IFC membership is the gateway to every benefit Vietnam’s new international financial centre offers – the tax regime, the foreign exchange rules, the sandbox, the specialised court. Being inside the geographic perimeter is not enough; an institution must be licensed as a member. This guide explains who qualifies, how the process works and what applicants should prepare.
What IFC membership actually confers
Decree 323/2025/ND-CP applies to members of the international financial centre, investors and organisations involved in investment and business activity and dispute resolution inside it. Membership is what brings an entity within that perimeter of special mechanisms – preferential tax treatment, the distinct foreign exchange regime, employment facilitation, land policy and access to the centre’s dispute resolution body.
Equally important is what membership does not do. It does not exempt a member from Vietnamese law generally, and it does not license activities outside the centre’s scope. The special regime operates inside defined boundaries, and structuring around that line is the core planning question.
Who can apply for IFC membership
The priority sector list in Decree 323/2025 signals the intended member base: developers of international financial centre infrastructure; green and ESG-linked finance vehicles; commodity, commodity derivative and international trade finance businesses; fintech and innovation firms; investment funds and asset management companies; and professional support service providers. Applicants outside these categories are not necessarily excluded, but the priority list is where licensing appetite concentrates.
The unified IFC membership licensing standard
The single most useful fact about IFC membership is that the criteria are uniform. All standards, regulations, processes, rules, business forms and licensing criteria are issued once by the Executive Council and applied simultaneously at both the Ho Chi Minh City and Da Nang locations. Applicants do not shop between sites for a softer regulator; they choose on ecosystem and cost.
Preparing an IFC membership application
Five workstreams typically run in parallel. Activity mapping: confirming the intended business sits within a licensed category and identifying which elements fall outside. Entity structuring: deciding what is established inside the centre, what stays in an ordinary Vietnamese company and what remains offshore. Substance planning: office space inside the perimeter, local staffing and the work permit position covered in our employment guide. Financial modelling: the tax and repatriation analysis in our tax incentives guide. And governance documentation – the policies, risk framework and compliance manual any credible supervisor expects.
Applications are submitted through the centre’s one-stop electronic administrative system, on which the executive bodies in both cities publish information.
IFC membership timing strategy
Early IFC membership carries an advantage that later entrants cannot replicate. From 2026 the centre’s institutions are mandated to propose further special mechanisms, and an advisory council of domestic and international finance and legal experts feeds that process. Founding members shape rules that subsequent applicants simply inherit. Within five years the Executive Council must review operations and may propose restructuring – a further reason to be established and heard before that review.
IFC membership FAQs
Can an existing Vietnamese company become a member?
An existing entity may apply where its activities fit a licensed category, though many groups establish a dedicated vehicle so the special regime applies cleanly to defined business and the legacy company continues under ordinary rules.
Is a physical office required?
Presence inside the perimeter is the practical expectation, and the decree provides functional zones – financial trading, banking, exchanges, offices, arbitration and courts – for exactly that purpose. Substance requirements are also what make tax positions defensible.
How long does it take?
The framework is new and timelines are still settling; applicants should budget for a preparation phase measured in months rather than weeks, and engage before the structure is fixed rather than after. Official texts are published via the Ministry of Finance, and our international financial centre overview gives the wider frame.
Common structuring mistakes
Four errors recur among early applicants. The first is applying with an activity description drafted for marketing rather than licensing – broad, aspirational language that a supervisor cannot map to a permitted category, which invites either refusal or a narrower licence than intended. The second is treating the member entity as a booking vehicle while all decisions are taken offshore; substance failures of that kind undermine both the licence and the tax position it was built to capture.
The third is under-scoping the compliance function. A financial centre supervisor with inspection powers expects documented policies, a named compliance officer and evidence that the framework operates, not merely that it exists. Retrofitting that after licensing is far more expensive than building it into the application. The fourth is sequencing the group structure after the licence rather than before, which forces amendments to filings already made and reopens questions that were closed.
None of these is difficult to avoid. All of them are difficult to unwind, which is why the preparation phase deserves more time and more senior attention than applicants typically allocate to it.
This article is provided for general information only and does not constitute legal advice for any specific case. Regulations may change – please consult a qualified professional before acting. Should further analysis be required, please contact one of our lawyers below.
