, the borrower shall report at the request of the State Bank.

Foreign loan report form

The Report form on the implementation of non-government-guaranteed short-term foreign borrowing and repayment by the borrower is stipulated in Appendix 05 issued alongside Circular 12/2022/TT-NHNN.

Appendix 05 has provided very detailed instructions on preparing foreign loan reports and non-government-guaranteed medium and long-term foreign loan reports. However, in case clients have any difficulties or need specific guidance for their enterprise’s case to apply for loan reporting, please contact Viet An Law Firm for the fastest and most accurate advice regarding foreign loan reporting services in Vietnam: latest updates.

Information and documents to be provided

Foreign loan reporting services of Viet An Law Firm

When using the reporting services of Viet An Law Firm, the client needs to provide the following documents, papers, and information:

• Information of the borrower: type, address, phone number, legal representative of the borrower,…
• Documents confirming foreign loan registration,…
• Information on the form of borrowing;
• Total value of foreign loans;
• Details of loans in other forms;…

Guidelines for submitting foreign loan reports via the website

Registering an account to use the website:

• Access the website at www.qlnhsbv.cic.org.vn. Users fill in the information on the electronic declaration requesting an access account according to the instructions on the Website, print the declaration from the Website, sign, and seal it;
• Users send the declaration via postal service or submit it directly at the designated State Bank branch;
• Within 03 working days from the receipt of the user’s declaration requesting an access account with complete and valid information, the competent authority approves and grants the access account via the email registered by the user.

Once granted an access account, users shall declare information, report, manage, and use information on the Website through their access account to ensure proper offshore loan compliance.

Will failure to submit reports on the implementation of foreign loans be penalized?

Based on Clause 3, Article 5 of Decree 340/2025/ND-CP:

“3. Fine levels and penalty authority:

The fine levels specified in Chapter II of this Decree are the fine levels applicable to individuals; the fine level applicable to organizations committing the same administrative violation shall be twice the fine level applicable to individuals;”

Based on Article 56 of Decree 340/2025/ND-CP:

“Article 56. Violations against regulations on the reporting, management, and provision of information regime

1. A warning shall be imposed for one of the following violations:

a) Violating regulations on deadlines, requirements for completeness of content, or submitting inaccurate reporting information and data from the third time onwards for daily periodic statistical reports within 01 month;

b) Submitting insufficient daily periodic statistical report forms from the second time onwards within 01 month.

2. A fine ranging from 5,000,000 VND to 10,000,000 VND (for individuals) or 10,000,000 VND to 20,000,000 VND (for organizations) shall be imposed for one of the following violations:

a) Violating regulations on deadlines, requirements for completeness of content, or submitting inaccurate reporting information and data from the fifth time onwards for daily periodic statistical reports within 01 month, except for the case specified in Clause 1 of this Article;

b) Violating regulations on deadlines, requirements for completeness of content, or submitting inaccurate reporting information and data from the third time onwards for periodic statistical reports of less than 01 month within 01 year, except for the cases specified in Clause 1, Point a Clause 2, Point b Clause 6 of this Article;

c) Failing to store and preserve records and documents for the prescribed duration under the law, except for the case specified in Point a Clause 1 Article 17 of this Decree;

d) Submitting insufficient daily periodic statistical report forms from the fourth time onwards within 01 month, or insufficient periodic statistical report forms of less than 01 month within 01 year, except for the case specified in Clause 1 of this Article;

e) Violating regulations on deadlines, requirements for completeness of content for other reports except for the cases specified in Clause 1, Points a, b, d of this Clause, Point c Clause 4 of this Article, Article 51; Clause 1 Article 53 of this Decree.”

Additionally, the violating entity shall be requested to additionally submit a complete and accurate report for violations regarding requirements for completeness and accuracy.

Foreign loan reporting services in VIetnam

• Legal consultancy on conditions for foreign borrowing; dossiers, registration procedures, and reporting of foreign loans;
• Consulting on online access account registration, guiding the submission of loan reporting dossiers via the website;
• Drafting documents and dossiers for reporting foreign loans;
• Representing the client to carry out procedures at competent state agencies;
• Consulting on legal issues during and after foreign borrowing.

Above is information about foreign loan reporting services in Vietnam: latest updates. Clients who need consultation on procedures, conditions for implementing loans, or other related issues, please contact Viet An Law Firm for the most effective support.