Vietnam's central bank mandates explicit consent for sharing credit information

Published 28 Sep 2026Data as of 14 Sep 2026VietnamRegulation

Correction: Stated that the issuance date is unverified.

Circular 46/2026/TT-NHNN amends Circular 15/2023/TT-NHNN, effective 1 November 2026
Sharing with voluntary member organisations or foreign credit bureaus requires consent in a verifiable form
Provision is electronic by default; paper requires agreement from the National Credit Information Centre (CIC)

Facts

Amendment: the State Bank of Vietnam (SBV) amended Circular 15/2023/TT-NHNN on credit information activities through Circular 46/2026/TT-NHNN, effective 1 November 2026. The issuance date was not given in reports (unverified). Source: VietnamPlus (2026-09-14).

Consent: when providing a borrower's credit information to voluntary member organisations, foreign credit information agencies and others, consent must be obtained in a clear and specific manner, and must be in a form that can be printed, copied and verified, including electronic form. Source: as above.

Method: information is in principle provided as electronic data in line with the credit information indicator system; paper provision is allowed only where electronic provision is not possible and with the CIC's agreement. The CIC sets the frequency of information exchange with voluntary members under agreements. Source: as above.

Analysis

In September Vietnam saw a sequence of moves to expand data use: the SBV Governor's call for data-driven lending (19 September) and a data-sharing agreement between the General Department of Taxation and the CIC (reported 25 September). This amendment adds a discipline of verifiable consent to that use, so expansion and discipline are advancing together.

By comparison, Thailand has also highlighted users' recognition of debt and consent in its BNPL rules (September 2026); regulators in the region share a direction of emphasising consent and disclosure in the use of data and credit.

Implications

ExecutivesLenders need systems that store the wording, timestamp and data scope of consents obtained via apps and online applications in a verifiable form.

InvestorsDigital lenders relying heavily on external data will face relatively larger post-implementation compliance costs and operational risks.

OperatorsWith about six weeks until the effective date, consent procedures for sharing data with partners or using external data, and agreements with the CIC, should be reviewed early.

Counterpoints and uncertainties

The circular text has not been obtained, so the scope of 'other organisations' and any transitional arrangements are unknown. Strict enforcement of consent requirements could delay the launch of partnership lending and data integrations. Conversely, the change may merely codify existing practice and have little practical impact.

Sources

Reports are for information only and are not investment advice. Methodology: sources, verification and definitions