Raising the bank's internal control standards to be closer to international best practices.

The Department of System Safety of Credit Institutions (CIs) of the State Bank of Vietnam (SBV) organized a discussion with representatives of credit institutions on the Draft Circular replacing Circular 13/2018/TT-NHNN regulating the internal control system of commercial banks and branches of foreign banks.

Speaking at the meeting, Mr. Nguyen Duc Long, Director of the Department of System Safety of Credit Institutions, State Bank of Vietnam , said that the State Bank of Vietnam is focusing on reviewing and issuing legal documents related to safety ratios and risk management requirements. The Circular replacing Circular 13/2018/TT-NHNN is an important document, as Circular 13 has been in effect for seven years since its issuance in May 2018. In the context of many changes to Basel III standards and the emergence of new issues in banking operations, reviewing, updating, and replacing the Circular is necessary. According to Mr. Nguyen Duc Long, the draft amendment has been sent for comments twice. The first time was in May 2025, aiming to amend and supplement several articles, but after review, some regulations were assessed as difficult to apply or creating additional compliance burdens. Therefore, the State Bank of Vietnam (SBV) continued to refine and resubmit the draft in October 2025 for broader consultation. The drafting committee received many detailed feedbacks and also held direct meetings with banks that registered to provide comments. In addition, SBV delegations also conducted on-site surveys at several banks of different sizes and governance models to fully understand the specifics of implementing the internal control system in practice.

Scene from the working session

Sharing his views on the draft's approach, a representative from the State Bank of Vietnam (SBV) stated that the core principle of international practice is that risk management must first and foremost be the responsibility of each individual bank. Banks must proactively build and operate internal control systems appropriate to their scale and risk level. Based on this, the regulatory authority will select a common set of standards and apply them uniformly throughout the system. Mr. Nguyen Duc Long emphasized that the draft Circular will be reviewed to align with international practices while also considering the practical conditions for implementation in Vietnam. The SBV will not regulate in excessive detail but will issue a framework, creating conditions for banks to proactively implement. Providing guidance at a reasonable level is an important lesson the SBV has learned from the process of drafting many previous documents. "The SBV will not regulate in excessive detail. This is also an experience from the process of drafting many previous regulations, and we will strive to issue guidance at the most reasonable level for banks," Mr. Nguyen Duc Long stressed.

Nguyen Quoc Hung, Vice Chairman and General Secretary of the Vietnam Banking Association, affirmed that replacing Circular 13/2018/TT-NHNN is necessary in the context of the banking system facing many new risks and pressures.

At the meeting, representatives from the drafting committee presented a summary of the notable new points in the draft, particularly regarding the risk management model, organizational structure, internal control functions, and requirements for the three lines of defense. Many delegates assessed that the draft showed clear progress in approaching a modern risk management model, but some content needs further refinement to ensure consistency and feasibility when applied.

Nguyen Quoc Hung, Vice Chairman and General Secretary of the Vietnam Banking Association, affirmed that replacing Circular 13/2018/TT-NHNN is necessary in the context of the banking system facing many new risk pressures. The regulations must be designed based on clearly identifying the risk management model of each bank to avoid overlap and limit different interpretations when applied. Mr. Nguyen Quoc Hung emphasized that the Circular needs to be consistent with the current legal system, and new terms in accordance with international practices must be clearly explained so that credit institutions can easily implement them. He also suggested that the drafting agency should only stipulate principles, allowing banks to proactively develop appropriate internal procedures instead of imposing details, thus avoiding difficulties in implementation.

Mr. Nguyen Duc Long, Director of the Department of System Safety of Credit Institutions, emphasized that the draft Circular amending Circular 13 will be reviewed to align with international practices while simultaneously taking into account the practical conditions of implementation in Vietnam.

Ms. Nguyen Thi Phuong, representing the Banking Law Club, stated that the draft Circular demonstrates an effort to approach a modern risk management model, but still faces obstacles related to the three-line defense model, organizational structure, risk decision-making authority, and risk management model. Some regulations concerning the internal control system may cause conflicts during application at credit institutions and branches of foreign banks due to differences in operating models, delegation of authority, and the level of completeness of the risk management system.

The meeting also recorded many specific opinions from banks such as Agribank, BIDV, Vietcombank, VietinBank, MB, Techcombank,ACB , VIB, and representatives of foreign banks. These opinions focused on clarifying the purpose of the risk management model, regulations on outsourced management, credit risk limits, reputational risk, technological risk, the mechanism of delegation of authority in insurance operations, the relationship between risk appetite and overall limits, as well as the requirements for controlling and preventing risks arising from operational practices.

After listening to opinions from the Banking Association, the Legal Club, and credit institutions, Mr. Nguyen Duc Long stated that all opinions would be recorded, reviewed, and appropriately explained by the relevant departments. Points requiring clarification will be explained by the drafting committee to clarify the approach and policy objectives; reasonable proposals will be incorporated and revised in the final draft. He emphasized that the Circular is a legal document applicable to all credit institutions, therefore it can only stipulate principles, avoiding excessive detail to prevent practical implementation difficulties. The draft is currently in its final stages of completion, and the State Bank of Vietnam will compile it for submission to the leadership for consideration and promulgation in the near future.

Speaking at the meeting, Mr. Nguyen Quoc Hung emphasized that this document has a significant impact on risk management throughout the entire system and needs to be developed transparently and clearly to support credit institutions in effectively complying with regulations. Therefore, the Banking Association will continue to review and synthesize the opinions of its members and submit them to the State Bank of Vietnam as soon as possible; and will coordinate with the Banking Legal Club to unify systematic feedback, contributing to the completion of the draft Circular before its issuance.

Source: https://thoibaonganhang.vn/nang-chuan-kiem-soat-noi-bo-ngan-hang-tiem-can-thong-le-quoc-te-175074.html