Context: Closing a quiet transaction office in a district and replacing it with a digital point sounds simple technologically, but legally it touches the bank’s network licence, the rights of customers holding savings books there, and the labour plan for surplus staff at once.
Legal Basis and How It Applies
A credit institution’s operating network is managed by the State Bank under the Law on Credit Institutions 32/2024/QH15: establishing, relocating or terminating branches and transaction offices must meet conditions and approval or notification procedures set by the State Bank, together with a duty to notify affected customers so they can move service points or continue via digital channels. A ‘digital branch’ or automated transaction point is not an independent legal form exempt from network conditions: a staffed point handling cash is still a network transaction point; only purely electronic channels (apps, internet banking) fall outside the physical-point concept.
The labour side is usually underestimated compared with licensing. Where digitalisation changes structure or technology, or economic reasons make many employees redundant, the Labour Code 45/2019/QH14 obliges the employer to build a labour-utilisation plan, consult the employee representative organisation, and dismiss only after retraining or redeployment proves impossible. Severance allowances and notice periods are mandatory costs that belong in the digital-transformation budget — a bank skipping this step may win on technology but lose a wave of labour lawsuits.
Application in Practice and Common Pitfalls
The safe working order for a digital-branch project is: settle the network plan with the State Bank first, notify customers early with a transfer plan, and run the labour-utilisation plan for staff at the closing point in parallel. Doing it in reverse — press-releasing a ‘fully digital bank’ before the network file is approved — is the classic legal-communications error of rushed transformations.
Action Checklist
The steps below turn the analysis above into concrete work:
- First, test your own situation against this ground: A credit institution’s operating network is managed by the State Bank under the Law on Credit Institutions 32/2024/QH15: establishing, relocating or terminating branches and transaction offices must meet conditions and approval or notification procedures set by the State Bank, together with a duty to notify affected customers so they can move service points or continue via digital channels.
- Record the application point specific to this case instead of copying conclusions from another case: The labour side is usually underestimated compared with licensing.
- Prepare the evidence and file relating to the following point before dealing with authorities or partners: The safe working order for a digital-branch project is: settle the network plan with the State Bank first, notify customers early with a transfer plan, and run the labour-utilisation plan for staff at the closing point in parallel. Doing it in reverse — press-releasing a ‘fully digital bank’ before the network file is approved — is the classic legal-communications error of rushed transformations.
- Answer the question clients ask most directly with this conclusion, and keep it on file: The bank must complete the procedures for changing or terminating a network transaction point under State Bank rules based on the Law on Credit Institutions 32/2024/QH15, notify customers of the closing point, and ensure substitute service via another point or digital channels.
Frequently Asked Questions
What procedure must a bank follow to close a physical branch and go digital?
The bank must complete the procedures for changing or terminating a network transaction point under State Bank rules based on the Law on Credit Institutions 32/2024/QH15, notify customers of the closing point, and ensure substitute service via another point or digital channels.
How are bank staff laid off due to digitalisation compensated?
Staff made redundant by structural or technological change are protected by the labour-utilisation plan under the Labour Code 45/2019/QH14: retraining or redeployment comes first, the employee representative organisation must be consulted, and dismissals require job-loss allowance and statutory notice.
Does opening a digital transaction point require State Bank approval?
A staffed point handling cash remains part of the operating network and must meet the State Bank’s conditions and procedures. Only purely electronic channels such as apps and internet banking are not physical transaction points; labelling a staffed point ‘digital’ does not exempt it from network conditions.
This article has been quality-reviewed by the FLAW AI Legal Council