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Under Decree 85/2026/NĐ-CP, supplementary pension funds are allowed to broaden their investment portfolios to include listed securities and to reduce their minimum allocation to Government bonds for sufficiently large funds. The Ministry of Finance said the move is intended to complete the legal framework and support sustainable development of the market.
Decree 85 defines participants as workers who join supplementary pension schemes through employers. The participation process is designed to cover the full cycle, from negotiating agreements with employees, signing contracts with the fund management company, opening personal pension accounts, and making contributions by both the employer and any portion employees entrust to the employer (if applicable).
The management of supplementary pension funds is a restricted business, requiring strict criteria covering the business form, financial capacity, governance experience, and personnel quality.
Decree 85 sets out four conditions:
(i) The entity must be an insurance company or a fund management company.
(ii) If the entity is a securities fund management company, it must be managing total assets of at least 1,000 billion VND.
(iii) If the entity is an insurance company, it must meet conditions to implement pension products and manage supplementary pension funds under insurance business law. If it is a securities fund management company, it must have at least 5 years of experience and be managing at least two public funds, including at least one bond fund, and must have a draft charter for the proposed funds and a business plan.
(iv) The entity must have at least five employees with at least five years of direct experience in pension fund management, mutual fund management, or insured fund management, including at least three staff with fund management licenses or international financial analysis certificates.
The Ministry of Finance said the operating mechanism will continue under a cooperation model among the fund management company, the supervising bank, the depository organization, and the unit managing personal accounts. These parties are tasked with ensuring transparency, accuracy, and safety of participants’ assets.
Governance and oversight are designed to combine pre- and post-activity controls, including issuing certificates of operating eligibility, reporting regimes, information disclosure, and periodic or unscheduled inspections. The Ministry will coordinate with other ministries to conduct checks every two years or carry out unscheduled inspections to assess compliance and continued service capability.
In cases of violations, beyond revoking the operating license, the fund management company may be barred from applying for a new license for three years, or required to suspend establishing new funds for two years and publicly disclose the violations.
On investment activity, Decree 85 allows funds to expand portfolios to listed securities while adjusting the minimum Government bond investment down to 40% for sufficiently large funds. The regulation also adds investment limits and risk management criteria to protect participants’ interests.
On payouts, the principle remains that payments from the fund are based on the balance in individual accounts according to market mechanisms, and the State does not guarantee payout levels. The regulation also allows early withdrawals in certain special cases and applies certain fees to discourage early withdrawal and encourage long-term saving.
After more than a decade of implementing Decree 88/2016/NĐ-CP on voluntary supplementary pension, Vietnam’s voluntary pension market has expanded as part of the social security system and as a long-term saving channel for workers.
Under the rules, voluntary supplementary pension is formed from voluntary contributions by workers and employers through personal pension accounts. Funds are licensed to be managed by insurance companies and securities fund management companies.
Ministry of Finance data show that by the end of 2025, the market had four eligible companies operating seven funds with net assets of nearly 2,210 billion VND. The scale rose 53% from 2024 and was 26 times higher than in 2021.
The asset structure remains safety-oriented: around 49.69% invested in Government bonds; 8.01% in cash and equivalents; 15.18% in fund certificates; and about 26% in receivables from interest and dividends. The Ministry said this structure aligns with the characteristics of long-term social security products that emphasize stability and sustainability.
Participant numbers have also increased steadily. By end-2025, the system had over 28,500 participants, up 17.1% year-on-year. Total contributions surpassed 720 billion VND, up 26.2%, while total payouts reached nearly 68 billion VND, more than double 2024.
The Ministry said it intends to continue refining policy to encourage participation through tax incentives, increase supervision to ensure transparency and efficiency, and study expanding the ability for individuals to participate directly in the voluntary supplementary pension system.
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