Da Nang's Implementing Decrees Are Too Strict: The Case for Amending Resolution 222

Vietnam's International Financial Centre in Da Nang (VIFC-DN) has formally told the National Assembly that Resolution 222's implementing framework is blocking what the resolution itself intended to enable. In early May 2026, the National Assembly's Economic and Financial Committee — the body directly responsible for supervising Resolution 222's implementation — conducted a site visit to VIFC-DN. What it heard was unusually direct: the guiding decrees are too restrictive to deliver the open, internationally competitive centre Resolution 222 envisaged. Da Nang is now preparing specific amendment proposals, with a clear escalation path if decree-level fixes fall short.

The Gap Between What Resolution 222 Permits and What the Decrees Allow#

Resolution 222's framework, passed as Resolution No. 222/2025/QH15, established the legal basis for Vietnam's International Financial Centre. The resolution was passed on 27 June 2025 and took effect on 1 September 2025 — dates confirmed in the resolution text and referenced throughout VIFC-DN's official communications (see Resolution 222 Explained for a full breakdown of its provisions). Eight government decrees were then issued to operationalise it, including Decree No. 323/2025/ND-CP (18 December 2025), which formally established VIFC-DN and its Executive Agency. For a full map of those eight instruments, see VIFC's Eight Implementing Decrees: A Practitioner's Reference Map.

The problem Dang Dinh Duc, Permanent Vice Chairman of the VIFC-DN Executive Agency, put on record at the May 2026 session is structural: Resolution 222 adopted what he called "a very open-minded approach," but the eight guiding decrees are "still quite strict, leading to difficulties in practical implementation." The resolution set the ambition; the decrees constrained it.

This is a familiar failure mode in Vietnamese regulatory architecture. Framework laws and resolutions routinely reflect political ambition at the National Assembly level, while implementing circulars and decrees — drafted by line ministries with different risk tolerances — narrow that ambition considerably by the time they reach practitioners.

Five Specific Obstacles#

The VIFC-DN Executive Agency identified five concrete obstacles at the May 2026 session.

1. No finalised operating regulations. The draft Operating Regulation — the document that will establish VIFC-DN's internal licensing and membership procedures on a firm legal foundation — is reportedly on its 10th iteration within the IFC Executive Council review process. Without it, every downstream procedure (membership applications, licensing for banking, fund management, asset management, sandbox operations) rests on an incomplete procedural base.

2. The salary benchmarking gap. Resolution 222 permits VIFC-DN to hire domestic and foreign experts at negotiated, market-level salaries — a deliberate departure from Vietnam's standard civil-service and state-enterprise pay scales. But no regulatory benchmark currently exists to determine what "market-level" means in an IFC context. Vietnam's general salary frameworks are not competitive with Singapore, Dubai, or Hong Kong. Until the job position plan is approved and a benchmarking mechanism established, the Executive Agency's current 21-person team cannot be expanded at competitive compensation levels. The talent implications for international recruitment are significant — see Living in Da Nang: Expat Guide for VIFC Finance Professionals for context on compensation expectations among international finance professionals.

3. Staffing quota delays. Even setting aside compensation, personnel quotas for the Executive Agency have not been allocated in a timely manner. The 21-person team cannot scale without quota approval, regardless of whether the salary benchmarking issue is resolved.

4. Limited platform and exchange scope. The current legal framework permits new platforms and exchanges in principle, but the permissible scope is, in the Executive Agency's characterisation, "limited and does not meet the expectations of international investors regarding flexibility and market connectivity." What specific categories of platform activity fall outside the permitted scope was not confirmed in available sources, but the concern is clearly directed at the gap between international investors' expectations — shaped by comparators like DIFC, ADGM, and GIFT City — and what Da Nang can currently offer. For a competitive baseline, see VIFC vs DIFC, AIFC, and GIFT City: How Vietnam's Financial Centre Compares.

5. Blocked licensing pipelines. According to figures cited at the May 2026 working session, VIFC-DN had 12 official members, 11 expressions of interest granted, and 12 entities completing membership registration applications as of 31 March 2026, with 85 or more domestic and foreign investors holding letters of interest. Converting that pipeline into actual presence requires functioning licensing procedures for banking subsidiaries, fund management, asset management, and sandbox operations. Those procedures remain unresolved. The bottleneck is not demand — it is the procedural framework to process it.

Da Nang's Proposed Fix: Decrees First, Resolution 222 If Necessary#

The Executive Agency's stated approach is to prepare specific amendment proposals targeting the relevant guiding decrees. This is the faster path: decree amendments can be initiated by the government and do not require National Assembly action. Only if decree-level amendments prove insufficient will Da Nang escalate to requesting that the National Assembly adjust Resolution 222 itself.

This sequencing matters for timeline. Decree amendments can move through the government's legislative calendar on a standard timetable — weeks to months, depending on political priority. A Resolution 222 amendment would require National Assembly scheduling, committee review, and a plenary vote, adding a minimum of several months to any substantive change. The fact that Da Nang has identified decree-level reforms as the primary vehicle signals a preference for speed over scope.

What remains unconfirmed is which specific provisions within the eight guiding decrees the Executive Agency intends to propose for amendment. Primary sources available at publication do not identify individual decree articles. Practitioners monitoring this process should watch for formal submissions from the Executive Agency to the Ministry of Finance and the Ministry of Justice, which would be the next procedural step.

The Sandbox-First Alternative#

Oscar Njuguna, Head of Membership at VIFC-DN, offered a parallel recommendation at the May 2026 session: allow certain activities to operate within a limited sandbox framework for evaluation, rather than waiting for a comprehensive legal system to be completed first.

This is a well-established approach in financial centre development. DIFC, for instance, used its Innovation Testing Licence to permit regulated experimentation before full licensing frameworks were built. Vietnam's own fintech regulatory landscape has been shaped by sandbox instruments — Decree 94's P2P lending sandbox being the most recent example (see Decree 94's P2P Sandbox: The Foreign Ownership Bar and What It Means for VIFC Firms).

The tension Njuguna's recommendation exposes is real: the guiding decrees appear to embed a sequencing assumption that the full regulatory architecture must be in place before operations begin. A sandbox-first model inverts that assumption. Whether the current decree framework permits sandbox operations to commence before the Operating Regulation is finalised is precisely the kind of question the pending amendment proposals will need to address. VIFC-DN does have sandbox operating procedures under development, but their status relative to the Operating Regulation's 10th-iteration draft is not confirmed in available sources.

What the National Assembly Commitment Actually Means#

Deputy Chairman Nguyen Ngoc Bao of the Economic and Financial Committee did not confine his May 2026 visit to ceremony. He confirmed the committee's supervisory mandate over Resolution 222 and committed to "work alongside VIFC-DN to remove bottlenecks in mechanisms, institutions, and legal regulations."

That is a specific institutional commitment, not a courtesy statement. The Economic and Financial Committee is the lead National Assembly body for reviewing and supervising Resolution 222 implementation. Its active engagement — site visits, formal working sessions, a named deputy chairman as lead reviewer — creates a legislative feedback loop that did not formally exist when the eight decrees were first issued. Da Nang can now route its amendment proposals through a committee that has publicly committed to act on them, rather than relying solely on executive-branch channels.

For practitioners evaluating the VIFC, the committee's supervisory role is worth understanding in detail. The arbitration infrastructure underpinning dispute resolution — critical for cross-border financial transactions — operates under Decree 328, which is one of the eight guiding instruments potentially subject to amendment. See our analysis at Decree 328 Explained: VIFC International Arbitration Centre.

MOU Scorecard#

VIFC-DN has signed more than 20 memoranda of cooperation, including with Binance, Tether, Bybit, Abu Dhabi Global Market, and Frankfurt Main Finance. These MOUs signal intent and generate political momentum. However, the binding commitments, timelines, and operational clauses within individual agreements are not confirmed from available primary sources — VIFC-DN has not published the full text of any signed MOU at time of publication. Practitioners should treat these as statements of interest rather than contracted commitments until formal licensing disclosures or operational announcements are made.

What to Monitor#

Four developments will determine whether Da Nang's amendment case advances from advocacy to enacted change:

1. The Operating Regulation's finalisation. Movement past a 10th draft iteration — and formal adoption by the IFC Executive Council — would unblock the licensing pipeline immediately, without waiting for decree amendments. This is the fastest available lever.

2. Formal amendment proposals submitted to MoF and MoJ. The Executive Agency has stated it is preparing proposals. Their submission would confirm which decree provisions are targeted and start the official amendment clock.

3. The Economic and Financial Committee's 2026 legislative agenda. If Nguyen Ngoc Bao's committee formally schedules a Resolution 222 review session — as distinct from a supervisory working visit — that signals the escalation path is being activated.

4. Staffing quota approval. An executive agency capped at 21 people cannot credibly process 85-plus letters of interest into memberships. Quota expansion is a prerequisite for operational credibility, independent of the broader decree reform process.

For practitioners evaluating VIFC-DN as a potential operating base, the framework's stated intent is clear and political will to address implementation gaps is now formally on record. What global financial institutions must weigh is whether the amendment timeline aligns with their own entry planning horizons — a question our guide to Vietnam's VIFC: What Global Financial Institutions Must Evaluate Before 2027 addresses in detail.

This article was last updated on 16 May 2026. We will update it as decree amendment proposals are formally submitted and the National Assembly's review schedule is confirmed.