T&S View: Vietnam's data-driven lending push and consent rules call for joint design

Published 28 Sep 2026Data as of 25 Sep 2026T&S ViewVietnamT&S ViewSME

This article is T&S’s view, separate from the facts it cites.

Correction: Restructured in the order facts, view, uncertainty.

In September a tax data-sharing agreement, the SBV's call for data-based underwriting and a consent circular coincided
We think data use and consent management should be treated as a single design problem
Data scope and implementing rules are not yet settled, so this view carries significant uncertainty

Facts

This article reflects the views of T&S.

Facts: (1) The General Department of Taxation and the National Credit Information Centre (CIC) signed a data exchange cooperation agreement (Viet Nam News, 2026-09-25; data scope and timing undecided). (2) On 19 September, SBV Governor Pham Duc An urged banks to shift from collateral-based to cash-flow and data-based underwriting, and SME credit was reported to have grown 12.4% year to date (Viet Nam News, 2026-09-19). (3) Under Circular 46/2026/TT-NHNN, the SBV requires explicit consent in a verifiable form for third-party sharing of credit information, effective 1 November 2026 (VietnamPlus, 2026-09-14).

Analysis

We believe these should be treated not as separate issues but as a single design problem. First, consent withstands later scrutiny only if what is recorded includes not just the fact of consent but which data are used, for what purpose and for how long. Second, when external data are brought into underwriting, alternatives are needed so that borrowers with missing data (such as cash-heavy micro-businesses) are not uniformly disadvantaged. Third, while the data scope is unsettled, underwriting should avoid over-reliance on any specific dataset.

By comparison, Thailand is also pursuing alternative-data underwriting (9 September, BOT Governor) alongside BNPL disclosure and affordability requirements (4 September); running data use and discipline in parallel is a regional trend.

Implications

ExecutivesIn our view, differences in data use will show up less in volume than in the quality of operating it lawfully and explainably.

InvestorsWhen evaluating lenders that promote data-driven credit, we think consent management and auditability are worth adding to the checklist.

OperatorsBefore the November effective date, we recommend reviewing consent wording, record retention and fallback underwriting for missing data together.

Counterpoints and uncertainties

The scope of tax data and the circular's implementing details are not yet settled, so the actual operational burden may prove lighter (or heavier) than expected. Even as data use expands, credit improvement may be limited in segments where the cash economy dominates, in which case our view may overstate the effect. This article is based on three press reports; SBV and tax authority primary documents have not been checked.

Sources

Reports are for information only and are not investment advice. Methodology: sources, verification and definitions