Amending Circular 17: Another important step forward in the market upgrading process

Many major changes effective immediately

The State Bank has just issued Circular No. 25/2025/TT-NHNN (Circular 25) amending and supplementing a number of articles of Circular No. 17/2024/TT-NHNN (Circular 17) regulating the opening and use of payment accounts at payment service providers.

In addition to many new points, Circular 25 has supplemented the contents in Article 6 and a number of related provisions of Circular 17, in order to facilitate the opening and use of payment accounts for foreign investors who are non-residents when conducting indirect investment activities in Vietnam. While many other provisions will take effect from March 1, 2026 or December 1, 2025, the contents in Article 6 and related provisions will take effect immediately upon signing and promulgating the Circular (from August 31, 2025).

Specifically, in Article 6, Circular 25 has added a provision allowing foreign investors conducting indirect investment activities in Vietnam to authorize financial institutions to open, close and use payment accounts. Banks and foreign bank branches are allowed to identify foreign investors and authorized organizations in accordance with the law on anti-money laundering.

A very important point in the new Circular is that Article 6 has removed the regulation requiring consular legalization in the payment account opening dossier of foreign investors: “a) The regulation on consular legalization in Point a, Clause 6, Article 12 of this Circular does not apply…”. Furthermore, the types of documents that foreign investors can use for identification are expanded: Instead of a passport, foreign investors can use other documents proving their identity issued by a competent foreign authority (Clause 2, Article 3).

At the same time, another major change is that at Point c, Clause 2, Article 6 of Circular 25, it is clearly stated: “The provisions at Point b, Clause 1, Article 5; Clause 3, Article 19; Point b, Clause 2, Article 21 of this Circular do not apply”. Thus, banks and foreign bank branches do not have to monitor the validity period of identity documents of account holders and related persons during the use of payment accounts. At the same time, banks and foreign bank branches do not have to keep and update all signature samples and seal samples (if any) of registered customers for checking and comparison during the use of payment accounts.

In addition, Circular 25 also allows banks and foreign bank branches to use the SWIFT system to open and use payment accounts for foreign investors to carry out indirect investment activities in Vietnam. On the other hand, in Clause 2, Article 7, the new Circular also allows opening foreign currency payment accounts by electronic means. Another new point is that in Clause 2, Article 8 of Circular 25, biometric information is not required to be verified when withdrawing money or making payment transactions by electronic means on payment accounts.

Time to open an official indirect investment account is shortened and convenient.

Procedure for opening a securities investment account for foreign investors: After opening an electronic securities transaction code (e-STC) at the Vietnam Securities Depository and Clearing Corporation (VSDC), investors will open (i) a securities transaction account at a securities company and (ii) an indirect investment account at a custodian bank after being granted an electronic securities transaction code.

Accordingly, according to the provisions of the securities law (Decree 155/2020/ND-CP and guiding documents), the time for VSDC to issue e-STC is 1 day and the time to open a trading account at the securities company is also 1 day after receiving e-STC.

Meanwhile, opening an indirect investment capital account at a custodian bank previously had regulations in the law on credit institutions and guiding documents requiring consular legalization, regulations on having to meet in person when KYC customers, not recognizing the role of global custodian banks and the use of SWIFT messages..., so this process took a lot of time.

However, under the strong direction of the Government and the active coordination of the State Bank in upgrading the stock market, the State Bank recently issued Circular 03/2025/TT-NHNN dated April 29, 2025 regulating the opening and use of Vietnamese Dong accounts to carry out foreign indirect investment activities in Vietnam.

Previously, the Ministry of Finance also issued Circular No. 20/2025/TT-BTC amending Circular No. 51/2021/TT-BTC, focusing on adjusting regulations related to the opening and use of indirect investment capital accounts; information disclosure obligations and reporting regimes of foreign investors to improve transparency and efficiency in management. Circular 03/2025/TT-NHNN combined with Circular No. 20/2025/TT-BTC has created a series of administrative reforms and experts assess that these changes will contribute to removing barriers and opening the door to attracting foreign capital.

Most recently, Circular No. 25/2025/TT-BTC was issued, continuing to be a major change when the regulations on opening payment accounts at payment service providers were amended and supplemented in accordance with international practices. Therefore, when implementing the opening of indirect investment accounts according to the newly issued guidance documents of the State Bank, the documents and procedures have been simplified and the implementation time has been shortened.

In addition, according to some global custodian banks, to complete the account opening documents, custodian banks usually still need to exchange and guide customers investing in Vietnam for the first time. It is estimated that the time to complete the documents will be about 2 weeks for the exchange and guidance of investors or global custodian banks and will be shorter depending on the coordination and exchange between banks and investors.

“With this duration, it has basically met the expectations of foreign investors,” the Ministry of Finance assessed.

Clearer signals for upgrade expectations are near

According to many experts, the amendment of legal regulations of Vietnamese state management agencies is of great significance for FTSE's September 2025 stock market classification assessment period, which will take place on October 7, 2025. Previously, Circular 68/2024/TT-BTC was issued and continued to be amended and supplemented in Circular 18/2025/TT-BTC, which has brought many advantages to foreign institutional investors when trading without requiring 100% of the money. This is a long step forward, consistent with implementation practice, ensuring reasonableness, and at the same time approaching international practices, serving the goal of upgrading the Vietnamese stock market. The provisions of Circular 20/2025/TT-BTC, Circular No. 03/2025/TT-NHNN, and Circular No. 25/2025/TT-NHNN create conditions for foreign investment funds to open new or expand indirect investment accounts, which means that foreign capital will likely flow into the market more strongly.

Many organizations and experts have expressed optimism about the possibility of the Vietnamese stock market being upgraded by FTSE in the next classification period. According to estimates, if FTSE Russell upgrades, passive index funds may pour in about 1 billion USD and active funds investing in emerging markets will immediately allocate 4-6 billion USD into the Vietnamese stock market.

In addition, VinaCapital experts also believe that upgrading the market also has the meaning of increasing the depth of the Vietnamese stock market, contributing to increasing the confidence of domestic investors, promoting transparency, standardizing the market, and thereby creating a more sustainable investment environment. These factors in the long term will attract both domestic and international investors to the stock market in particular and the economy in general.

Source: https://baodautu.vn/sua-doi-thong-tu-17-them-buoc-tien-quan-trong-cho-tien-trinh-nang-hang-thi-truong-d381274.html