Notable amendments to the Law on Insurance Business

The Law on Insurance Business 2022 (Law on Insurance Business), which was adopted on 16 June 2022 and came into effect on 01 January 2023, provides a clear legal framework for insurance business in Vietnam, promoting a healthy and competitive environment. On 10 December 2025, the National Assembly promulgated Law No. 139/2025/QH15, amending and supplementing a number of provisions of the Law on Insurance Business (Amendment Law), with the purpose of further perfecting the legal framework for insurance business activities. The Amendment Law came into effect on 01 January 2026. In this legal update, we will highlight notable provisions of the Amendment Law.

1. Operating principles of insurance agents

While the Law on Insurance Business generally provides that an individual insurance agent may not act for multiple insurance enterprises or foreign non-life insurance branches operating within the same business lines or sectors, the Amendment Law further clarifies that an individual insurance agent may represent only one insurer within the same insurance line (life insurance, non-life insurance, or health insurance).

2. Insurance auxiliary services

The Amendment Law abolishes conditions for providing insurance auxiliary services, which will take effect from 01 July 2026. Accordingly, from 01 July 2026, insurance auxiliary services will no longer be classified as a conditional business line. This represents a significant step under the Amendment Law aimed at eliminating unnecessary business conditions and reducing regulatory barriers and aligns with the objectives of Law No. 143/2025/QH15 entitled the Law on Investment, passed by the National Assembly on 11 December 2025 and taking effect on 01 March 2026.

3. Insurance brokerage services

The Law on Insurance Business contained no provisions regulating the investment activities of insurance brokerage enterprises. As a result, certain investment activities posed potential risks with respect to the management and use of equity capital of insurance brokerage enterprises, which could negatively affect their financial stability. To address this gap, the Amendment Law introduces provisions to ensure that the investment activities of insurance brokerage enterprises are conducted safely and effectively. Specifically, the Amendment Law provides that investments by insurance brokerage enterprises must ensure the principles of safety, solvency, and efficiency, compliance with the law, and sole responsibility for the investments. Insurance brokerage enterprises are prohibited from investing, in any form, in their shareholders, capital-contributing members, or related persons of such shareholders or capital-contributing members as defined under the Law on Enterprises, except for deposits made with shareholders or capital-contributing members who are credit institutions.

4. Principles for holding concurrent position  

The Law on Insurance Business does not allow an Actuary and a Chief Accountant in an insurance enterpriseto hold any other position within the same organisation. Notwithstanding, the Amendment Law has amended these provisions to allow the aforementioned positions to hold additional managerial roles. In particular:

(i) an Actuary may concurrently hold the position of Head of Insurance Pricing; and

(ii) a Chief Accountant may concurrently hold the position of Head of Finance and Accounting.

5. Implementation timeline

Under the Law on Insurance Business, the provisions on solvency and intervention measures are set to take effect on 01 January 2028. The Amendment Law, however, extends the effective date of these provisions to 01 January 2031, covering the following matters: (i) financial security; (ii) solvency; (iii) remedial measures; (iv) early interventions; (v) control measures; (vi) responsibilities of insurance enterprises, reinsurance enterprises, and foreign branches in Vietnam while subject to remedial measures, early intervention, and control measures; and (vii) bankruptcy of insurance enterprises and reinsurance enterprises. Accordingly, the corresponding provisions under the Law on Insurance Business 2000, which would have expired on 31 December 2027, are effectively extended until 31 December 2030.

In addition, from 01 January 2028 to 31 December 2030, insurance enterprises, reinsurance enterprises, and foreign branches operating in Vietnam are required to monitor and manage capital, calculate capital adequacy ratios, and develop capital increase plans and roadmaps in accordance with regulations issued by the Minister of Finance.

Click here to download: Legal Update (EN) - Notable amendments to the Law on Insurance Business 

We also would like to refer you to our recently published first edition of Vietnam’s Insurance Sector Legal & Investment Guide. Click here to request a copy.

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The summary is not intended to be nor should it be relied on as a substitute for legal or other professional advice.

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