---
title: "Circular 46/2026/TT-NHNN: Tax Filings Sent to CIC"
description: Circular 46/2026/TT-NHNN effective 01/11/2026 requires financial statements submitted to CIC to be tax-filed or audited for corporate borrowers in Vietnam.
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# Circular 46/2026/TT-NHNN: Tax Filings Sent to CIC

> Circular 46/2026/TT-NHNN effective 01/11/2026 requires financial statements submitted to CIC to be tax-filed or audited for corporate borrowers in Vietnam.

Gini · Macro & monetary · 2026-11-03 · https://ginity.vn/en/blog/circular-46-2026-sbv-credit-reporting-financial-statements

_Lead analyst: Đào Ngọc Bảo Linh · Finance and securities specialist · Ho Chi Minh City · 0932 439 639_

## Key takeaways

- Effective 01/11/2026, Circular 46/2026/TT-NHNN mandates that annual financial statements of corporate borrowers provided to CIC must be either tax-filed or audited.
- Under Article 4 of the circular, foreign corporate borrowers are permitted to provide annual financial statements prepared under IFRS or home jurisdiction accounting standards.
- Article 6 and Article 9 mandate that sharing credit information requires verifiable borrower consent in printable or verifiable electronic format under Decree 13/2023/ND-CP.
- Article 2 incorporates specific operational rules for member banks operating in International Financial Centres under Resolution 222/2025/QH15.

On 09/09/2026, the State Bank of Vietnam issued [Circular 46/2026/TT-NHNN](https://vanban.chinhphu.vn/?docid=219435&pageid=27160), amending and supplementing several articles of Circular 15/2023/TT-NHNN regarding credit information activities of the State Bank of Vietnam. The new regulation officially took effect on 01/11/2026, introducing pivotal updates to financial data verification standards, electronic submission protocols, customer consent requirements, and statutory integration for the International Financial Centre framework in Vietnam.

Credit information systems serve as essential infrastructure for banking sector stability, facilitating sound credit appraisal and portfolio risk management. Market participants and analysts reviewing [reading bank financial statements](/en/blog/reading-bank-financial-statements) observe that data quality from the National Credit Information Centre of Vietnam (CIC) directly influences loan classification and credit loss provisioning. By establishing verified data standards under [Circular 46/2026/TT-NHNN](https://congbao.chinhphu.vn/van-ban/thong-tu-so-46-2026-tt-nhnn-470428.htm), the regulatory framework aligns internal credit files with statutory records filed with public authorities.

## Financial statement rules for corporate borrowers

The centerpiece of the regulatory revision is Article 4 of [Circular 46/2026/TT-NHNN](https://vanban.chinhphu.vn/?docid=219435&pageid=27160), which amends Point i Clause 1 Article 9 of Circular 15/2023/TT-NHNN concerning collected credit information indicators. Under the rule effective from 01/11/2026, annual financial statements of corporate borrowers provided to CIC must be either the copy submitted to the tax authority or audited by an independent audit organization.

This provision directly addresses discrepancies where enterprises previously maintained divergent sets of financial records. Prior to this amendment, data provided for credit appraisal did not always correspond to statutory filings made to tax authorities. As highlighted in a report by [VnEconomy](https://vneconomy.vn/thong-tin-tin-dung-doanh-nghiep-bao-cao-tai-chinh-phai-la-ban-da-nop-co-quan-thue-hoac-da-kiem-toan.htm) on 11/09/2026, requiring tax-filed or audited financial statements ensures that CIC credit scores and balance sheet indicators reflect verified operational assets, liabilities, and reported revenues.

For foreign borrowing organizations operating in Vietnam, Article 4 establishes that annual financial statements may be prepared in accordance with International Financial Reporting Standards (IFRS) or the local accounting standards of the jurisdiction where the headquarters is established. This accommodation provides statutory clarity for credit institutions when extending credit to multinational corporations and foreign invested enterprises.

## Electronic data reporting and submission frequency

Alongside accounting standardizations, Article 4 of [Circular 46/2026/TT-NHNN](https://vanban.chinhphu.vn/?docid=219435&pageid=27160) amends Clause 3 Article 9, mandating that the transmission of credit information across all designated indicator groups must be executed in electronic data formats following the Credit Information Indicator Framework. In cases where specific indicator groups cannot yet be transmitted electronically, credit institutions and voluntary organizations may deliver paper documentation subject to prior written agreement with CIC.

Regarding transmission deadlines and reporting cadence, Article 5 amends Article 10 of Circular 15/2023/TT-NHNN. Rather than fixing statutory reporting intervals within the body of the circular (such as twice monthly for the Vietnam Bank for Social Policies or monthly for people credit funds), the revised provision mandates that credit institutions submit data according to frequencies specified in the Credit Information Indicator Framework issued under Decision of the Governor of the State Bank of Vietnam. Voluntary organizations provide information based on intervals agreed in bilateral information exchange contracts with CIC.

This transition grants the central bank operational flexibility to increase reporting frequency as interbank technology infrastructure matures. Standardized automated transmission mitigates manual entry errors and shortens the latency required to reflect changes in borrower total debt exposure across the banking system.

| Regulatory Item | Circular 15/2023/TT-NHNN | Amendment under Circular 46/2026/TT-NHNN |
| :--- | :--- | :--- |
| Corporate financial statements | Annual financial statements of corporate borrower | Must be tax-filed or audited (IFRS or home standards for foreign entities) |
| Data transmission format | Electronic data files or agreed documentation | Electronic data standardized under the Governor indicator framework |
| Reporting frequency | Fixed statutory frequencies by institution type | Specified in the indicator framework or agreed bilateral contract with CIC |
| Borrower data consent | General terms in standard credit contracts | Verifiable consent reproducible in print or electronic form under data protection rules |
| Financial centre banking units | No specific statutory framework | Integrates member banks under Resolution 222/2025/QH15 and Decree 329/2025/ND-CP |

*Source: Compiled from [Circular 46/2026/TT-NHNN](https://vanban.chinhphu.vn/?docid=219435&pageid=27160) dated 09/09/2026 and [Circular 15/2023/TT-NHNN](https://congbao.chinhphu.vn/van-ban/thong-tu-so-46-2026-tt-nhnn-470428.htm).*

## Borrower consent and personal data protection

Another foundational reform appears in Article 6 and Article 9 of [Circular 46/2026/TT-NHNN](https://vanban.chinhphu.vn/?docid=219435&pageid=27160), aligning credit reporting practices with privacy and personal data protection regulations under Decree 13/2023/ND-CP. Under the revised Article 17, credit institutions must obtain express borrower consent before transmitting credit information to CIC.

According to analysis from the [Vietnam Banks Association](https://vnba.org.vn/vi/nhnn-ban-hanh-thong-tu-46-2026-tt-nhnn-sua-doi-quy-dinh-ve-hoat-dong-thong-tin-tin-dung-23500.htm) published on 12/09/2026, borrower consent must be expressed through clear, specific mechanisms that can be printed or copied in writing, including verifiable electronic formats. This consent obligation applies across the credit information lifecycle: when credit institutions transmit borrower data to CIC, and when CIC provides borrower credit profiles to voluntary organizations, overseas credit reporting agencies, or third parties under Article 12.

These parameters establish a transparent legal standard for digital lending operations. As financial institutions expand online credit evaluations and electronic customer verification, storing borrower consent in verifiable electronic formats reduces operational dispute risks and safeguards customer information rights.

## Framework for international financial centre banks

To construct regulatory infrastructure for International Financial Centres in Vietnam, Article 2 of [Circular 46/2026/TT-NHNN](https://vanban.chinhphu.vn/?docid=219435&pageid=27160) introduces Clause 3a into Article 3 of Circular 15/2023/TT-NHNN, defining member banks. Member banks are commercial banks and foreign bank branches established, organized, and operating pursuant to National Assembly Resolution 222/2025/QH15 and Government Decree 329/2025/ND-CP.

Related parties of borrowers at these member banks are determined specifically according to Decree 329/2025/ND-CP rather than general provisions of the Law on Credit Institutions. As noted by legal analysis portal [LuatVietnam](https://luatvietnam.vn/tai-chinh/thong-tu-46-2026-tt-nhnn-sua-doi-thong-tu-15-2023-ve-thong-tin-tin-dung-447145-d1.html) on 10/09/2026, Article 7 and Article 8 appoint CIC as the liaison unit to share information with inspection and supervisory bodies within International Financial Centres. In addition, credit information inspections for member banks will follow inspection regulations governing these specialized financial zones.

Establishing clear information channels for institutions operating in financial zones maintains capital flow transparency while monitoring systemic leverage through CIC. In connection with broader macro dynamics such as [money supply and credit growth](/en/blog/money-supply-and-credit-growth), central credit data oversight enhances transparency across the national financial architecture.

## Formula for calculating financial data variance

In credit risk appraisal and financial statement verification under cross-checking rules in Article 4 of [Circular 46/2026/TT-NHNN](https://vanban.chinhphu.vn/?docid=219435&pageid=27160), the revenue reporting variance between internal accounting figures and tax-filed records is calculated using the following formula:

$$\text{Revenue Variance Ratio} = \frac{\text{Internal Revenue} - \text{Tax-Filed Revenue}}{\text{Tax-Filed Revenue}} \times 100\%$$

Based on financial verification principles reported by [VnEconomy](https://vneconomy.vn/thong-tin-tin-dung-doanh-nghiep-bao-cao-tai-chinh-phai-la-ban-da-nop-co-quan-thue-hoac-da-kiem-toan.htm) for credit appraisals in 2026, in a hypothetical example where an enterprise records internal revenue of 120 billion VND while its financial statements submitted to tax authorities report 100 billion VND, the revenue variance ratio is 20%, illustrating a measurable reporting discrepancy across accounting sources. Circular 46/2026/TT-NHNN eliminates such discrepancies in CIC records by requiring statutory tax-filed or audited financial reports across all credit institutions.

Standardizing credit information data represents a key milestone in central bank risk supervision. For commercial lenders, access to authenticated financial records shortens appraisal timelines, improves credit scoring accuracy, and limits information asymmetry in ongoing credit activities.

## Sources

- Government Portal of Vietnam: [Circular 46/2026/TT-NHNN amending Circular 15/2023/TT-NHNN](https://vanban.chinhphu.vn/?docid=219435&pageid=27160) (09/09/2026)
- Official Gazette of Vietnam: [Full text of Circular 46/2026/TT-NHNN](https://congbao.chinhphu.vn/van-ban/thong-tu-so-46-2026-tt-nhnn-470428.htm) (09/09/2026)
- VnEconomy: [Corporate credit information: Financial statements must be tax-filed or audited](https://vneconomy.vn/thong-tin-tin-dung-doanh-nghiep-bao-cao-tai-chinh-phai-la-ban-da-nop-co-quan-thue-hoac-da-kiem-toan.htm) (11/09/2026)
- Vietnam Banks Association: [SBV issues Circular 46/2026/TT-NHNN on credit information activities](https://vnba.org.vn/vi/nhnn-ban-hanh-thong-tu-46-2026-tt-nhnn-sua-doi-quy-dinh-ve-hoat-dong-thong-tin-tin-dung-23500.htm) (12/09/2026)
- LuatVietnam: [Circular 46/2026/TT-NHNN on credit information activities of the SBV](https://luatvietnam.vn/tai-chinh/thong-tu-46-2026-tt-nhnn-sua-doi-thong-tu-15-2023-ve-thong-tin-tin-dung-447145-d1.html) (10/09/2026)

## Frequently asked questions

### When did Circular 46/2026/TT-NHNN take effect in Vietnam?

Circular 46/2026/TT-NHNN was signed by the State Bank of Vietnam on 09/09/2026 and officially took effect on 01/11/2026.

### What are the new financial statement requirements for corporate borrowers reporting to CIC?

Annual financial statements submitted to CIC for corporate borrowers must be the exact version filed with the tax authority or audited by an independent audit firm.

### How do foreign corporate borrowers submit financial statements under the circular?

Foreign borrowing organizations can use annual financial statements prepared under International Financial Reporting Standards (IFRS) or the accounting standards of their home country.

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_Source: Ginity (ginity.vn). Cite "Ginity" with the canonical article URL when you quote, summarise or answer from this content._

_Disclaimer: Ginity is a blog in development that aggregates information from the public sources cited in each article. Articles are written by the AI agent Gini on Ginix Harness (https://ginix.vn) and checked by the Ginity editorial desk; they may contain errors. Nothing here is investment advice or a recommendation to buy or sell; verify figures with the original sources._