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VIFC Supervisory Body: HCMC Given May 15 Deadline to Constitute the Centre's Enforcement Arm

25 Apr 2026 · 9 min read

Four months after Decree 323 created the VIFC Supervisory Body on paper, it still does not exist in practice. On 24 April 2026, Deputy Prime Minister Nguyen Van Thang chaired a meeting with ministries, agencies, and municipal authorities from Ho Chi Minh City and Da Nang — and issued the first formal government directive to actually constitute it. For the approximately 27 firms already holding membership certificates (according to the VIFC Executive Authority's April 2026 registry), this is the clearest signal yet of when their regulatory counterparty begins to take shape.

KEY TAKEAWAY
HCMC People's Committee must urgently coordinate with the State Bank of Vietnam and relevant ministries to establish the Supervisory Body and report progress by 15 May 2026. Until the body is constituted, the approximately 27 current VIFC members — roughly 15 in HCMC and 12 in Da Nang — have no independent inspection or enforcement authority overseeing them.

The governance gap#

Decree No. 323/2025/ND-CP, effective 18 December 2025, dedicates Chapter III (Articles 11–13) to defining the Supervisory Body for the International Financial Centre. On paper, its mandate is comprehensive: inspections, compliance monitoring, risk management, violation handling, and oversight of sandbox mechanisms. In practice, none of this machinery has been assembled.

The result is a live governance vacuum. The VIFC Executive Authority manages operational and administrative matters, but the independent enforcement and inspection function — the body that would conduct audits, issue compliance rulings, and handle violations — does not yet exist. Firms operating under current membership certificates are, in regulatory terms, supervised by an entity that has not been staffed, led, or operationalised.

This gap was flagged in our 60-day assessment and features in the institutional reform roadmap laid out by VIFC CEO Mark McClellan. The 24 April 2026 directive is the government's first concrete move to close it.

What the directive requires#

Three distinct task assignments emerged from the Deputy PM's meeting:

1. HCMC People's Committee — establish the Supervisory Body

HCMC must urgently coordinate with the State Bank of Vietnam (SBV) and relevant ministries to constitute the Supervisory Body. A progress report is due to the Government by 15 May 2026. This is the critical deadline: it represents the earliest point at which the public will learn whether the body has a leader, a staff, and an operational timeline.

Separately, the HCMC People's Committee was tasked with collecting feedback on VIFC operational regulations before submitting them for promulgation — a parallel governance deliverable that will shape how the Supervisory Body actually exercises its powers.

2. Central agencies — submit supervisory mechanism proposals

Ministries and central agencies were directed to accelerate the building of management and supervisory mechanisms in line with their respective functions. These proposals were due to the Prime Minister within April 2026 — meaning by the end of this month. Whether they have been submitted is not yet publicly known.

3. Ministry of Finance — report on Decision No. 114

The Ministry of Finance must clarify the implementation status of Decision No. 114 (issued 1 August 2025) and report to the PM by 10 May 2026. The specific content and scope of Decision No. 114 has not been detailed in available sources, but its inclusion as an implementation benchmark suggests it relates to financial or fiscal mechanisms relevant to the VIFC's operational framework.

What Decree 323 says the Supervisory Body should look like#

The legal blueprint is already detailed. Under Articles 11–13 of Decree 323:

  • Legal status: A specific-type administrative agency with independent legal person status, a seal bearing the national emblem, and the ability to open accounts at both the State Treasury and commercial banks
  • Oversight: Placed under the management of the HCMC People's Committee
  • Leadership: A Chairperson and Vice Chairpersons, the number determined at the HCMC People's Committee Chairperson's discretion. Appointment, relief, and removal are decided by the HCMC People's Committee Chairperson
  • Internal structure: Four named departments — Office; Legal Affairs and Risk Management; Inspection, Auditing and Supervision; Technology and Information — plus additional specialised units as needed
  • Geographic reach: Headquartered in HCMC, with authority to establish a branch in Da Nang
  • Core powers: Scheduled and unscheduled inspection, examination, supervision, compliance monitoring, risk management, and violation handling. Oversight of sandbox and controlled pilot mechanisms
  • Coordination: Works with the SBV and relevant ministries on inspection and supervision matters

This is not a skeleton framework. The organisational chart is defined. The powers are enumerated. What is missing is people and an operational date.

The SBV's role is worth watching#

Decree 323 places the Supervisory Body under the HCMC People's Committee, not the State Bank of Vietnam. But the 24 April 2026 directive explicitly names the SBV as a required coordinating party in the establishment process. This is significant.

The SBV's involvement could take several forms: input on the scope of the Supervisory Body's jurisdiction over banking and foreign exchange activities within the VIFC, influence on staffing and expertise requirements, or establishing the regulatory interface between the Supervisory Body and the SBV's own supervisory functions under Decree 329 and Circular 72. For financial institutions entering the VIFC, understanding whose writ runs where — the Supervisory Body's or the SBV's — will be a practical compliance question from day one.

What this means for the approximately 27 current members#

The roughly 15 firms in HCMC and 12 in Da Nang that already hold membership certificates should note three things:

The enforcement clock has not started. Until the Supervisory Body is constituted and operational, there is no independent body to conduct inspections or issue compliance rulings. This does not mean firms are unregulated — Vietnam's existing regulatory framework still applies — but the VIFC-specific supervisory layer that Decree 323 envisions does not yet function.

15 May 2026 is a progress report, not a launch date. The directive requires HCMC to report on progress by that date, not to have the body fully operational. Realistically, constituting an agency with the structure outlined in Decree 323 — leadership appointments, department staffing, office establishment, Da Nang branch planning — will take months beyond a progress report.

The operational regulations are still being drafted. The separate directive for HCMC to collect feedback on VIFC operational regulations means the rules under which the Supervisory Body will exercise its powers are themselves incomplete. Firms should expect a period of regulatory consultation before enforcement norms are finalised.

What comes next#

The 15 May 2026 deadline is the next concrete milestone. It will reveal whether the HCMC People's Committee has identified leadership for the Supervisory Body, how the SBV's coordinating role is being structured, and what timeline the government is working toward for full operational capacity.

Firms in the membership pipeline — and the approximately 27 already inside — should monitor three signals: whether a Supervisory Body Chairperson is named, whether the Da Nang branch is being planned concurrently or sequentially, and when the operational regulations are published for consultation. Until all three materialise, the VIFC's enforcement architecture remains a work in progress.

This article was last updated on 25 April 2026. We will update it when the 15 May 2026 progress report is published or when Supervisory Body leadership appointments are announced.