Circular 151/2025/TT-BTC: Amendments to Insurance Certificate Regulations

Overview

Circular 151/2025/TT-BTC was issued by the Minister of Finance on December 31, 2025, and takes effect from January 1, 2026. This document amends and supplements several articles of Circular 69/2022/TT-BTC dated November 16, 2022, which provides detailed regulations on various types of certificates in the insurance sector (as previously amended by Circular 85/2024/TT-BTC).

Scope of Application

This Circular amends regulations related to:

• Insurance Certificates: Professional certificates for employees working directly in insurance companies
• Insurance Agency Certificates: Certificates for individuals acting as agents distributing insurance products
• Insurance Brokerage Certificates: Certificates for individuals operating as independent insurance brokers and consultants
• Insurance Auxiliary Service Certificates: Certificates for support activities in the insurance sector such as valuation, loss adjustment, and risk management

Key Amendments

Circular 151/2025/TT-BTC continues to refine the legal framework established by Circular 69/2022/TT-BTC and Circular 85/2024/TT-BTC, focusing on:

Certificate Issuance Conditions

• Updated requirements regarding qualifications, experience, and training for each certificate type
• Clarification of professional ethics standards and professional competency
• Specific regulations on training programs and examination procedures

Certificate Management and Renewal

• Procedures for renewal and reissuance of certificates upon expiration or loss
• Conditions for maintaining certificate validity, including continuing education requirements
• Supervision and compliance inspection mechanisms by regulatory authorities

Certificate Revocation and Suspension

• Cases of certificate revocation due to legal violations
• Procedures for temporary suspension and restoration of certificates
• Rights and obligations of individuals whose certificates have been revoked

Impact on Businesses

Insurance Companies

Insurance companies need to:

• Review all personnel to ensure valid certificates under new regulations
• Update internal training programs to align with new standards
• Establish electronic certificate management systems and monitor validity periods
• Plan for renewal and supplementary training for employees before certificate expiration

Insurance Agency and Brokerage Firms

Insurance agency and brokerage companies must:

• Ensure 100% of sales and advisory staff hold valid professional certificates
• Develop internal control procedures for certificate management
• Establish mechanisms to monitor compliance with professional ethics
• Maintain records demonstrating employee competency and compliance

SMEs Providing Insurance Auxiliary Services

SMEs operating in insurance auxiliary services (valuation, loss adjustment, risk management) need to:

• Understand certificate requirements applicable to each service type
• Invest in training and human resource development according to new standards
• Strictly comply with certificate regulations to maintain credibility and competitiveness

Compliance Implementation Steps

Step 1: Current Status Assessment (Before January 1, 2026)

• Check the list of current employees and certificate status
• Identify individuals requiring training, new certification, or renewal
• Assess the gap between current requirements and new regulations

Step 2: Action Plan Development

• Develop training and certification roadmap for employees
• Allocate budget for training and examination activities
• Establish specific timeline for each implementation phase

Step 3: Implementation and Monitoring

• Register employees for recognized training courses
• Organize internal examinations or register for examinations at competent authorities
• Monitor progress and results achieved

Step 4: Internal Process Updates

• Develop electronic certificate management procedures
• Establish reminder mechanisms for certificate renewal before deadlines
• Integrate certificate requirements into recruitment and training processes

Penalties for Violations

Under current legal regulations, violations related to insurance certificates may be subject to:

• Operating without certificates: Monetary fines, suspension of operations
• Using invalid certificates: Monetary fines, certificate revocation
• Professional ethics violations: Certificate revocation, temporary practice prohibition
• Certificate forgery: Severe administrative penalties, potential criminal prosecution

Recommendations for Businesses

1. Act Now: Don't wait until the last minute; start reviewing and planning immediately
2. Invest in Training: View training and certification as long-term investments in service quality
3. Build Compliance Culture: Create an environment encouraging employees to enhance professional qualifications
4. Leverage Technology: Use HR management software to track certificates and provide automatic reminders
5. Seek Professional Advice: When necessary, seek support from legal experts or industry associations

Key Compliance Checklist

• Conduct comprehensive staff certificate audit
• Identify gaps between current status and new requirements
• Develop training and certification budget
• Establish certificate tracking system
• Create renewal reminder procedures
• Update recruitment policies to include certificate requirements
• Document all certificate-related processes
• Schedule regular compliance reviews

Resources and Support

Businesses should:

• Monitor updates from the Ministry of Finance and regulatory authorities
• Participate in industry association seminars and workshops
• Consult with professional advisors specializing in insurance regulation
• Establish relationships with recognized training providers
• Join industry forums to share best practices

Conclusion

Circular 151/2025/TT-BTC represents an important step in enhancing the quality and professionalism of Vietnam's insurance industry. Businesses must proactively comply to avoid legal risks and enhance competitive capabilities in the market. The effective date of January 1, 2026, provides businesses with a clear timeline to ensure full compliance. Companies that take early action will be better positioned to meet the new requirements and maintain uninterrupted operations in the insurance sector.