VCI Legal – January 30, 2026

On 26 August 2025, the Government issued Decree No. 232/2025/ND-CP (“Decree 232”), amending Decree No. 24/2012/ND-CP dated 3 April 2012 (“Decree 24”) on the management of gold business. Decree 232 came into effect on 10 October 2025 and introduces significant changes to the regulatory framework for gold production and trading.

Gold Bar Production

Under Decree 24, the State held an exclusive right to produce gold bars and to import/export gold materials for production purposes. Decree 232 abolishes this exclusivity and establishes a licensing mechanism administered by the State Bank of Vietnam (SBV).

Under the new framework, enterprises and commercial banks may engage in gold bar production provided they hold a gold trading license and meet the following conditions:

· Minimum charter capital of VND 1,000 billion for enterprises or VND 50,000 billion for commercial banks;

· No record of administrative sanctions in gold trading, or if sanctions were imposed, full compliance with corrective measures;

· Internal regulations governing gold bar production, including procedures for material import, production process, production supervision, and quality control.

Detailed procedures and documentation required to obtain a gold bar production license will be prescribed in guidance issued by the Governor of the SBV. Licensed entities must comply with all production requirements under Decree 232, including standard disclosure, quality assurance, warranty obligations, and maintaining information systems for recording production data.

Import and Export of Gold Bars and Materials

The SBV is responsible for allocating annual quotas to licensed enterprises and commercial banks for the import and export of gold bars, as well as the import of gold

materials. Each transaction of import or export of gold bars, or import of gold materials, requires a specific license issued by the SBV.

Import licenses for gold materials may be granted to:

1. Gold trading enterprises with processing contracts with foreign partners, allowing temporary import for processing into jewelry or fine art products for re-export;

2. Foreign-invested enterprises producing jewelry and fine gold products;

3. Enterprises investing overseas in gold mining activities.

For the export of gold materials, enterprises holding a domestic gold mining license may apply to the SBV for permission to export gold legally mined in Vietnam.

About VCI Legal:

VCI Legal is an award-winning business law firm in Vietnam with a wide range of legal and corporate services, among other things, corporate, banking & finance, tax, labor & HR, real estate and dispute resolution with special focus on international investment disputes, We also offer our specialized type of service called “In-House Counsel Service” with the aim of assisting our clients in dealing with all types of internal and external issues arising from their day-to-day operations and business activities. With our offices in both Hanoi and Ho Chi Minh City, we have a tremendous depth of experience in providing well-reasoned and comprehensive legal advice to not only multinationals and Fortune 500 companies, but also small and medium enterprises.

Our professional team comprises one of the leading law firms in Vietnam with service quality highly recommended and acknowledged by international legal service reviewers such as: The Legal 500, AsiaLaw Profiles, IFLR, KPMG’s Tax Directors’ Handbook, Acquisition International, ACQ Global, Global Law Experts, Finance Monthly, and Chambers & Partners.

For many years, VCI Legal has been ranked among the top law firms in Vietnam for corporate, finance, insurance, taxation, employment, intellectual property and investment. With a “Can Do Attitude” combined with a “Know How” capacity, our firm is big enough to provide comprehensive legal support for any in-house legal matters, yet small enough to care about each of our clients. We undertake each engagement with the mindset of a long-term relationship, with the will to give whatever it takes to understand and fulfill your needs.

Ho Chi Minh City

Suite P7-42.18, Vinhomes Central Park, 720A Dien Bien Phu, Thanh My Tay Ward, Ho Chi Minh City, Vietnam

Tel.: (+84) 028 3827 2029 Fax: (+84) 028 3823 4436

Hanoi

Suite 1903, Floor 19, W1 Tower, Vinhomes Westpoint, Pham Hung, Tu Liem Ward, Hanoi City, Vietnam

Tel.: (+84) 024 3936 4985 – (+84) 024 3936 4987

Affiliated Offices: Beijing – Shanghai – Hanoi – Ho Chi Minh City – Singapore – New Delhi – Dubai – Doha – Zurich – Paris – Rome – Brescia – Washington D.C. – Los Angeles