The State Bank of Vietnam (SBV) has released a draft circular tightening oversight of artificial intelligence in the banking sector, requiring lenders and e-wallet providers to notify customers in advance whenever AI systems are deployed in direct interactions.
Regulatory Impact
The proposed regulation applies broadly to all banks and intermediary payment service providers operating AI-powered customer-facing tools — including virtual assistants, automated hotlines, and chatbots. Institutions must also notify users when AI is used for emotion recognition or biometric classification. Any AI-generated content, whether image, audio, or video, must be clearly disclosed to prevent potential misunderstanding. Notably, the draft explicitly prohibits financial institutions from exploiting customer vulnerabilities — such as age, disability, or financial hardship — to market high-risk or unsuitable financial products using AI. The rules are expected to take effect in March 2026, while AI systems already in operation will have until September 2027 to achieve full compliance.
Compliance Requirements
Banks must establish a human review mechanism for customers wishing to contest decisions made by AI systems, ensuring access to personnel oversight in all such cases. Separate notification protocols are required when biometric classification or emotion recognition functions are applied. Mandatory labeling of AI-generated content represents another key compliance obligation. Financial institutions are expected to conduct thorough internal audits of existing AI deployments ahead of the effective date.
Industry Response
Vietnamese banks have significantly expanded AI use in recent years, applying it across areas such as eKYC, credit scoring, loan appraisal, and fraud detection. The rapid spread of generative AI in customer service — handling queries on transactions, card services, interest rates, and exchange rates — has heightened regulatory concerns around data security, output accuracy, and privacy protection. The SBV framed the tighter framework as a measure to control risks arising from this rapid expansion, while ensuring fair treatment and protection of vulnerable customer groups.
International Context
Vietnam’s move reflects a broader global trend toward structured AI governance in the financial sector. The EU AI Act mandates transparency and human oversight requirements for high-risk AI systems, while regulators in the United States and Singapore are advancing comparable frameworks for financial services. Vietnam’s draft circular aligns with this emerging international regulatory direction, signaling the country’s intent to develop a responsible AI ecosystem in tandem with rapid adoption.
