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

Implications

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 has not been reported. 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.

Counterpoints and uncertainties

The scope of 'other organisations' and any transitional arrangements will decide how quickly lenders must change their consent flows. 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.