On 18 September, SBV reported approval of Decision 1809/QĐ-TTg on banking modernisation and business access to credit. The programme includes supply-chain lending and lending based on payment data and cash flows. Its 2030 ambition includes at least 300,000 SMEs with outstanding credit at credit institutions; this is a target, not an achieved lending result.
Event / source publication date: 18 September 2026The following is Human Fintech’s analysis
Choose a cash cycle before choosing a platform.
For an international lender or technology partner assessing Vietnam, the useful starting point is a narrow customer segment with an observable funding gap. A supplier awaiting payment from a buyer needs a different repayment structure from a business collecting daily retail receipts. A broad SME label hides those differences and makes a single underwriting model difficult to validate.
Market-entry planning should establish which local institution originates the loan, which party services it and how exceptions reach a decision-maker. The policy announcement does not itself grant a foreign entrant permission to lend or access customer information. Local legal assessment remains a separate workstream. Product development should follow a credible operating arrangement rather than assume that a national ambition removes these dependencies.
Build an evidence trail from receipts to repayment capacity.
Transaction records need interpretation before they can support a credit decision. Internal transfers, borrowing proceeds and customer advances can all increase an account balance without representing sustainable earnings. The proposed product should specify how these items are identified, how missing information is treated and when the application needs manual review. A score that conceals uncertainty is harder to monitor than a smaller set of explicit assumptions.
Continuity matters as much as initial access. Data collected once at application may not support monitoring throughout the loan. Teams should establish who maintains permission, validates incoming records and handles interrupted feeds. The cost of those tasks belongs in unit economics alongside funding and expected losses. A fast application journey can still produce an expensive servicing model.
Make the pilot answer an investment question.
A useful pilot can test whether repayment dates fit the borrower’s observed cash cycle and whether a delayed major customer payment is detected early enough for intervention. Agree the response before launch: customer contact, a review of unused availability or referral for an individual credit decision. These are proposed operating choices, not requirements asserted by the announcement.
Scale decisions should rely on comparable cohorts, collected payments and actual servicing effort. The national target is not a sales forecast for an individual lender. For investors and partners, the relevant question is whether a specific institution can obtain reliable evidence, convert it into appropriate credit terms and maintain that process as volumes increase. That is a more useful basis for investment than the size of the policy ambition alone.
White Fintech.
Parts II–III of White Fintech cover lending economics, funding and risk management: a foundation for further reading about the lending business.
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