Regarding the proposed regulation requiring bullion producers to hold a charter capital of at least VND 1,000 billion (approximately USD 39.2 million), the Vietnam Gold Traders Association (VGTA) argues that the condition is excessively stringent.

Proposal: Lower capital requirement to VND 500 billion

According to VGTA, the activity of gold bullion trading is an intermediary stage between producers and consumers, facilitating the smooth distribution of goods from manufacturers to buyers. Like any other commodity, bullion traders should only be required to register their business in accordance with the Law on Investment and the Law on Enterprises.

“The requirement for State Bank of Vietnam (SBV) approval is unnecessary. It creates additional licensing barriers and represents rigid intervention in the market. This adversely affects business freedom and market fluidity,” the Association stated.

They also pointed out that this would result in dual licensing for bullion producers – one for production and another for trading – further complicating the process and limiting operational efficiency.

The VGTA criticized the requirement that bullion producers must have a charter capital of at least VND 1,000 billion. They noted that very few companies meet this threshold - likely only one to three gold businesses nationwide. Such a regulation effectively preserves the state monopoly over bullion production and restricts supply.

Therefore, the Association suggests the SBV examine the actual initial investment capital of SJC, Vietnam’s largest state-owned gold producer, to develop a more realistic capital requirement for new entrants.

“A more suitable capital requirement for gold bullion producers is VND 500 billion (approx. USD 19.6 million),” the Association proposed.

In addition to capital, the VGTA emphasized that other key criteria should include the producer’s capacity (assets, infrastructure, and technology for bullion production), business performance, market reputation, branding, quality of product design and finish, and compliance with government regulations in the gold trading sector.

Recommendation: Remove one-time licensing for each gold import/export batch

The VGTA also proposed eliminating the regulation requiring separate licenses for each batch of gold bullion or raw gold exported or imported. They argue that this increases administrative burdens and licensing barriers, restricts gold exports, and prevents the recycling of foreign currency earnings.

Due to the highly volatile global gold market, delays caused by licensing could cause businesses to miss favorable trading opportunities, affecting both production and export efficiency.

Instead, the Association recommends that the SBV grant annual import-export quotas for gold bullion and raw materials. These quotas should be allocated transparently to each business at the beginning of the year, with no additional licensing required.

Within the approved quota, businesses should have full autonomy in determining the timing and volume of transactions to maximize efficiency. Companies would be required to submit periodic reports on their import-export activity. Any adjustments to quotas would remain at the SBV’s discretion.

Nguyen Le