You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

January 22, 2026

Vietnam Eases Burdens and Extends Compliance Deadline for Insurance Businesses

On December 10, 2025, Vietnam’s National Assembly enacted Law No. 139/2025/QH15 amending the Law on Insurance Business. The amendment, effective from January 1, 2026, introduces various changes in an effort to lift restrictions and hurdles for insurance businesses. Key points that may impact the activities of stakeholders in Vietnam’s insurance market are highlighted below.

Management Personnel Qualifications

To broaden the talent pool while ensuring competency standards, the amended law opens up the positions of director or general director to more candidates. Previously, candidates were required to hold either (i) a university degree or higher in insurance or (ii) a university degree in another discipline and an insurance certificate issued by a qualified insurance training institution. Now, candidates holding a university degree or higher in economics, finance, banking, law, business administration, accounting, or auditing, with at least one insurance‑related module, are also accepted.

These changes are expected to mitigate the ongoing challenges faced by insurers in recruiting suitably qualified candidates for key executive positions, while still maintaining appropriate professional standards.

Fewer Registrations for Insurance Businesses

As part of the legislature’s broader initiative to reduce administrative burdens across all business sectors, the amended Law on Insurance Business relaxes registration requirements for the insurance industry, notably:

  • Insurance enterprises and foreign non‑life insurance branches are no longer required to register and obtain prior approval from the Ministry of Finance (MOF) for their methodologies and bases for calculating premiums for motor vehicle insurance products (excluding compulsory civil liability insurance for motor vehicle owners). Instead, insurance enterprises are now only required to notify the MOF before applying or amending these methodologies.
  • While life insurers must continue to register with the MOF their principles for separating owners’ equity from insurance premium funds, non‑life insurance enterprises and foreign non‑life insurance branches are now only required to notify (rather than register with) the MOF these principles prior to implementation.

Extended Compliance Milestones for Businesses’ Readiness

The risk‑based capital (RBC) regime, a capital adequacy framework requiring insurance businesses to maintain minimum capital levels proportionate to their risk exposures, was introduced in 2022 to replace the current fixed solvency margin framework, and was originally scheduled for full adoption in 2028. However, recognizing the technological and practical challenges faced by both insurers and regulators in implementing the RBC regime, the amended Law on Insurance Business has a phased timeline, drawing on Hong Kong’s experience where Hong Kong regulators allowed insurance businesses a three-year transitional period to prepare resources and upgrade their systems.

Core RBC requirements (including actual capital, risk‑based capital, and capital adequacy ratio) will apply from January 1, 2028, while supervisory intervention measures will only take effect from January 1, 2031. From 2028 to 2030, insurers will operate under a transitional period, during which they must monitor capital based on RBC principles and may adopt self‑directed capital‑increase plans if shortfalls arise.

This extended deadline allows insurers additional time to upgrade systems, remedy data and accounting gaps, and prepare for full RBC compliance, enhancing stability and regulatory certainty.

Insurance Agent Certifications Extended by Six Months

The deadline for insurance agent certificates issued before January 1, 2023, to be converted to the new standardized certificates was originally December 31, 2025. The amended law allows these certificates to remain valid for an additional six months, until June 30, 2026. This extension provides insurers with needed time to compile, review, and standardize documentation for its insurance agents, addressing longstanding inconsistencies in historical records and easing the operational burden of processing a large volume of certificates.

Outlook

With the amended Law on Insurance Business now in effect, insurers and stakeholders should begin assessing how the revised qualification standards, reduced administrative procedures, phased RBC implementation, and extended insurance agent certificate transition will affect their operations.

RELATED INSIGHTS​ 

May 28, 2025
Tilleke & Gibbins attorneys in Vietnam have contributed the 2025 edition of Doing Business in Vietnam, a comprehensive Q&A-style resource from Thomson Reuters Practical Law that provides essential insights for companies navigating business operations in Vietnam. The guide presents a detailed overview of the country’s legal framework and regulatory environment, reflecting recent updates in Vietnamese legislation and practice. This annually updated guide offers key information on the following areas: Legal system: Structure of the Vietnamese judiciary and the role of codified law. Foreign investment: Conditions for market access, licensing requirements, foreign ownership restrictions, and investment incentives. Business vehicles: Formation and operation of legal entities, including limited liability companies, joint-stock companies, and representative offices. Employment: Employment contracts, social insurance, labor rights, and procedures for hiring foreign nationals. Tax: Overview of corporate income tax, personal income tax, value-added tax, and other tax obligations. Intellectual property: Procedures for protecting and enforcing patents, trademarks, copyrights, and other IP rights. Data protection: Compliance requirements under Vietnam’s data privacy laws, including the Personal Data Protection Decree. Competition law: Antitrust rules and regulatory oversight under the Law on Competition. Anti-bribery and corruption: Legal framework and enforcement practices aimed at curbing corrupt activities. E-commerce and digital business: Regulations governing online platforms, digital content, and cross-border services. Marketing and advertising: Laws and guidelines on advertising standards and consumer protection. Product regulation and liability: Safety requirements, product liability issues, and roles of relevant authorities. Doing Business in Vietnam is part of Practical Law’s global series of legal guides designed to support international practitioners and businesses. To access the most recent edition of the Vietnam guide, visit the Practical Law website and sign up for a free trial.
May 2, 2025
Attorneys from Tilleke & Gibbins have updated the latest edition of Doing Business in Thailand, a Q&A-style guide from Thomson Reuters Practical Law that offers an overview of key legal considerations for companies operating in jurisdictions worldwide. The contribution outlines the country’s legal and regulatory framework for foreign investment and business operations and reflects the latest legislative developments. The chapter addresses the following core topics: Legal system: Structure of the courts and the codified nature of Thai law. Foreign investment: Business restrictions under the Foreign Business Act, sector-specific regulations, exchange control rules, and investment incentives. Business vehicles: Overview of partnerships, private and public limited companies, and other legal entities. Employment: Labor protections, employment contracts, foreign worker requirements, and termination procedures. Tax: Corporate and personal income tax, indirect taxes, and tax obligations for residents and non-residents. Intellectual property: Registration and enforcement of patents, trademarks, designs, and copyrights. Data protection: Key provisions of the Personal Data Protection Act and related compliance obligations. Competition law: Regulatory framework under the Trade Competition Act. Anti-bribery and corruption: Relevant legislation and enforcement mechanisms. E-commerce and digital business: Legal regime for online transactions and digital platforms. Marketing and advertising: Consumer protection laws and regulations affecting advertising and marketing practices. Product regulation and liability: Safety standards, liability regimes, and roles of enforcement authorities. Practical Law, a legal reference resource from Thomson Reuters, publishes a range of guides for hundreds of jurisdictions and practice areas. The insurance and reinsurance guide is a valuable resource for legal practitioners, covering numerous jurisdictions worldwide. To view the latest version of the guide, please visit the Practical Law website and enroll in the free Practical Law trial to gain full access.
April 29, 2025
On April 11, 2025, Thailand’s Office of Insurance Commission (OIC) released draft principles for two notifications for public comment, open until the end of April. These aim to amend the OIC Notifications on Guidelines for Customer Personal Data Protection for life and non-life insurance businesses, which were issued in 2021. Key Principles Both life and non-life insurance companies will be required to obtain consent for the following processing activities: Processing of general personal data: When requesting the OIC to disclose information related to a customer’s insurance policy for the purpose of underwriting or claims consideration. Processing of sensitive personal data: When requesting the OIC to disclose information related to a customer’s insurance policy for the purpose of underwriting or claims consideration; and When requesting the OIC to disclose information about a customer’s insurance fraud behavior for fraud monitoring, fraud risk management, and assessing and preventing insurance fraud risk for underwriting or claims payment. The consent for the above processing activities must be in accordance with the consent requirements prescribed by the OIC, and the disclosure of personal data must also comply strictly with the conditions set by the OIC. Life insurance companies may obtain consent for other purposes as long as they comply with Thailand’s Personal Data Protection Act B.E. 2562 (2019), and companies will be liable in the event of a personal data breach. Additional Principles for Non-Life Insurance Businesses Non-life insurance companies will be required to provide a privacy notice and a summary of the privacy notice for each type of insurance policy in accordance with the form prescribed by the OIC. The privacy notice and its summary must be provided prior to or at the time of offering insurance policies, or together with the consent form for data processing through any channels used for offering insurance.
April 1, 2025
The collapse of a building under construction in Bangkok on March 28, 2025, following a powerful earthquake in Myanmar has sparked widespread public concern about the potential financial impact on local insurers and insurance implications. The construction site was insured under a contractors’ all risks (CAR) policy, and initial reports and market speculation suggest that the event could cause serious financial strain for the domestic insurance industry. Nevertheless, local insurers connected to the site of the collapse may face limited exposure for two main reasons: Reinsurance significantly mitigates local insurers’ exposure. According to market sources, 95% of the CAR coverage for the construction site was reinsured by foreign reinsurers. This is standard risk-management practice for large-scale infrastructure and construction projects, allowing local insurers to participate in underwriting while transferring most of the liability offshore. As a result, the direct financial impact on domestic insurers is expected to be minimal, subject to the reinsurance contracts and any potential claims disputes. Potential exclusions may apply. The Thai General Insurance Association has issued an interim public advisory noting that coverage under the CAR policy may be limited or excluded altogether, pending a full investigation. CAR policies often contain exclusions for certain events, depending on how the policy is worded and the actual cause of the incident. A thorough factual and forensic investigation will be necessary to determine the true cause and assess policy applicability. For further information or assistance in reviewing CAR or project insurance coverage in Thailand, please contact Athistha (Nop) Chitranukroh at [email protected], Witchupong Chittchang at [email protected], or Ajaree Trachukul at [email protected].