Opening a Vietnam Business Bank Account for a Foreign-Owned Company

A Vietnam business bank account is not simply an administrative item on a company-setup checklist. For a foreign-owned company, the account arrangement must match the origin, purpose and evidence behind each flow of funds. The practical task is to align the entity’s registrations, investor information, authorised signatories and planned transactions before money moves. This guide explains the 2026 framework in plain English and identifies the questions to settle with the chosen licensed bank.

Direct answer: A foreign-owned company may need more than one banking arrangement because routine operating payments and regulated foreign-investment capital flows have different purposes. Since 18 August 2026, SBV Circular 38 governs investment capital accounts and related investment transfers. The chosen licensed bank must still complete its own review, so confirm the account type, documents, currencies, signatory process and opening method in writing before funds are sent. 1 2

1. Map the money flow before choosing a Vietnam business bank account

The first decision is functional: identify who will send money, why it is being sent, which entity receives it and what evidence exists for the transaction. Start with this exercise rather than a list of banks: Vietnam’s foreign-exchange framework distinguishes investment-related flows from ordinary company operations. A bank can then assess an account proposal against a coherent commercial and regulatory record rather than a collection of documents assembled after the fact. 1

For a new subsidiary, map at least four streams separately: investor capital, payments connected to investment preparation or project implementation, domestic operating receipts and payments, and eventual transfers of capital, profits or other lawful revenues. The descriptions should match the company’s registrations and internal approvals. If the company expects foreign-currency transactions, record the currency, counterparty and business purpose for each planned flow. The aim is not to create a legal opinion internally. It is to give the selected bank a precise fact pattern on which it can state its operational requirements.

This discipline is particularly important when a regional group uses shared service centres, multiple shareholders or layered holding companies. A treasury team may see one transfer, while the bank sees a customer-identification question, an account-purpose question and a foreign-exchange documentation question. Reconciling these views early reduces the risk that a legitimate transaction is presented through an account whose purpose or supporting records do not fit. The practical control is simple: no funding instruction should be released until the local finance owner, corporate legal owner and bank contact agree on the intended route and evidence. 1 2

It is also sensible to keep a version-controlled transaction map. Show the investor or parent, the Vietnamese entity, the planned investment capital account if applicable, and the account used for ordinary operating activity. Attach the board or shareholder approval, company registration extracts, source-of-funds narrative and transaction documents to the relevant node. This becomes a working file for banking and later change management, not a one-time incorporation pack.

Table 1. Account-purpose comparison. It is a planning aid, not a bank account recommendation or a universal account list. 1 2

Figure 1. Purpose-led account flow. Original visual created from Circular No. 38/2026/TT-NHNN, especially Articles 1, 6 and 7. 1

2. Distinguish an investment capital account from an operating payment account

The term that should anchor a 2026 discussion is “investment capital account”, not the older “direct investment capital account” or “DICA” shorthand. Circular 38 regulates the opening and use of foreign-currency and Vietnam-dong investment capital accounts, capital contribution, transfers of capital, profits and lawful revenues, project transfers and other money-transfer transactions related to foreign investment. It applies from 18 August 2026. That scope explains why a foreign-owned company should not label every company account as an investment capital account. 1

Article 6 identifies the subjects that open investment capital accounts, including economic organizations established by foreign investors and certain foreign-invested economic organizations with foreign investors or member enterprises holding more than 50% of charter capital. Article 7 then states principles for opening one foreign-currency investment capital account and/or one VND investment capital account at the same licensed bank, with a separate account possible for each foreign currency used for capital contribution. Whether a particular company falls within the Article 6 categories, and how its planned currencies and flows fit, should be confirmed with the licensed bank and advisers familiar with the company’s facts. 1

An ordinary payment account has a different operational role. It supports the company’s banking arrangements for ordinary activity under the bank’s account terms, mandate and controls. The payment-account rules do not erase the separate foreign-investment framework. They require banks and foreign bank branches to examine legality and validity, cross-check consistency and accuracy of customer materials, and conduct customer due diligence under anti-money-laundering rules. For organizations established and operating in Vietnam, the amended rule describes a direct meeting with the legal representative for the relevant due-diligence process, subject to exceptions specified in the rule. 2

This is why “we need a VND account and a USD account” is an incomplete instruction. It does not identify the account holder’s regulatory classification, each currency’s intended use, the person who can give instructions, or the documentary trail. A better instruction is: “Here are the company’s registrations, ownership chart, expected capital contribution, operating flows, signatories and currencies. Which account arrangement does the bank require, and what may each account receive or pay?” Written confirmation will be more useful than an informal assumption based on another company’s experience.

3. Apply the 2026 FX rules to the entity’s actual registration sequence

The 2026 investment framework changed the sequence discussion, but it did not make a foreign-investment project automatically operational. Law on Investment No. 143/2025/QH15 has applied since 1 March 2026. Article 19(2) allows a foreign investor to establish an economic organization to implement an investment project before carrying out procedures to grant or adjust an Investment Registration Certificate, while requiring market-access conditions for foreign investors to be satisfied when establishing the organization. The current implementing decree is Decree No. 96/2026/ND-CP, effective 31 March 2026. 3 4

Circular 38 addresses a related practical question. Its Article 7(3) says that where a foreign investor establishes an economic organization before the IRC grant or adjustment procedures, that foreign-invested economic organization may open one foreign-currency investment capital account and/or one VND investment capital account at the same licensed bank before the IRC is granted or amended. Before the IRC, however, the permitted use stated in that clause is limited to receiving charter capital and interest on the account balance, paying lawful investment-preparation expenses in Vietnam, and refunding capital if the IRC is not granted or amended. Treat this as a narrow, source-backed framework, not as permission to start the project or use the account for unrestricted activity. 1 3

After an IRC or ERC is issued or modified, Article 15 of Circular 38 requires the relevant subjects to supplement those documents to the licensed bank where the investment capital account is open. The same article requires truthful and full declarations of transaction content and purpose, provision of relevant documents and papers when requested and guided by the bank, and responsibility for the authenticity of materials provided. The cleanest operational response is a post-registration change-control checklist that notifies both the bank relationship team and the company’s treasury administrator whenever registrations, ownership, legal representatives, addresses or account authorities change. 1

The planning lesson is conservative. Decide the entity and investment sequence before creating funding instructions, and do not turn an ERC-first option into an implied approval for a regulated activity, location or project. The Ho Chi Minh City Investment and Trade Promotion Centre similarly frames the newer flexibility as a sequencing change rather than a relaxation of substantive investment conditions. Its published discussion predates Circular 38’s effective date for foreign-exchange terminology, so Circular 38 controls the current FX wording in this guide. 10 1

4. Treat bank KYC, signatory design and documentary evidence as a workstream

Bank onboarding is an evidence exercise as much as an application. The bank must be able to identify the customer, entity, ownership and representatives, and understand the mandate and expected activity. The information supplied should be internally consistent. A difference between an ownership chart, an enterprise registration, a board resolution and a passport spelling can create a clarification loop even where the underlying business is straightforward. Resolve those differences before the file is submitted. 2

Do not publish or rely on a universal checklist for all foreign-owned companies. A bank may request different evidence depending on the investor type, ownership chain, account purpose, currency, legal representative, transaction pattern, risk assessment and whether documents were issued overseas. The 2025 Enterprise Law amendment and 2026 enterprise-registration changes make ownership and beneficial-owner information a live corporate-record consideration. That does not mean every shareholder is automatically a beneficial owner for every purpose. It means the company should maintain an accurate, current ownership and control record and ask the bank exactly what it needs. 5 6

At a practical level, prepare a controlled package in four groups. First, collect entity evidence: the current ERC, IRC where relevant, tax and address details, and any changes since issuance. Second, prepare investor and ownership evidence: a simplified group chart, ownership percentages, beneficial-owner and control information where applicable, and authorized corporate approvals. Third, prepare people evidence: legal representative and signatory details, IDs, mandates, contact information and bank user roles. Fourth, prepare transaction evidence: a concise account-purpose statement, expected incoming and outgoing flows, source-of-funds narrative and supporting contracts or resolutions when relevant. The bank, not this article, determines the final list and acceptable formality. 1 2

Published bank materials demonstrate why this should be treated as a dedicated workstream. HSBC Vietnam’s commercial-banking download centre lists a Corporate Account Opening Process, a mandate for account use and operation, account-services instruction forms and foreign-exchange guidance. These documents are not a recommendation to choose HSBC and cannot replace a shortlisted bank’s current instructions. They are, however, a useful primary-bank reminder that account opening involves mandate, operating authority and transaction-document controls as well as incorporation papers. 8 9

Figure 2. Bank onboarding readiness tracker. Original working aid informed by payment-account customer-identification rules and published corporate onboarding materials. 2 8 9

5. Coordinate company, project and bank milestones without promising a fixed timeline

The account-opening workstream should begin early, but it should not outrun the legal and investment analysis. A viable order is: define the business activity and investor structure; identify the entity and investment pathway; ask the bank for an account-purpose and documentary list; prepare ownership, mandate and transaction evidence; then submit, open and activate accounts under the bank’s instructions. Some steps can run in parallel, but only if the legal sequence and bank guidance support it. Avoid quoting a single elapsed time because the pace depends on dossier completeness, document formalities, sector or location factors, bank review and signatory availability. 3 4 8

The National Business Registration Portal confirms the official online business-registration route and status-search function. It is useful for entity-registration planning, but it is not evidence that a foreign investor can complete every banking or identity step remotely. Likewise, an online enterprise-registration process does not tell a bank how it will satisfy its customer-due-diligence procedures for a particular organization. Separate the authority workstream from the bank workstream and assign an owner to each. 7 2

Use decision gates rather than calendar promises. Gate one is commercial and regulatory: can the proposed activity, location and investor structure proceed on the planned route? Gate two is corporate: which ERC and IRC materials, if applicable, are current and consistent? Gate three is banking: has the selected licensed bank confirmed the account structure, its required documents, certification or translation requirements, participant roles and submission method? Gate four is funding: has the bank confirmed the appropriate account and support for the first transfer? Gate five is maintenance: are updates to registrations, ownership and signing authority routed to the bank promptly?

This approach prevents a common internal mismatch. Legal teams may consider a company “formed” when an ERC is issued; finance may consider it “fundable” once a bank relationship has been selected; operations may consider it “live” once an office or customer is ready. The more reliable definition is transaction-specific: an activity is ready only when its approvals, registrations, banking route, internal mandate and evidence requirements are aligned. That distinction is especially important where foreign-investment capital and ordinary operating cash are both expected in the launch period. 1 3

Figure 3. Entity and bank dependency map. Original visual created from Law on Investment No. 143/2025/QH15 and Circular No. 38/2026/TT-NHNN. It is not a duration promise. 3 1

6. What this means for a regional finance or operations lead

The immediate action is to appoint a single local banking coordinator with authority to collect facts from corporate legal, treasury, tax, HR and the local management team. The coordinator does not need to decide the law. Their job is to make the file consistent and to record the bank’s written conditions. That includes the exact accounts proposed, currencies, document versions, people who will attend or authenticate, authorised users, initial transaction purpose and escalation contact. A single evidence register, stored alongside the company’s corporate records, is more robust than email threads held by separate functions.

For a regional controller, the key financial control is separation of duties. One person should not independently define the transaction purpose, authorise the transfer, upload documents and approve the bank instruction. Even in a small company, designate a preparer, a reviewer and an authorised approver. Reconcile the first investment-related transfers to the bank confirmation, the company’s approvals and the accounting treatment. If a planned transaction changes, pause rather than improvising a new payment route.

For a founder or country manager, the most useful contribution is clarity about the operating model. Be able to answer: What will this company do locally? Who owns and controls it? What capital or funding will enter Vietnam? Who may bind the entity? Which overseas documents can be legalized or certified if requested? What is the first transaction after account opening? A bank conversation is more productive when those answers are documented and consistent with the investment and enterprise records.

A practical readiness checklist for the first bank meeting

Table 2. First-meeting readiness checklist. VietPard editorial analysis based on the cited sources; confirm each item with the selected licensed bank. 1 2 8

7. Common mistakes to avoid

Using obsolete terminology or old checklists. Many legacy guides refer to a DICA. Circular 38, effective 18 August 2026, uses “investment capital account”. Updating the vocabulary is not cosmetic: it helps the team ask the bank the right question about current account classification and permitted use. Do not copy a checklist from a prior transaction without reconciling it to the present company, investor and account purpose. 1

Treating an operating account as a substitute for the foreign-investment account arrangement. Ordinary payment-account onboarding and foreign-investment foreign-exchange controls sit alongside one another. An account may be suitable for operational payments yet not be the correct route for an investment-related transfer. Obtain confirmation before sending capital, receiving funds from an investor or re-routing a transfer because an account is not yet active. 1 2

Assuming a bank must accept a fixed document package. The payment-account framework requires legality, validity and consistency checks, plus customer due diligence. Banks also maintain their own customer-risk and mandate processes. Request the shortlisted bank’s written list, confirm document formalities, and record each item’s acceptance date. 2 8

Leaving the legal representative and digital-banking mandate until the end. Corporate account opening is not solely about the entity. It also involves the people who represent it, operate it and approve instructions. Define signing rules, online-banking roles, internal approval limits, secure contact points and departure procedures before credentials are issued. A mandate that does not match real authority creates a control problem even if the account opens successfully. 8 9

Mistaking an ERC-first sequence for project permission. Law on Investment No. 143/2025/QH15 allows a foreign investor to establish an economic organization before IRC procedures in the stated route, subject to market-access conditions. It does not remove applicable project, market-access, location or sectoral requirements. Keep the entity, project and banking decisions linked, and seek case-specific professional review where a project has regulated features. 3 4 10

Failing to update the bank after a corporate change. Article 15 of Circular 38 requires relevant updated IRC, ERC or equivalent papers to be supplied to the bank after grant or modification. Incorporate bank notification into the company’s corporate-secretarial checklist for changes in registration, ownership, legal representative or signing authority. Confirm the bank’s own update process and deadlines rather than assuming a government filing automatically updates bank records. 1

Coordinating entity formation and banking steps? Explore VietPard’s company setup support for assistance with the coordination process.

Frequently asked questions

Can a foreign-owned company open a bank account in Vietnam?

A foreign-owned company may be able to open accounts in Vietnam, but the correct arrangement depends on the entity’s classification, registrations, proposed transactions and the bank’s review. Circular 38 sets the foreign-exchange framework for investment capital accounts for specified subjects, while payment-account rules require banks to review organizational materials and conduct customer due diligence. Confirm eligibility, documents, account use and the opening process directly with the selected licensed bank. 1 2

What is an investment capital account in Vietnam?

An investment capital account is the current term used in SBV Circular 38 for a foreign-currency or VND payment account opened for foreign-investment purposes by the subjects covered by the circular. The circular regulates opening and use, capital contribution, transfers of capital, profits and lawful revenues, project transfers and related transactions. It is not a generic label for every company account, so its applicability and permitted transactions need bank confirmation. 1

Do I need an IRC to open a Vietnam business bank account?

There is no safe universal answer. The entity’s stage, investment route and the bank’s requirements matter. Circular 38 expressly provides that, where a foreign investor establishes an economic organization before IRC grant or adjustment procedures, the organization may open specified investment capital account arrangements before the IRC in the circumstances and limited uses set out in Article 7(3). Ask the chosen bank to confirm your company’s classification and required registration documents in writing. 1 3

Can I open a company bank account remotely?

Do not assume that a foreign-owned company can complete account opening fully remotely. Payment-account rules set customer-identification and due-diligence procedures for organizations, including rules concerning the legal representative, while banks set their own onboarding process. For example, a published corporate bank workflow may include mandate and account-services materials, but it does not guarantee the process for another customer or bank. Confirm attendance, identity verification, original-document and digital-submission requirements with the selected bank. 2 8 9

What documents does a Vietnam bank require for a foreign-owned company?

The final list is bank-specific and case-specific. As a preparation framework, expect the bank to assess entity registrations, ownership and control information, the legal representative and authorized signatories, account mandate, expected transactions and supporting documents. Document formality requirements, such as certification, translation, legalization and validity, should be confirmed directly with the selected bank. Use a tracker so that the corporate file and the bank file remain consistent. 1 2 5 8

Conclusion: build the bank file around purpose, evidence and change control

Opening a Vietnam business bank account for a foreign-owned company is best treated as a controlled market-entry workstream. Start with the money flow, distinguish the investment capital account framework from ordinary operating banking, and align the entity’s registrations with its ownership, mandate and first transactions. Circular 38 provides the current 2026 foreign-exchange foundation, while payment-account rules and the bank’s own process determine the practical onboarding record. The sensible next step is a written confirmation from the chosen licensed bank before any investment-related funding instruction is released. 1 2

This article is general information for business planning, not legal, tax, banking, investment or immigration advice. Requirements may change and can depend on the investor, activity, location, entity records, transaction purpose and bank assessment. Validate the current Vietnamese text, current bank instructions and professional advice appropriate to the company’s circumstances before filing, opening an account or transferring funds.

Sources and Further Reading

All sources were accessed 10 September 2026. Vietnamese statutory text controls where an English reference translation is used.

[1] State Bank of Vietnam. Circular No. 38/2026/TT-NHNN on foreign exchange management of foreign investment activities in Vietnam. 31 July 2026; effective 18 August 2026. Source link

[2] State Bank of Vietnam. Circular No. 25/2025/TT-NHNN amending Circular No. 17/2024/TT-NHNN on payment accounts. 31 August 2025; effective dates vary by provision. Source link

[3] National Assembly of Vietnam, Government Portal. Law on Investment No. 143/2025/QH15. 11 December 2025; effective 1 March 2026. Source link

[4] Government of Vietnam. Decree No. 96/2026/ND-CP detailing and guiding the Law on Investment. 31 March 2026; effective 31 March 2026. Source link

[5] National Assembly of Vietnam, Government Portal. Law No. 76/2025/QH15 amending and supplementing the Law on Enterprises. 17 June 2025; effective 1 July 2025. Source link

[6] Government of Vietnam. Decree No. 296/2026/ND-CP amending Decree No. 168/2025/ND-CP on enterprise registration. 23 July 2026; effective 23 July 2026. Source link

[7] National Business Registration Portal. Official National Business Registration Portal and online registration route. Live operational page; accessed 10 September 2026. Source link

[8] HSBC Vietnam. Commercial Banking Download Centre, including Corporate Account Opening Process and Account Services materials. Live page; accessed 10 September 2026. Source link

[9] HSBC Vietnam. Corporate Account Opening Process. Published corporate onboarding material; accessed 10 September 2026. Source link

[10] Ho Chi Minh City Investment and Trade Promotion Centre. Which investing structure should foreign investors choose?. Investor news page; accessed 10 September 2026. Source link

[11] VietPard. Vietnam Company Setup Services. Live service page; accessed 10 September 2026. Source link