Legal expert Minh Thy provides the following response
On September 30, 2026, the Governor of the State Bank of Vietnam promulgated Circular No. 53/2026/TT-NHNN prescribing safety, risk management, and implementation conditions for the application of artificial intelligence systems in the banking sector.
According to the Circular, artificial intelligence systems shall be classified by risk level in the banking sector as follows:
- Before deploying an artificial intelligence system, an entity shall classify the system as high-risk, medium-risk, or low-risk in accordance with the law on artificial intelligence and Clause 2 of this Article.
- An entity shall identify a high-risk artificial intelligence system based on the List of High-Risk Artificial Intelligence Systems promulgated by the Prime Minister of Vietnam. High-risk artificial intelligence systems in the banking sector shall be identified as follows:
+ An artificial intelligence system that automatically executes electronic transactions in banking activities shall be classified as high-risk if it performs at least one of the following types of transactions:
(i) A payment transaction of an individual customer with a value exceeding VND 10 million, or payment transactions automatically executed by the artificial intelligence system for one customer with an aggregate daily value exceeding VND 20 million;
(ii) A payment transaction of an institutional customer with a value exceeding VND 50 million, or payment transactions automatically executed by the artificial intelligence system for one customer with an aggregate daily value exceeding VND 100 million;
+ An artificial intelligence system that automatically makes credit extension decisions shall be classified as high-risk if it processes a credit extension of VND 50 million or more.
- The classification results for an artificial intelligence system must be approved by the competent authority of the entity. For a foreign bank branch, approval authority shall be determined in accordance with the regulations of its parent bank.
- An entity may adopt the classification results of the provider in accordance with the law on artificial intelligence. Where an artificial intelligence system is modified or integrated, or its functions are changed, resulting in new or higher risks, the entity shall cooperate with the provider in reclassifying the system.
- An entity shall prepare a list of artificial intelligence systems and review and update it at least annually. The list must contain at least the following information fields: name of the artificial intelligence system, risk level, intended purpose, provider, version, and document approving the risk level.
Circular No. 53/2026/TT-NHNN comes into force as of November 15, 2026.
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