VIFC's Eight Implementing Decrees: A Practitioner's Reference Map

Vietnam enacted the entire legislative package underpinning its International Financial Centre in a single day. On 18 December 2025, all eight implementing decrees for Resolution 222/2025/QH15 were signed into effect, with the official launch ceremony following three days later on 21 December 2025, hosted by Prime Minister Pham Minh Chinh. The speed of delivery was itself a signal: the government treated the decree package as a political commitment, not a technocratic exercise.

For lawyers, compliance officers, and investment committee staff approaching the VIFC framework for the first time, the challenge is now different from what it was six months ago. The legal architecture exists; navigating it requires knowing which decree governs which question. This article maps all eight decrees — their numbering, subjects, effective dates, the Resolution 222 articles each operationalises, and the open questions that remain unresolved at each level.

The Eight Decrees at a Glance#

Note: The Resolution 222 article mapping for Decrees 325, 326, 328, 329, and 330 reflects the broad thematic coverage confirmed in public sources. The precise article-by-article cross-reference for these five decrees has not been independently verified at publication date; readers should treat those entries as indicative rather than definitive pending full text review.

For deep-dives into individual decrees, VIFC Insight has published stand-alone explainers on each: Decree 323, Decree 324, Decree 325, Decree 327, Decree 328, Decree 329, and Decree 330.

Decree 323: Governance and Membership Architecture#

Decree 323/2025/ND-CP establishes the structural scaffolding for the entire VIFC. Three institutions sit above the operational layer.

The IFC Executive Council is the highest coordinating body. It approves strategy, issues binding policy guidance, and resolves inter-city disputes between Ho Chi Minh City and Da Nang. According to government announcements, the Council is chaired by a Deputy Prime Minister-level appointee; Deputy PM Nguyen Hoa Binh has been named in this role per publicly reported statements at the time of launch.

The City-level Management Authorities operate as independent legal entities under their respective People's Committees. They issue member registration certificates, licenses, and sandbox approvals — the last of these capped at a maximum period of five years.

The IFC Supervision Authority is based in Ho Chi Minh City, with a Da Nang branch described as optional. It handles inspection, enforcement, and sandbox evaluation — a separation of licensing and supervision functions that mirrors common IFC design practice elsewhere.

Decree 323 also confirms cross-recognition: a firm registered at either node is jointly recognised as an IFC member at both. This matters operationally. A Da Nang-registered digital-asset firm does not need a separate HCMC membership to access HCMC-based counterparties within the zone.

Zone Geography#

The HCMC IFC covers 898 hectares across Saigon Ward, Ben Thanh Ward, and Thu Thiem Urban Area (An Khanh Ward), bounded by Vo Van Kiet, Le Duan, and Ton Duc Thang streets and the Saigon River.

The Da Nang IFC covers approximately 300 hectares across multiple sites: An Hai Ward (6.17 ha), Software Park No. 2 (0.12 ha), a coastal access road site (9.7 ha), the Nhu Nguyet/Xuan Dieu intersection (1.98 ha), and a roughly 282-hectare coastal reclamation area opposite Nguyen Tat Thanh Street. The reclamation component means a substantial portion of Da Nang's IFC footprint does not yet exist as built real estate — an important caveat for firms evaluating physical presence timelines.

For a detailed comparison of which node suits which firm type, see the VIFC Da Nang vs HCMC entry guide.

Decree 324: Tax and Financial Policy#

Decree 324/2025/ND-CP operationalises the Resolution 222 provisions with the broadest commercial impact: the corporate income tax incentives, the sandbox finance regime, and the preferential treatment for priority financial activities. It implements Articles 10, 11, 12, 18, 19, 24, 26, 27, and 31 of Resolution 222 — the widest article coverage of any single decree in the package.

The headline CIT incentive is a 10% rate for 30 years for priority sectors, with a four-year full exemption followed by nine years at 50% of the otherwise-applicable rate. For non-priority IFC activities, the rate is 15% for 15 years. The standard Vietnamese CIT rate of 20% applies outside the incentive period.

The open question here is material: Decree 324 lists incentive categories in outline form. The definitive sector-by-sector specification of which projects qualify as "priority" — and therefore access the 10% rate — has not been published in granular form. Firms should treat any preliminary self-assessment of CIT eligibility as provisional until the Management Authorities issue that specification.

Decree 325: Labour and Foreign Professionals#

Decree 325/2025/ND-CP addresses the employment framework for IFC members, including the rules that modify Vietnam's standard foreign hiring regime for VIFC entities. The practical effect is a relaxation of the work permit and labour market test requirements that otherwise constrain international firms staffing up in Vietnam. The dedicated explainer at Decree 325 covers the operational detail.

Decree 326: Land Use#

Decree 326/2025/ND-CP governs land allocation and environmental policy within the IFC zones. It has received the least secondary analysis of any decree in the package. The decree departs from standard Vietnamese property law in at least one commercially significant respect: it permits land allocation to strategic investors without the public auction process that would ordinarily be required under Vietnam's Land Law. This carve-out applies within the designated IFC zone boundaries and is intended to accelerate the assembly of development-ready plots for anchor tenants. Separately, the decree modifies the environmental impact assessment timeline for IFC projects, allowing parallel processing rather than sequential approval — a change that reduces the pre-construction compliance period for infrastructure-heavy developments. A stand-alone explainer on Decree 326 is forthcoming.

Decree 327: Foreign Entry, Exit, and Residence#

Decree 327/2025/ND-CP is the one decree in the package that did not take effect on 18 December 2025. Its effective date is 17 January 2026 — a 30-day lag that gave immigration authorities time to align administrative procedures. It operationalises Articles 18 and 20 of Resolution 222, which provide for streamlined visa and residence arrangements for IFC members and their senior personnel. Full coverage is available at Decree 327.

Decree 328: International Arbitration#

Decree 328/2025/ND-CP establishes the International Arbitration Centre within the IFC. Combined with the Law on Specialized Courts (Law 150, passed by the National Assembly on 11 December 2025 and effective 1 January 2026), the decree completes the dispute resolution architecture that international counterparties will require before committing significant capital to VIFC-governed transactions. The full architecture is covered in Law 150 Explained and Decree 328.

Decree 329: Banking, Foreign Exchange, and AML/CFT#

Decree 329/2025/ND-CP implements Article 16 of Resolution 222 and the broader banking and foreign exchange provisions. Its key operational rules concern how IFC members move money.

IFC member enterprises must use foreign currency payment accounts — termed "member capital accounts" — at member banks for all cross-border activity. Wholly foreign-owned IFC members are exempt from the outbound investment registration requirement that would otherwise apply under Vietnam's standard overseas investment rules, but they must still use member capital accounts and meet disclosure obligations. Non-wholly foreign-owned members must register outbound FDI with the IFC Management Authority before transferring funds.

The relationship between Decree 329 and Circular 72 — which governs how IFC members invest capital outside the zone — is covered in detail at Circular 72's Mainland Investment Rules.

Decree 330: Commodity Exchange#

Decree 330/2025/ND-CP covers Commodity Exchange operations within the IFC. It sits outside the core banking and securities framework but matters for firms considering commodity trading, derivatives, or supply chain finance platforms — particularly through Da Nang, which Resolution 222 designated as the innovation sandbox node with specific mandates for specialised trading platforms. The full explainer is at Decree 330.

Five Open Questions the Decrees Leave Unanswered#

The eight decrees constitute a complete legal framework in the sense that no required implementing instrument is missing. They do not constitute a complete operational framework — significant detail sits below decree level. Five gaps merit specific tracking.

1. Granular CIT priority project list. Decree 324 names incentive categories; the Management Authorities must still publish the sector-by-sector specification. Until they do, firms cannot finalise tax modelling.

2. Sandbox exemption scope. Decree 323 authorises sandbox licenses that suspend specified legal provisions for up to five years. The specific provisions suspended for any given sandbox participant require specification at the Management Authority level — the decrees do not enumerate them in advance.

3. VIFC sandbox versus SBV national fintech sandbox. The relationship between the VIFC sandbox regime (Decree 323/324) and the SBV's national fintech sandbox (Decree 94) is unresolved for firms whose products operate in overlapping categories. A payments firm with a national Decree 94 licence and a proposed VIFC sandbox application faces genuine regulatory ambiguity. See Decree 94 Explained for the national framework baseline.

4. Decree 326 land allocation rules. The strategic-investor carve-out from standard public tender procedures is commercially significant and legally novel. No secondary guidance has been published.

5. Licensing procedures and capital requirements. The decrees establish member categories — commercial banks, securities firms, fintech and digital asset organisations — but the specific licensing procedures and minimum capital requirements for each are expected from the Management Authorities rather than from the decrees themselves. Firms at the market-entry assessment stage should treat published capital thresholds as indicative until confirmed by the relevant Management Authority.

The VIFC Supervisory Body update covers the April 2026 directive requiring HCMC to constitute the enforcement arm by 15 May 2026 — a prerequisite for the Management Authorities to issue the guidance that fills these gaps.

What Comes Next#

Deputy PM Nguyen Hoa Binh has stated publicly that the eight decrees will eventually be consolidated into a dedicated IFC law or legal code. The government's published development roadmap runs in three phases: operational launch and initial infrastructure (2025–2026), policy refinement and attraction of major international financial institutions (from 2026), and a government review within five years that could produce a more unified legal model.

The practical implication for firms entering now: the decree-level framework is stable, but the sub-decree implementation layer — licensing rules, sandbox exemption lists, CIT priority project specifications — will continue to evolve through 2026 and beyond. Building regulatory monitoring into any VIFC market-entry plan is not optional.

This guide was last updated on 3 May 2026. We will update it as implementing specifications are issued by the HCMC and Da Nang Management Authorities.