Positive and negative credit data in Southeast Asia: what published sources describe
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Credit bureaus · Part 2
Key points
- Published texts for the Philippines, Vietnam, Cambodia, Malaysia, Singapore and Indonesia describe bureau files that record repayment conduct, not only defaults
- The differences lie in who must report, how long adverse records stay visible (five years after they end in Vietnam; a 12 months arrears window in Malaysia's CCRIS report) and thresholds such as Indonesia's IDR 1 million
- In T&S's view, the lender's question shifts from whether positive data exist to whether a borrower's other lenders report them and how quickly records change
Implications for lenders
Lenders operating in several of these markets can set approval rules per country for how long an adverse item counts, because Vietnam allows negative information to be provided for up to five years after it ends while Malaysia's CCRIS report shows arrears over a 12 months window. For small-ticket products in Indonesia, a thin SLIK file may reflect the IDR 1 million threshold rather than a lack of credit history, which may support a modest starting limit that grows with observed repayment. Where key competitors or informal lenders sit outside reporting, affordability checks may need sources beyond the bureau.
Implications
Facts
Philippines: the implementing rules and regulations of the Credit Information System Act (Republic Act No. 9510), approved on 27 May 2009, require covered submitting entities to submit basic credit data, both positive and negative, on all their data subjects. Positive information covers timely repayment or non-delinquency; negative information covers poor credit performance such as loan defaults and bankruptcy reports.
Vietnam: a 2020 presentation by the National Credit Information Centre (CIC), published on IFC's website, says credit institutions are mandated to report both positive and negative information to the CIC, while organisations that take part under the decree-based framework share both kinds voluntarily, on a reciprocal basis. The State Bank of Vietnam's Circular 15/2023/TT-NHNN (issued 5 December 2023, effective 1 January 2025) requires credit institutions to provide the full set of credit information indicators set by the Governor, defines negative information as information on bad debts, breaches of payment obligations and other adverse items, has the CIC keep credit information for at least five years from the date it arises, and allows negative information to be provided for no more than five years after it ends, except where state authorities request it under law. People's credit funds and microfinance institutions report monthly. 1
Cambodia: an impact study on credit reporting prepared for IFC (February 2019) says institutions covered by the National Bank of Cambodia's Prakas on Credit Reporting (May 2011) are required to supply both positive and negative information on consumers to the credit bureau, and that other, non-regulated lenders may also contribute.
Malaysia: Bank Negara Malaysia's Credit Bureau FAQ says CCRIS is not a blacklist and provides only factual information as reported by participating financial institutions, including banks, Islamic banks, investment banks, development financial institutions and certain insurers. The report shows outstanding facilities, credit applications and the number of instalments in arrears over the last 12 months; once a shortfall is settled it no longer appears. 2 The FAQ also names private credit reporting agencies that lenders may use alongside CCRIS.
Singapore: the government's MoneySense guide (updated 28 September 2026) describes a credit report as a compilation of credit payment history collected across banks and major financial institutions, and says the bureau's information comes from its members, such as banks and credit card companies, and from public sources on bankruptcy; accounts with a history of prompt payments help to boost a credit rating.
Indonesia: in a press release of 6 July 2026, OJK said debtor information in SLIK, its credit information system, now covers only facilities above IDR 1 million, and that from 1 July 2026 a lender must update the record of a repaid loan within 3 working days of repayment. 3 The release does not say how facilities at or below the threshold are treated in reporting to OJK.
Earlier regional survey: the Federal Reserve Bank of San Francisco's Asia Focus note "Credit Bureaus in Asia" (October 2011) listed Thailand's National Credit Bureau, together with bureaus in Malaysia, Singapore and Indonesia, as collecting both positive and negative data at the time.
Analysis
"What a credit bureau holds, and how each kind of data shapes a lending decision" (the first part of this series) contrasted negative-only files, which record only adverse events, with positive data that also record on-time payment. On the published descriptions compared here, none of these systems is described as negative-only: each records repayment conduct on performing accounts as well as arrears and defaults. The practical differences sit in three narrower places.
Who must report. In the Philippines the duty to submit both kinds of data applies to all covered submitting entities. In Vietnam it is mandatory for credit institutions and voluntary for other participants; in Cambodia it is mandatory for covered institutions, with others able to contribute. A positive record is only as complete as the set of lenders that feed it, so a borrower's on-time history with a non-reporting lender is invisible.
How long adverse records stay visible. Vietnam allows negative information to be provided for up to five years after it ends; Malaysia's CCRIS report shows arrears over a 12 months window and drops a shortfall once it is settled; Indonesia now requires repaid loans to be updated within 3 working days. These choices set how quickly a borrower's recovery shows up. A shorter window helps a recovered borrower regain access sooner; a longer one gives a lender more history to price on. Neither is better in itself: they balance rehabilitation against risk information.
Thresholds. Indonesia's change means the smallest facilities, below IDR 1 million, are no longer part of SLIK debtor information. Small-ticket products such as BNPL, microloans and earned wage access are where such facilities sit, so a borrower who has used only small credit lines may now show a thinner file than their actual repayment record.
In T&S's view, for a lender designing approval, limit, pricing and monitoring rules in this region, the useful question is less whether a bureau holds positive data, since all the systems described here do, than whose positive data it holds, how long adverse items remain and how fast changes appear. Approval rules that decline on any recent adverse item behave differently where items drop off on settlement than where they stay visible for years; limit and pricing rules that reward a long clean record work only where the borrower's main lenders report.
Counterpoints and uncertainties
The comparison rests on published descriptions from different dates, from a 2011 regional survey to rules effective in 2025 and 2026, and a description of what must be reported does not show how complete or timely reported data are in practice. Voluntary participants may report only part of their portfolios. The rules cited here can be amended, and an amendment can change what must be reported, how long adverse items stay visible or how information is shared. Indonesia's release does not say whether facilities below the threshold remain reported to OJK. Thailand's position is shown here only through the 2011 survey, and later changes may not be reflected. A counterpoint to the T&S view: where reporting is near-universal for regulated lenders, as the Philippine and Cambodian texts require, the positive-versus-negative distinction may matter less than credit scores and other bureau products that summarise the data.
This article is based solely on publicly available sources.
Key figures
- Maximum period negative information may be provided: five years. Longest period after a negative item ends during which CIC may provide it, except to state authorities under law (Circular 15/2023/TT-NHNN). Vietnam, National Credit Information Centre (CIC). Basis date: 1 Jan 2025. Source: State Bank of Vietnam: Circular 15/2023/TT-NHNN on credit information activities (Vietnamese text, Thu Vien Phap Luat)
- CCRIS report look-back window: 12 months. Period for which the CCRIS report shows instalments in arrears and credit applications (Bank Negara Malaysia Credit Bureau FAQ). Malaysia, CCRIS (Bank Negara Malaysia). Basis date: 21 Oct 2026. Source: Bank Negara Malaysia: Credit Bureau, Frequently Asked Questions
The FAQ page carries no date; the window is as shown on the page in October 2026.
- SLIK debtor-information threshold: IDR 1 million. SLIK debtor information covers only financing facilities above this amount (OJK, from July 2026). Indonesia, SLIK reporting institutions. Basis date: 6 Jul 2026. Source: OJK press release SP 128/DKPU/OJK/VII/2026: OJK Luncurkan Optimalisasi SLIK (2026-07-06)
Sources
- Credit Information Corporation: Implementing Rules and Regulations of the Credit Information System Act (Republic Act No. 9510), approved 27 May 2009primary
- State Bank of Vietnam: Circular 15/2023/TT-NHNN on credit information activities (Vietnamese text, Thu Vien Phap Luat)primary
- IFC / National Credit Information Centre of Vietnam: Reforms and Developments in Credit Information System in Vietnam (presentation, 2020)primary
- Bank Negara Malaysia: Credit Bureau, Frequently Asked Questionsprimary
- MoneySense (Government of Singapore): Credit Reports and Creditworthiness (updated 2026-09-28)primary
- OJK press release SP 128/DKPU/OJK/VII/2026: OJK Luncurkan Optimalisasi SLIK (2026-07-06)primary
- CRS Insights for IFC (World Bank Group): Impact Study on Credit Reporting in Cambodia (February 2019), hosted by BIIA
- Federal Reserve Bank of San Francisco, Asia Focus: Credit Bureaus in Asia (October 2011)
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A Japanese version of this article is available: 日本語版
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