Offshore Loan Registration [Update 2026]
Entering the Vietnamese market through company formation or other investment vehicles is a key step for foreign investors. As Vietnam’s economy grows, businesses increasingly require capital, with foreign loans being a common source for operational funding.
The State Bank of Vietnam strictly regulates loan disbursement and repayment, including mandatory loan registration for:
- Medium and long-term loans
- Extensions of short-term loans leading to total loan-term exceeding 12-month period
- Short-term loans without extension still have outstanding principal from the initial disbursement date, except those loans have been fully paid within 30 business days from the first day of loan disbursement
Circular 80/2025/TT-NHNN issued on 31 Dec 2025 by State Bank of Vietnam sets a milestone in Vietnam’s digitalization & transformation in terms of Foreign Exchange Management for Enterprises’ Offshore Borrowings and Repayments.
Prominent changes comparing to Circular 12/2022 are highlighted below:
Reduced Paperwork: Full legal documents (IRC/ERC) are no longer required; the SBV will verify details directly via the National Business Portal. A summary of core terms can be submitted instead of a full loan agreement translation, cutting down on bureaucratic delays.
Online Submissions: Applications can now be made entirely online via the National Public Service Portal (Cổng Dịch vụ công Quốc gia) at dichvucong.gov.vn. This marks a major digital transformation by the SBV to save businesses time and effort.
Faster Processing: SBV review time has been slashed from 12–15 working days to a maximum of 10 working days. In additional, the Borrower has 60 days for dossier supplementation from the date receiving Notification of document supplementing and revising from SBV.
Authority Decentralization: Provincial SBV branches can now approve loans under USD 20 million (up from the previous USD 10 million limit), starting July 25, 2026.
By updating Circular 12/2022/TT-NHNN, Circular 80 introduces streamlined procedures, enhanced digitalization, and strict processing deadlines for foreign loan registrations. For businesses, this means accelerated access to offshore capital and a reduced administrative workload.
Circular 80/2025/TT-NHNN is effective from 25 Jan 2026.
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