5 Key Points from Circular 08/2026/TT-BTC on Pre-Funding Requirements for Foreign Institutional Investors
Under the previous framework, investors were generally required to deposit 100% of purchase funds in a local account before placing a buy order. This approach differed from settlement mechanics used in most developed capital markets, where trades are typically executed first and settled within a standard cycle.
For foreign institutional investors operating across multiple jurisdictions, this created operational inefficiencies and constrained participation in the Vietnamese market.
The Ministry of Finance issued Circular 08/2026/TT-BTC in early 2026, introducing targeted changes to pre-funding requirements for certain securities transactions by foreign institutional investors.
The Circular took effect shortly after issuance, marking a step toward aligning Vietnam’s securities settlement framework with international post-trade practices, while maintaining existing foreign exchange controls.
Circular 08/2026/TT-BTC permits eligible foreign institutional investors to execute securities purchase orders before remitting funds, provided that payment is completed within the prescribed settlement cycle.
In international practice, this approach is commonly described as post-trade settlement, where:
Vietnam’s reform adopts this widely recognized model while retaining regulatory oversight.
Covered investors:
Not covered:
Circular 08/2026/TT-BTC does not:
Funds must still be transferred and settled in compliance with existing law.
Internationally, post-trade settlement is recognized by global standard-setting bodies including IOSCO and the BIS, which Vietnam is member of, as a core feature of modern securities markets.
Index providers and multilateral institutions assess pre-funding requirements when evaluating market accessibility for institutional investors.
By adjusting the timing of funding requirements for institutional trades, Vietnam aims to:
Practical implications
Companies, funds, and intermediaries should:
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