Vietnam Legal Watch — 25 May 2026

Executive Summary

The week ending 25 May 2026 marks the effective date of three significant government decrees and the issuance of several new circulars that reshape the regulatory landscape across environmental compliance, banking innovation, investment administration, and tax enforcement. Decree 110/2026/ND-CP on Extended Producer Responsibility (EPR) takes effect on 25 May, imposing mandatory recycling obligations on producers and importers while exempting businesses with annual revenue below VND 30 billion. Circular 19/2026/TT-NHNN, signed 19 May, decentralizes the implementation of the banking-sector regulatory sandbox established under Decree 94/2025/ND-CP, clearing the path for fintech pilots at the provincial level. Circular 55/2026/TT-BTC, promulgated 15 May, unifies all investment-registration forms under the new Law on Investment 143/2025/QH15 and its guiding Decree 96/2026/ND-CP, replacing the old planning-ministry templates with a single Ministry of Finance system. Meanwhile, a controversial draft decree on travel bans for tax debts as low as VND 1 million has entered public consultation, drawing industry pushback over proportionality.

Context and Methodology

This report draws on primary Vietnamese and English-language legal and regulatory sources published between 19 and 25 May 2026, including LuatVietnam, Tạp chí Kinh tế - Tài chính (Ministry of Finance), VnEconomy, Vietnam Briefing (Dezan Shira), Allen & Gledhill, Viet An Law, and VietNamNet. Sources were cross-referenced against official gazette references and government decree numbers where available. Analysis distinguishes between enacted law, newly effective instruments, draft legislation under consultation, and policy commentary.

Key Developments

1. Decree 110/2026/ND-CP: Extended Producer Responsibility Takes Effect 25 May

Decree 110/2026/ND-CP, which details several articles of the Law on Environmental Protection regarding the responsibilities of producers and importers for recycling products and packaging and for treating waste, becomes effective on 25 May 2026. Under the decree, producers and importers must recycle products and packaging according to mandatory recycling rates and technical standards set by the Ministry of Natural Resources and Environment. The decree specifies exemptions: businesses with annual revenue below VND 30 billion (approximately USD 1.14 million) are exempt from recycling obligations.

This is the implementing regulation that gives teeth to the EPR provisions in the 2020 Law on Environmental Protection. Producers and importers of electronics, batteries, packaging, vehicles, and other listed product categories must now establish or join approved recycling schemes, report recycling volumes, and meet annual mandatory rates. The VND 30 billion revenue threshold means that most SMEs are exempt, concentrating compliance burden on larger manufacturers and importers.

Practical impact: Manufacturing companies, importers of consumer goods, and packaging producers with revenue above VND 30 billion must immediately evaluate their recycling obligations. E-commerce platforms and retailers sourcing from affected producers should verify that suppliers hold valid recycling certifications. Non-compliance penalties will follow existing environmental violation sanctions. Companies below the threshold should nonetheless prepare for potential future downward revision of the exemption level.

2. Circular 19/2026/TT-NHNN: Banking Regulatory Sandbox Decentralized

The State Bank of Vietnam (SBV) issued Circular 19/2026/TT-NHNN on 19 May 2026, defining the decentralization of implementation of administrative procedures under Decree 94/2025/ND-CP, which established the regulatory sandbox in the banking sector. The circular delegates authority for processing sandbox applications, monitoring pilot projects, and enforcing sandbox conditions to SBV branches and provincial-level banking authorities, rather than concentrating all decisions at SBV headquarters.

Decree 94/2025/ND-CP itself created a formal legal pathway for fintech companies, payment service providers, and other financial innovators to test new products and business models within a controlled regulatory environment, with temporary exemptions from certain licensing and compliance requirements. Circular 19 makes this pathway operationally accessible by distributing the administrative workload and shortening processing timelines for sandbox applicants.

Practical impact: Fintech startups and payment companies planning to pilot new services in Vietnam now have clearer and faster access to the sandbox framework. Provincial-level processing means that companies headquartered outside Hanoi or Ho Chi Minh City can apply through their local SBV branch rather than navigating central bureaucracy alone. The banking sandbox is expected to cover areas such as digital lending, blockchain-based payments, open banking APIs, and AI-driven credit scoring. Companies should monitor subsequent SBV guidance on eligible sandbox categories and prepare applications promptly, as early entrants may benefit from more flexible interpretation.

3. Circular 55/2026/TT-BTC: Unified Investment Forms Under New Investment Law

The Ministry of Finance promulgated Circular 55/2026/TT-BTC on 15 May 2026, prescribing standard forms and reports for investment activities and investment promotion in Vietnam. The circular replaces the former planning-ministry system (Circular 03/2021/TT-BKHĐT) with a unified set of forms aligned to the new Law on Investment 143/2025/QH15 (effective 1 March 2026) and its guiding Decree 96/2026/ND-CP (enacted 31 March 2026).

The new forms cover investment registration certificates (IRC), enterprise registration certificates (ERC) for foreign-invested enterprises, IRC amendment dossiers, investment activity reporting, and investment promotion documentation. All forms are designed for electronic submission through the national investment information system, and the circular mandates synchronization of electronic investment data across government databases.

This is the administrative backbone of Vietnam's investment reform. The new Law on Investment shifted emphasis from capital-scale thresholds to qualitative criteria — technology content, R&D activity, supply-chain integration — for incentive eligibility. Decree 96/2026 established a three-tier special-incentive structure ranging from VND 3,000 billion (innovation/R&D centres) to VND 30,000 billion (other priority sectors), with mandatory disbursement requirements within three to five years. Circular 55 now provides the practical forms through which investors engage with this system.

Practical impact: All foreign-invested enterprises and investors submitting IRC applications, amendments, or investment reports must transition to the new forms immediately. Companies already holding IRCs under the old law should review whether their existing registration information maps cleanly to the new form fields. The synchronization of electronic data means that discrepancies between investment-registration and enterprise-registration databases will surface more quickly, requiring proactive data-housekeeping. Companies in AI data centres, semiconductor manufacturing, hydrogen energy, and green ammonia should note that these sectors are newly listed in Appendix II of Decree 96 as priority investment categories with access to enhanced incentives.

4. Decree 133/2026/ND-CP: Electricity Administrative Violations Effective 25 May

Decree 133/2026/ND-CP, dated 4 April 2026, regulates administrative violations in the electricity sector and takes effect on 25 May 2026. Among its provisions, landlords who collect electricity fees from tenants at rates exceeding regulated levels face fines of VND 20–30 million (approximately USD 760–1,140). The decree also addresses other electricity-sector violations including unauthorized connections, meter tampering, and safety breaches.

Practical impact: Property owners leasing commercial or residential space and including electricity in rental charges must ensure that their per-kWh rates comply with local electricity-regulation ceilings. This has been a persistent area of informal overcharging in Vietnam's rental market. Real-estate companies managing multi-tenant buildings should audit their utility-billing practices before the effective date.

5. Draft Decree on Travel Bans for Tax Debts from VND 1 Million

The Ministry of Finance has submitted a draft decree guiding the implementation of the Law on Tax Administration, proposing temporary exit bans for taxpayers classified as no longer operating at their registered addresses (TT06 status in the tax system) with tax debts of VND 1 million (approximately USD 40) or more. The measure would apply 30 days after tax-authority notification if the taxpayer still fails to fulfil obligations. Affected groups include business individuals, household business owners, beneficial owners of enterprises, and legal representatives of companies and cooperatives.

The proposal has drawn criticism from industry figures. Nguyen Vu Cao, chairman of Van Khang Phat Group, called the VND 1 million threshold "overly strict" and proposed raising it to VND 100 million or higher, arguing that treating small and large debts identically creates a disproportionate enforcement regime. Lawyer Nguyen Van Duoc noted that the proposal is actually more structured than existing rules under Decree 49/2025, which already allows exit suspension for TT06-status taxpayers regardless of debt amount after 30 days' notice.

The draft also addresses "ghost addresses" — registered business locations where the taxpayer is no longer physically present — a widespread issue in Vietnam's business-registry system. Alongside this, the SBV is separately consulting on amendments to Decree 58/2021 on credit information services, proposing stricter cybersecurity, disaster-recovery, and business-continuity requirements for credit-information companies.

Practical impact: The draft is not yet enacted, but businesses should ensure their registered addresses are current and that no outstanding tax debts exist, however small. Companies with relocated or closed branches should formally deregister rather than leaving them in TT06 status. The proposal signals escalating enforcement against informal and shadow businesses, which could affect supply-chain partners and subcontractors.

Continuing Developments

1 July 2026 Implementation Wave

The following previously enacted instruments remain on track for their 1 July 2026 effective date:

Decree 174/2026 — social-media misinformation fines (VND 20–50 million)
Decree 161/2026 — base salary increase to VND 2,530,000/month
Decree 162/2026 — 8% pension increase
Decree 90/2026 — e-cigarette fines up to VND 5 million (already effective 15 May 2026)
Circular 08 — SIM biometric enforcement phases beginning June and August 2026

Decree 141/2026: Household Business Tax Exemption Expansion

Effective retrospectively from 1 January 2026, Decree 141/2026 raises the annual revenue threshold for tax exemption from VND 200 million to VND 1 billion, introduces CIT exemptions for qualifying small enterprises, and requires e-invoicing for household businesses exceeding VND 1 billion in revenue. The General Department of Taxation has issued Official Dispatch No. 11 directing immediate implementation.

Banking Transfer Threshold

From 1 May 2026, under Circular 40/2024/TT-NHNN, banks have ceased automatic instant processing for transfers exceeding VND 500 million. Such transfers must now use standard banking channels. This affects treasury operations and supplier-payment timing for businesses handling large-value transactions.

Continuing Regulatory Reform Tracks

PM Directive 527/TTg-CĐS (18 May): ban on new administrative procedures and business-licence conditions
Resolution 135/NQ-CP (22 May): 10% recurrent and 5% capital budget cuts for FY 2026
Draft e-securities trading Circular (MOF): consultation ongoing
Product traceability and VNeID integration draft decree: consultation ongoing

Comparative Analysis

The regulatory trajectory in May 2026 shows two parallel currents. On one hand, the government is tightening enforcement — EPR obligations, electricity-billing penalties, tax-debt travel bans, high-value transfer restrictions. On the other, it is streamlining market access — unified investment forms, banking sandbox decentralization, expanded tax exemptions for micro businesses, and the ongoing prohibition on new administrative procedures. This dual movement reflects the political mandate from Conclusion 18-KL/TW on double-digit growth: remove barriers to investment while tightening compliance on those already operating. The 25 May effective-date cluster (Decrees 110, 133) combined with the 1 July wave creates a compressed compliance calendar for businesses operating across multiple sectors.

Key Risks

EPR compliance gap risk is high for mid-sized manufacturers and importers who may not have been tracking the 25 May effective date. Companies above the VND 30 billion revenue threshold must immediately assess which product categories they handle, determine mandatory recycling rates, and either establish in-house recycling capacity or join collective recycling schemes. Failure to comply exposes them to environmental administrative penalties and potential import holds.
Investment-form transition risk affects all foreign-invested enterprises. The shift from the old planning-ministry system to Circular 55/2026 forms may create data-mapping issues, particularly for companies with legacy IRCs containing fields that do not directly correspond to the new templates. Companies with pending IRC amendments should verify which form version applies to their filing date.
Tax-enforcement escalation risk from the draft travel-ban decree, even at the VND 1 million threshold, signals that the tax authorities are building systematic tools against non-compliance at all levels. Businesses should audit their entire Vietnamese entity structure for dormant registrations, ghost addresses, and micro-debts that could trigger enforcement.
Banking sandbox access risk exists for fintech companies that delay sandbox applications. Early movers in the decentralised SBV framework may benefit from more flexible pilot terms before the regulator accumulates enough data to impose stricter conditions. The window for "first-mover advantage" in sandbox participation is typically narrow in emerging markets.
Compliance calendar compression risk is significant. With multiple decrees taking effect on 25 May (EPR, electricity penalties) and 1 July (base salary, pensions, social media fines, SIM biometrics), businesses operating across sectors face a six-week period requiring simultaneous adjustments to payroll, environmental compliance, social-media policies, employee-device management, and financial reporting.

Appendix: Source Assessment

Source	Type	Reliability	Freshness	Notes
VnEconomy (en.vneconomy.vn)	Government-affiliated media	High	25 May 2026	Confirmed Decree 110, 133, 90 effective dates
Allen & Gledhill	International law firm	High	15 May 2026	Decree 96/2026 investment-law analysis
Viet An Law	Vietnamese law firm	High	May 2026	Circular 55/2026 detailed breakdown
Vietnam Briefing (Dezan Shira)	Professional services	High	May 2026	Decree 141, Circular 40, draft tax enforcement
VietNamNet	Vietnamese media	Medium-High	May 2026	Travel-ban draft debate and expert commentary
Tạp chí Kinh tế - Tài chính	Ministry of Finance	High	21 May 2026	Homepage scan for policy headlines and e-securities draft
LuatVietnam	Legal database	High	24 May 2026	Standard legal-news scan; limited new items this cycle