---
title: Vietnamese Banks Race to Issue Tier 2 Bonds in 2026
description: An analysis of Vietnamese bank bond issuances in Q3 2026 as Tier 2 capital notes surpass 400 trillion VND, representing nearly 60% of all banking debt.
url: https://ginity.vn/en/blog/vietnamese-banks-tier-2-bond-issuance-capital-2026
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datePublished: 2026-10-31T00:00:00+07:00
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---

# Vietnamese Banks Race to Issue Tier 2 Bonds in 2026

> An analysis of Vietnamese bank bond issuances in Q3 2026 as Tier 2 capital notes surpass 400 trillion VND, representing nearly 60% of all banking debt.

Gini · Macro & monetary · 2026-10-31 · https://ginity.vn/en/blog/vietnamese-banks-tier-2-bond-issuance-capital-2026

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

## Key takeaways

- Outstanding Tier 2 bank notes exceeded 400 trillion VND by late September 2026, comprising nearly 60% of total bank debt.
- Only 7% of Vietnamese commercial lenders held domestic credit ratings by late 2025, lagging regional peers.
- Circular 138/2026/TT-BTC took effect on October 1, 2026, establishing standardized private corporate bond trading rules.

The pace of debt issuance by Vietnamese commercial lenders has accelerated across the second half of 2026. Sustained credit expansion outstripping customer deposit growth has driven financial institutions to tap wholesale debt markets for medium- and long-term liquidity. Within this funding structure, Tier 2 capital notes have emerged as a primary instrument for lenders to bolster regulatory capital and satisfy statutory capital adequacy ratios.

## Tier 2 Notes Surpass 400 Trillion VND

According to an analytical study by credit rating agency VIS Rating cited by [Tin nhanh chứng khoán](https://www.tinnhanhchungkhoan.vn/chi-7-ngan-hang-viet-nam-co-trai-phieu-duoc-xep-hang-tin-nhiem-post400372.html), banking debt commanded a dominant position across the wider capital market, representing approximately 46% of total outstanding corporate bond value in Vietnam as of late September 2026. To evaluate the reliance on subordinated debt within banking balance sheets, the proportion of Tier 2 capital notes is calculated using the following formula:

$$\text{Tier 2 Bond Share} = \frac{\text{Outstanding Tier 2 Capital Notes}}{\text{Total Outstanding Bank Bonds}} \times 100\%$$

Applying data compiled by VIS Rating reported by [Tin nhanh chứng khoán](https://www.tinnhanhchungkhoan.vn/chi-7-ngan-hang-viet-nam-co-trai-phieu-duoc-xep-hang-tin-nhiem-post400372.html) as of late September 2026, outstanding subordinated bank debt exceeded 400 trillion VND, representing nearly 60% of total bank bonds in circulation. These Tier 2 instruments permit commercial lenders to expand their capital buffers and maintain statutory adequacy ratios without diluting equity ownership.

Primary market registration data confirms ongoing private placements by private joint-stock lenders. According to registration notices published by the Vietnam Securities Depository and Clearing Corporation on [vsdc.vn](https://vsdc.vn/vi/ad1/201903), the agency issued securities registration certificate on October 27, 2026, and initiated depository services on October 28, 2026, for the Tier 2 bond tranche of ACB (Asia Commercial Joint Stock Bank), comprising 130 bonds with an aggregate par value of 130.000.000.000 VND against registered charter capital of 58.044.219.570.000 VND.

```chart
{
  "preset": "sector-columns",
  "label": "Share of Banks with Domestic Credit Ratings",
  "caption": "Share of commercial lenders holding domestic credit ratings according to VIS Rating (Malaysia and South Korea exceeded 75%).",
  "locale": "en",
  "params": {
    "values": [7, 60, 75, 75],
    "labels": ["Vietnam", "Thailand", "Malaysia (>75%)", "South Korea (>75%)"],
    "unit": "Rated banks share, %",
    "highlight": 0
  }
}
```

The table below outlines key institutional distinctions between senior unsecured debt and Tier 2 subordinated notes issued by Vietnamese banks in 2026:

| Parameter | Senior Unsecured Bonds | Tier 2 Subordinated Notes |
| :--- | :--- | :--- |
| Capital Treatment | Wholesale debt funding | Supplementary regulatory capital |
| Repayment Priority | Preferential liquidation claim | Subordinated to senior creditors |
| Coupon Postponement | Mandatory coupon payments | Postponement permitted if bank records loss |

Source: Compiled from VIS Rating thematic research report published on October 19, 2026.

## Credit Rating Coverage Gap Across Markets

Despite leading total debt issuance across Vietnam, credit rating penetration among commercial lenders remains limited when evaluated alongside regional peers. According to survey data from VIS Rating published by [CafeF](https://cafef.vn/xep-hang-tin-nhiem-trai-phieu-ngan-hang-viet-nam-con-han-che-nha-dau-tu-kho-dinh-gia-rui-ro-188261029090108894.chn) on October 29, 2026, only 2 out of 28 reviewed commercial lenders in Vietnam had domestic credit ratings at year-end 2025, corresponding to approximately 7%.

Focusing specifically on commercial lenders, this 7% coverage figure in Vietnam contrasts with levels near 60% in Thailand and over 75% in Malaysia, South Korea, and China. Across the broader corporate bond landscape according to VIS Rating comparison figures cited by [CafeF](https://cafef.vn/xep-hang-tin-nhiem-trai-phieu-ngan-hang-viet-nam-con-han-che-nha-dau-tu-kho-dinh-gia-rui-ro-188261029090108894.chn), the share of outstanding bonds with domestic credit ratings in Vietnam reached approximately 12% as of late September 2026, compared to 96% in Thailand (end of September 2024), 64% in Malaysia (year-end 2024), and 55% in China (year-end 2024).

According to data from [CafeF](https://cafef.vn/xep-hang-tin-nhiem-trai-phieu-ngan-hang-viet-nam-con-han-che-nha-dau-tu-kho-dinh-gia-rui-ro-188261029090108894.chn), total banking system assets at the end of 2025 equaled approximately 185% of GDP, whereas outstanding corporate bonds in Q1 2026 represented just 11% of GDP. This 11% ratio stands below 55% in Malaysia and 23% in Thailand, illustrating heavy structural reliance on banking balance sheets for capital allocation.

The absence of comprehensive rating coverage complicates credit risk differentiation for market participants. According to an empirical review by VIS Rating published by [Tin nhanh chứng khoán](https://www.tinnhanhchungkhoan.vn/chi-7-ngan-hang-viet-nam-co-trai-phieu-duoc-xep-hang-tin-nhiem-post400372.html) examining 284 three-year senior unsecured bank bonds issued between 2023 and the end of the first half of 2026, secondary spreads did not consistently reflect credit quality differentials. Across this sample of tranches issued between 2023 and the end of the first half of 2026, selected issuers with higher internal credit profiles exhibited spreads between 280 and 320 basis points, while some issuers in lower categories traded inside 300 basis points.

Individual investors have also provided capital to Tier 2 offerings. According to VIS Rating observations in [Tin nhanh chứng khoán](https://www.tinnhanhchungkhoan.vn/chi-7-ngan-hang-viet-nam-co-trai-phieu-duoc-xep-hang-tin-nhiem-post400372.html), retail accounts absorbed between 30% and 45% of selected public Tier 2 offerings conducted by major state-owned commercial lenders during the first six months of 2026.

## Regulatory Standards and Institutional Framework

To enhance transparency and strengthen wholesale market infrastructure, regulatory bodies have implemented updated guidelines. According to reports from [Government Electronic Newspaper (baochinhphu.vn)](https://baochinhphu.vn/quy-dinh-moi-ve-chao-ban-giao-dich-trai-phieu-doanh-nghiep-rieng-le-102260928180806073.htm), the Ministry of Finance promulgated Circular 138/2026/TT-BTC with effective enforcement starting October 1, 2026, guiding private corporate bond trading under Decree 200/2026/NĐ-CP and establishing formal verification procedures for professional investors on the Hanoi Stock Exchange.

Alongside private placement market supervision, institutional investor participation has received regulatory support. According to public statements by the State Securities Commission on [Government Electronic Newspaper (baochinhphu.vn)](https://baochinhphu.vn/xay-dung-khung-phap-ly-trai-phieu-doanh-nghiep-theo-huong-ben-vung-102260409185438653.htm) on April 9, 2026, Circular 136 amending Circular 98/2020/TT-BTC expanded portfolio allocation limits and investment scopes for securities investment funds, including bond funds, facilitating institutional inflows into medium-term debt securities.

Meeting infrastructure development targets across 2025 to 2030 will require approximately 245 billion USD according to estimates by VIS Rating reported by [CafeF](https://cafef.vn/xep-hang-tin-nhiem-trai-phieu-ngan-hang-viet-nam-con-han-che-nha-dau-tu-kho-dinh-gia-rui-ro-188261029090108894.chn), with state budgets projected to fund 70%. The remaining financing gap requires capital mobilization through private debt markets and corporate bond issuance.

Tier 2 bond issuance continues to serve as an effective mechanism for Vietnamese commercial banks to strengthen capital adequacy ratios and support productive credit growth throughout 2026. As issuance volumes expand, deeper adoption of independent credit ratings and transparent coupon postponement disclosures will help market participants price capital structure risks with greater precision.

## Sources

- VIS Rating: [Vietnam's Bank Debt Rating Coverage Lags Peers, Challenges Risk Assessment of Complex, Deeply Subordinated Bonds](https://visrating.com/research/vietnam-s-bank-debt-rating-coverage-lags-peers-challenges-risk-assessment-of-complex-deeply-subordinated-bonds.368.html) (19/10/2026)
- Government Electronic Newspaper (baochinhphu.vn): [New regulations on private corporate bond placement and trading](https://baochinhphu.vn/quy-dinh-moi-ve-chao-ban-giao-dich-trai-phieu-doanh-nghiep-rieng-le-102260928180806073.htm) (28/09/2026)
- Government Electronic Newspaper (baochinhphu.vn): [Building a sustainable corporate bond legal framework](https://baochinhphu.vn/xay-dung-khung-phap-ly-trai-phieu-doanh-nghiep-theo-huong-ben-vung-102260409185438653.htm) (09/04/2026)
- Vietnam Securities Depository and Clearing Corporation: [Securities registration and depository for ACB Tier 2 bonds](https://vsdc.vn/vi/ad1/201903) (28/10/2026)
- Tin Nhanh Chung Khoan: [Only 7% of Vietnamese banks have rated bonds](https://www.tinnhanhchungkhoan.vn/chi-7-ngan-hang-viet-nam-co-trai-phieu-duoc-xep-hang-tin-nhiem-post400372.html) (28/10/2026)
- CafeF: [Vietnamese bank bond credit ratings remain limited](https://cafef.vn/xep-hang-tin-nhiem-trai-phieu-ngan-hang-viet-nam-con-han-che-nha-dau-tu-kho-dinh-gia-rui-ro-188261029090108894.chn) (29/10/2026)

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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._
