On July 1, 2026, the rules for transferring money from a company account changed in Vietnam. The State Bank of Vietnam (the central bank)’s Circular 77 (Circular 77/2025/TT-NHNN) took effect, and transfers by corporations and sole proprietors above a certain amount can no longer be approved without the legal representative’s (người đại diện theo pháp luật) own face authentication and a one-time password (OTP). Companies that have not registered biometrics may have their online banking itself temporarily suspended. For Japanese managers who run local subsidiaries and for expats entrusted with accounting, this is a practical matter of payments jamming up while the representative is away on travel or a business trip. This article lays out which transactions trigger face authentication and from what amount, who should register, and what happens if you don’t make it in time — explained so that even people involved with Vietnam for travel or short stays can follow.
What began on July 1
The starting point here is Circular 77, issued by the State Bank on December 31, 2025. It amends and supplements the 2024 Circular 50 (Circular 50/2024/TT-NHNN, which set safety and security rules for online banking services) and took effect on July 1, 2026. The aim is to cut fraudulent transfers via impersonation or account lending. Face authentication had been introduced for transfers above a set amount on personal accounts since 2024, and this extends that thinking to companies and household businesses (hộ kinh doanh).
The point is that who presses the transfer-approval button is no longer "anyone." For transactions above a threshold, the company's legal representative holds their own face up to a smartphone or app camera to verify identity, then enters an OTP to approve. There will be situations where the practice of an accountant tapping it through on someone's behalf can no longer be used.
From what amount, and for which companies, does facial recognition apply
The thresholds are tiered by the nature of the company. Because the central bank sets the ceiling and each bank decides its own standard within that range, the exact figures vary by the bank you use. The representative lines commonly cited in reports are as follows.
| Target | The amounts at which facial recognition becomes required | Reference yen conversion |
|---|---|---|
| Sole proprietors and micro-enterprises (using simplified accounting) | Over 10 million dong per transaction, or over 20 million dong in a day's total | About 61,000 yen / about 123,000 yen |
| Companies less than 12 months from incorporation or account opening | Over 50 million dong per transaction, or over 100 million dong in a day's total | About 307,000 yen / about 610,000 yen |
| Invoice payments and international transfers | A guideline of over 100 million dong per transaction or per day | about 610,000 yen |
The yen figures are rough estimates assuming roughly 163 dong to the yen in early July 2026 (a guide, since rates move daily). Transactions below this threshold can be sent as before, with no need to hold up your face. Put the other way, the more a company routinely runs payments in the hundreds of thousands of yen, the more often the representative's face authentication enters the approval flow as a checkpoint. International transfers and large invoice payments tend to be sizable, so they are the transactions most likely to get caught.
What stops if you're unregistered
Another thing not to overlook is the measure for companies that haven't registered biometric data itself. If the identity information and biometrics of the legal representative haven't been updated, each bank advises that electronic banking services, including online transfers and withdrawals, may be temporarily suspended from July 1. In other words, it's not that "only transactions over the threshold are stopped"; if registration is entirely incomplete, transfer routes other than the counter become unusable - a heavy matter. The more a company relies on internet banking for payroll and payments to business partners, the bigger the impact.
How locals see it
Vietnamese banks have repeatedly urged corporate customers to hurry their registration since before the rule took effect. Several banks, TPBank among them, have moved to standardize biometric authentication and permission management ahead of time in their corporate apps, and economic media have run features on “preparing for Circular 77.” Small and mid-sized managers voice worry that approvals may not go through when the representative is on a regional trip or abroad. On the other hand, given the ongoing damage from account sub-lending and impersonated transfers, some see a system where the person approves with their face as a deterrent to fraud. Among those who handle the practical work, how to distribute an operation where approval concentrates on a single representative is the immediate headache.
What Japanese business owners and expats should do this week
For Japanese who hold a local corporation or a household-business account, what to check is simple. First, whether the legal representative's biometric registration is complete at your bank. If not, while the representative is in Vietnam, complete face registration in the corporate app with a valid chip-embedded ID card or passport on hand. In Vietnam, identity verification is being consolidated onto VNeID and electronic ID (eID), and account-related identity checks will keep tightening in this direction. On the entry and residence procedures for the company itself,Vietnam's immigration procedures consolidate into VNeID from June: what expats and companies should dokeeping that in mind too rounds out the full picture around identity verification.
Second is the approval structure. At companies where the representative is at Japan headquarters and not stationed locally, an operation requiring the representative's facial recognition every time there's an over-threshold transfer realistically won't work. It's safest to consult your bank on whether frequently used payments can be split below the threshold, or whether you can switch to an authority design that routes approvals through multiple people. Third is the cash-flow calendar. If the representative is scheduled to be out of the country for an extended period, processing large payments ahead of time so they don't pile up in that window avoids accidents where approvals jam and payments are delayed.
As part of Vietnam’s 2026 “identity-verification shift”
Circular 77 is less a one-off change to banking rules than part of the digitalization and tightening of identity verification Vietnam is pursuing in 2026. That same July, the treatment of income tax and social insurance for residents also changed, affecting take-home pay. Company accounts, personal tax and pensions, entry declarations — across life and business, 'how you prove who you are' is being updated. As for changes to take-home pay and social insurance,Your take-home pay in Vietnam changes from July: income tax and pensions residents should knowwe've laid it out. Handling this by looking at the bank alone tends to leave separate gaps in tax or immigration procedures, so it's wise to take stock of the July-area rule changes all together.
How does it relate to short-term travelers?
People staying just a few days purely for travel are not the direct target of this facial-recognition rule. The target is those who hold a corporate or sole-proprietor account in Vietnam. That said, in Vietnam, traveler-facing systems are also moving at the same time in July 2026 - the return of health declarations on entry, and changes around urban transport and airports. If you're on a half-business, half-tourism stay, checking this period's changes together before departure is reassuring. On increases and decreases in pre-travel procedures,Health declarations return for entry to Vietnam from July, adding one more thing to do before departurefor reference.
Summary: register the representative’s face “before they’re away”
From July 1, 2026, Vietnamese companies and sole proprietorships require the legal representative's facial recognition and an OTP for transfers above certain amounts, and companies that haven't registered biometrics may find online banking itself halted. As a guide, the thresholds are over 10 million dong per transaction for sole proprietors and micro-businesses, and over 50 million dong per transaction for companies less than 12 months old (at about 163 dong to the yen, early July 2026). Three things to do: confirm with your bank that the legal representative's biometric registration is complete; review your authorization design so approvals above the threshold can proceed even in the representative's absence; and move large payments forward before the representative is away for a long stretch. Company accounts have entered an era tied to the representative's face. Before you next leave Vietnam, we recommend checking your company's registration status first.
