Key Highlights of Circular No. 25/2025/TT-NHNN on the Opening and Use of Payment Accounts

Circular No. 25/2025/TT-NHNN (“Circular 25/2025”), amending and supplementing a number of provisions of Circular No. 17/2024/TT-NHNN (“Circular 17/2024”) on the opening and use of payment accounts at payment service providers, was issued on August 13, 2025. The Circular marks significant changes, consistent with the Government’s policy of streamlining the organizational structure and advancing administrative reform. Set out below are some of the key amendments and supplements of Circular 25 in comparison with its predecessor:

1. Replacement of the term “State Bank branch” with “Regional State Bank branch”

In Circular No. 17/2024, “State Bank branch” was the abbreviated reference to provincial or municipal branches of the State Bank directly under the Central Government. Although this change may appear minor, it carries significant meaning, ensuring consistency in terminology in line with the Decisions on establishment, as well as the regulations on functions, duties, powers, and organizational structure of the 14 Regional State Bank branches. This reflects uniformity, efficiency, and alignment with the new model of administrative management in coordination with the local government system following the merger.

2. Changes in Documentation for Opening Payment Accounts (“PAs”)

Circular No. 25/2025 introduces changes to the documentation requirements for opening PAs, particularly for foreign individuals and organizations.

• For foreign individuals: Circular No. 25/2025 supplements additional identity documents issued by foreign competent authorities that can serve as proof of identity for foreign individual customers. Accordingly, instead of being limited to passports as under the previous regulation, foreign individuals may now flexibly use other identity documents recognized under the laws of their country to open a PA.
• For organizations: Under Circular No. 25/2025, in cases where an organization uses an electronic identification account, banks and foreign bank branches are not required to request submission of documents, information, or data already contained in the organization’s electronic identification account. This represents a major change, ensuring conformity and consistency with the provisions on electronic identification for organizations under Decree No. 60/2024/ND-CP.

3. Supplementing Detailed Requirements for Verifying Legality, Validity, and Accuracy of Customer-Provided Documents, Information, and Data

Circular No. 25/2025 stipulates detailed procedures for verifying the information and documents provided by customers when opening payment accounts (“PAs”) for each case, as follows:

For account holders who are individuals:

(i) In cases where the account holder or their representative uses a national ID card, electronic ID card, ID card with information storage module, or digital identity, banks or foreign bank branches must meet the account holder or their representative in person and carry out verification of identity documents, ensuring that biometric information matches accurately;

(ii) In cases where the account holder or their representative uses an ID card without an information storage module or a birth certificate for individuals under 14 years old who do not yet have an ID card or passport, banks or foreign bank branches must meet the account holder or their representative in person and carry out verification of identity documents, ensuring that the biometric information displayed on the identity documents matches correctly;

(iii) In cases where the account holder is a foreign individual not present in Vietnam, banks or foreign bank branches may verify the customer’s information through a third party or by outsourcing to another organization;

(iv) In cases where the representative is an organization, verification shall be conducted in accordance with the provisions applicable to organizations.

For account holders who are organizations

(i) In cases where the account holder is an organization established and operating in Vietnam, banks or foreign bank branches must meet the legal representative of the account holder in person and carry out verification of the legal representative’s information in accordance with the provisions applicable to individuals;

(ii) In cases where the account holder is a foreign legal entity, banks or foreign bank branches may verify the information of the legal representative through a third party or by outsourcing to another organization, provided that the third party or the outsourced organization meets the legal representative in person and carries out verification of identity documents, ensuring that the biometric information of the legal representative matches accurately.

The provisions applicable to organizations mentioned above are not mandatory in cases where the account holder is: (i) State agencies or public service units; (ii) Credit institutions or foreign bank branches; (iii) Listed organizations as regulated under the Securities Law; (iv) Organizations included in the Fortune Global 500 list published by Fortune magazine in the preceding year; (v) Other organizations selected by banks or foreign bank branches, who shall bear full responsibility for the risks arising from such selection.

For joint payment accounts: (i) In cases where the joint payment account holder is an individual, the provisions applicable to individuals shall apply; (ii) In cases where the joint payment account holder is an organization, the provisions applicable to organizations shall apply.

In cases where customers register to conduct transactions via online banking applications: banks or foreign bank branches must verify the information regarding the phone number of the account holder or the account holder’s representative (for individual customers) or the legal representative of the account holder (for organizational customers) to ensure that the information of the subscriber matches the information on the identity documents of that person.

4. Supplementing Regulations on Opening and Using Payment Accounts by Non-Resident Foreign Investors for Indirect Investment Activities in Vietnam

An important new point is that Circular No. 25/2025 supplements the scope of account holders to include non-resident foreign investors (“NFI”) conducting indirect investment activities in Vietnam, who are authorized to open, close, and use payment accounts through an organization having a custody service agreement with the NFI. Banks or foreign bank branches must carry out customer identification for both the non-resident foreign investors and the authorized organization in accordance with laws on anti-money laundering.

The opening and use of accounts by NFIs to conduct indirect investment activities in Vietnam shall comply with the provisions of this Circular, the current regulations on foreign exchange management, and the following regulations:

• The provisions on legalization of documents do not apply to the documents in the payment account opening dossier of foreign investors issued by competent foreign authorities. However, such documents must be notarized or authenticated in accordance with the laws of Vietnam or foreign laws within 12 months as of the date the bank or foreign bank branch receives the dossier;
• Banks or foreign bank branches shall verify the legality and validity of the documents, information, and data provided by the customer, ensure accurate matching, and carry out customer identification in accordance with laws on anti-money laundering;

Note: The following provisions do not apply to non-resident foreign investors (NFIs):

• The provision on authorizing a third party to use the payment account in cases where the account holder is an organization;
• The provision on the obligation to monitor the validity period of the identity documents of the account holder and related persons during the use of the payment account; to notify the customer at least 30 days before the expiry date of the identity documents so that the customer can update or supplement information in a timely manner; and to temporarily suspend payment or withdrawal transactions on the payment account in cases where the customer’s identity documents have expired or exceeded the usage period recognized by the bank or foreign bank branch;
• The provision on the obligation to retain and fully update the customer’s signature samples and seal samples (if any) registered for verification and comparison during the use of the payment account by the bank or foreign bank branch.

5. Supplementing Appendix No. 03: List of Organizational Customers Opening and Using Payment Accounts Suspected of Fraud, Deception, or Legal Violations

Previously, Circular No. 17/2024 only regulated the template list applicable to individuals. Now, Circular No. 25/2025 extends it to organizations, enabling more comprehensive monitoring and reducing the risk of legal entities using accounts to conceal cash flows, conduct money laundering, or engage in other illegal activities. At the same time, this provision also provides a basis for banks to proactively refuse, closely monitor, or report to competent authorities upon detecting risks, thereby contributing to the safety of payment activities and enhancing the prevention and control of legal violations in the financial – banking sector.

In general, Circular No. 25/2025 brings significant changes, particularly focusing on the requirement to verify the legality and accurate matching of documents and information of individuals and organizations seeking to open payment accounts. These new provisions ensure that the information and documents reflecting the personal and organizational data are strictly controlled and secured, while simultaneously imposing higher responsibilities on banks, contributing to the transparency and safety of Vietnam’s financial – banking system.

Time of writing: 20/09/2025

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You can refer for more information:

• New Provisions under Decree No. 239/2025/ND-CP Providing Guidance on Certain Articles of the Law on Investment (Part 2)
• New Provisions under Decree No. 239/2025/ND-CP Providing Guidance on Certain Articles of the Law on Investment (Part 1)
• Personal data management in the education sector under the Personal Data Protection Law
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