Consolidated Document No. 33/VBHN-NHNN: Registration Procedures for Government-Guaranteed Foreign Loans and International Bond Issuances
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Based on:33/VBHN-NHNN - Government Official Gazette
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The State Bank of Vietnam (SBV) has issued Consolidated Document No. 33/VBHN-NHNN, merging Circular No. 22/2013/TT-NHNN (effective from October 1, 2013) with the amendments introduced by Circular No. 78/2025/TT-NHNN (effective from January 25, 2026). The document sets out the procedures for registering, and registering changes to, foreign loans and international bond issuances that carry a Government guarantee, applying to borrowers and bond issuers under the rules on Government guarantee issuance and management. The key update from Circular 78/2025/TT-NHNN is the addition of an online filing channel through the National Public Service Portal, alongside in-person and postal submission. It also sets a clear 3-working-day deadline for SBV to check dossier completeness, and renames the responsible unit from «Vụ Quản lý Ngoại hối» (Foreign Exchange Management Department) to «Cục Quản lý ngoại hối» (Foreign Exchange Management Authority), reflecting an administrative upgrade of that unit within SBV. The confirmation timeline remains 7 working days for a new loan or bond registration and 5 working days for a change registration, both counted from receipt of a complete, valid dossier. If a dossier is incomplete, the borrower has up to 60 days to supplement it before the file is closed. While this is a technical administrative procedure, large enterprises, state-owned enterprises, and foreign-invested companies raising foreign loans or issuing international bonds under a Government guarantee should note the updated filing process, especially the 30-day window from signing the guarantee letter or amendment agreement to submit the registration dossier to SBV before disbursement or implementing any change.
Scope and Applicability
Consolidated Document No. 33/VBHN-NHNN, certified by SBV on January 22, 2026 (signed by Deputy Governor Doan Thai Son), merges Circular No. 22/2013/TT-NHNN dated September 24, 2013 with the amendments in Circular No. 78/2025/TT-NHNN dated December 31, 2025. It applies to:
- Borrowers and international bond issuers whose foreign loans or bond issuances carry a Government guarantee under the rules on Government guarantee issuance and management.
- Organizations and individuals involved in the registration or change-registration procedures for such loans and bond issuances.
Filing Channels and Dossier Format (new rules under Circular 78/2025/TT-NHNN)
- Dossiers may be submitted in person at SBV's One-Stop Unit, by postal service, or online via the National Public Service Portal.
- Electronic dossiers must use a digital signature; paper dossiers must consist of originals, true copies, or certified copies as required.
- Registration dossiers must be prepared in Vietnamese; foreign-language originals must be translated with the translator's signature certified (except for agreements the borrower translates and certifies itself, taking responsibility for accuracy).
- SBV must check dossier completeness within 3 working days of receipt.
Registration Procedure for Foreign Loans and International Bond Issuances
The dossier includes: the application form (Appendix 1A or 1B), the Ministry of Finance's guarantee letter, the competent authority's approval of the investment project or capital-use plan, and the signed loan agreement or bond issuance documents.
Process:
- Within 30 days of signing the guarantee letter and before drawing down funds, the borrower submits one dossier set to SBV.
- SBV confirms registration within 7 working days of receiving a complete, valid dossier, specifying the loan's key terms (value, purpose, interest rate, penalty interest, fees, security, tenor, disbursement and repayment schedule).
- If the dossier is incomplete, SBV notifies the borrower within 5 working days; the borrower has 60 days to complete it, after which the file is closed.
Change-Registration Procedure
Any change to an already-registered loan or bond issuance must be registered as a change. The dossier includes the change-registration application (Appendix 2A or 2B), the signed amendment agreement, and any letter or annex adjusting the Ministry of Finance's guarantee letter.
Process:
- Submit the dossier within 30 days of signing the amendment and before implementing the change.
- SBV confirms within 5 working days of receiving a complete dossier; if incomplete, it notifies within 3 working days; the borrower has up to 60 days to complete the dossier.
Reporting Obligations
Borrowers must report to the Ministry of Finance on the implementation of guaranteed foreign loans and bond issuances as required by the Ministry, and copy the report to SBV's Foreign Exchange Management Authority (the new name replacing the former «Foreign Exchange Management Department») for coordinated monitoring.
Effective Dates
- Circular 22/2013/TT-NHNN took effect October 1, 2013, and repealed Sections I-IV of Chapter III of Circular 09/2004/TT-NHNN.
- Circular 78/2025/TT-NHNN takes effect January 25, 2026, amending or repealing provisions in Circulars 37/2013, 29/2015, 10/2016, 15/2019, 10/2022, 24/2022, and 23/2024/TT-NHNN concerning dossiers and administrative procedures in foreign exchange management.
- Transitional provisions: dossiers submitted in full before Circular 78/2025/TT-NHNN's effective date continue to be processed under the prior rules; borrowers need not resupply dossier components that have since been waived or reduced if already requested before the effective date.
- Application form Appendices 1A, 1B, 2A, and 2B are replaced with updated templates.