Legal position as at 16 September 2026
Legal basis
| Instrument | What it governs | In force from |
|---|---|---|
| Circular 38/2026/TT-NHNN | Opening, operation and closing of foreign investment capital accounts | 18 August 2026 |
Replaces Circular 06/2019/TT-NHNN.
On 31 July 2026 the State Bank of Vietnam issued Circular 38/2026/TT-NHNN. It took effect on 18 August 2026 and replaced Circular 06/2019/TT-NHNN, which had governed foreign exchange for foreign direct investment since 2019. It also amended Circular 03/2025/TT-NHNN on the Vietnamese-dong accounts used for foreign indirect investment.
If your company is foreign-invested and holds a capital account in Vietnam, this affects the account you already have, not only accounts opened from now on.
What actually changed#
The account has a new name#
The circular replaces the term direct investment capital account (tài khoản vốn đầu tư trực tiếp) with foreign investment capital account (tài khoản vốn đầu tư nước ngoài) .
This matters more than a renaming usually would. Almost every English-language guide, and a good deal of bank documentation, still says “DICA”. For the next year or two you will see both terms used for the same thing, sometimes in the same file.
You no longer have to open the foreign-currency account first#
Under the previous framework the foreign-currency capital account came first and the Vietnamese-dong account followed. Circular 38 allows an investor to hold foreign-currency and Vietnamese-dong investment capital accounts at the same licensed bank without having to establish the foreign-currency account before the dong one.
Capital contributed in more than one currency#
Where investment capital is contributed in different foreign currencies, separate investment capital accounts may be opened for each of those currencies at the same bank.
The account can be opened before the investment registration certificate#
This is the change that has drawn the most attention. Certain foreign-invested economic organisations may now open an investment capital account before an investment registration certificate (giấy chứng nhận đăng ký đầu tư) has been issued or amended.
Under the old sequence a company could find itself unable to receive capital because the account could not be opened until the certificate existed, while the certificate process itself assumed funds were available.
Reported as Articles 6.1(b), 7.5(b)(i) and 7.6 of Circular 38/2026/TT-NHNN. Article numbers not yet verified.
Capital from the International Financial Center#
The circular extends to capital moving from Vietnam’s International Financial Center into the rest of the country, under Decree 329/2025/ND-CP, alongside conventional foreign direct investment.
Circular 06/2019 compared with Circular 38/2026#
| Item | Under Circular 06/2019 | Under Circular 38/2026 |
|---|---|---|
| Name of the account | Direct investment capital account | Foreign investment capital account |
| Order of opening | Foreign-currency account first | Either order, at the same bank |
| Multiple currencies | Restricted | Separate account per currency, same bank |
| Timing against the IRC | After issue or amendment | Before issue or amendment, in defined cases |
| International Financial Center | Not covered | Covered |