Fund management companies and venture capital funds are the member group the International Financial Centre hopes to attract earliest, because they bring both capital and deal networks. Resolution 222/2025/QH15 opens IFC membership registration to this group, but the dossier and approval process remain at principle level: this article identifies which parts an enterprise can prepare right away and which parts must await the criteria the IFC governing authority will publish.
IFC membership of a fund manager is not a new fund management licence
The first distinction to draw: IFC membership registration is not a new fund management licence, and it does not replace the fund management company establishment and operation licence issued by the State Securities Commission under the Law on Securities 54/2019/QH14. The two layers run in parallel. The current licensing layer decides whether the enterprise may manage funds at all; the IFC membership layer decides whether it may operate within the centre’s perimeter and access the centre’s special regimes.
For venture capital funds the layering is even clearer. A fund formed under the current securities and investment framework keeps that legal status unchanged; the fund, or its manager, registering IFC membership adds an operating layer, including access to investors inside the centre, a more flexible foreign exchange regime for cross-border capital flows and a testing environment for new investment products. Confusing the two layers is the error that makes many dossiers structurally wrong from the start.
The registration dossier: document groups an enterprise can complete today
Although official forms have not been issued, the dossier structure can be predicted with confidence in four groups. Group one is legal entity documents: the valid fund management licence, charter, ownership structure and list of fund executives. Group two is professional capability: management team profiles, fund management practising certificates of key personnel and the track record of funds under management. Group three is control systems: risk governance rules, segregation of fund assets from the manager’s own assets, and portfolio valuation mechanisms. Group four is the IFC activity plan: the types of funds to be brought into the centre, target investor groups and expected capital flows through the centre.
On process, Resolution 222/2025/QH15 places membership approval with the IFC governing authority in Ho Chi Minh City or Da Nang, depending on the registration location. A sensible sequence for the enterprise to organise itself is expression and registration filing, legal dossier appraisal, the membership recognition decision, and post-recognition maintenance duties. This article states no specific approval deadline for each step, because as at 21 October 2026 no document has published one; any timeline commitment in market advisory materials is currently without legal basis.
What a venture fund gains inside the IFC, and the maintenance duties that come with it
A venture fund’s advantage inside the IFC lies in the environment, not in a separate standalone tax preference. A fund operating through an IFC member sits in an ecosystem with a more open foreign exchange regime for cross-border contributions and exits, the ability to test new fund structures within the controlled testing mechanism, and the centre’s tax incentive frame applied by project type as oriented by Resolution 222/2025/QH15. Specific rates and exemption or reduction periods must be checked against the project dossier at registration and should not be quoted generically for every fund.
In return, an IFC member must maintain its conditions continuously: keep the management team at the standard declared in the dossier, report periodically on assets under management and fundraising activity in the centre, notify changes in ownership and executives, and comply with anti-money laundering duties for investor capital. Loss of maintenance conditions is a ground for the governing authority to review membership, so these duties belong in the internal compliance calendar from the recognition date.
Frequently Asked Questions
What dossier do fund managers and venture capital funds need to register IFC membership?
The dossier should be prepared in four groups: legal entity documents and the valid fund management licence under the Law on Securities 54/2019/QH14; management team capability including practising certificates of key personnel; risk governance and fund asset segregation systems; and the IFC activity plan. Official forms had not been issued as at 21 October 2026, so this is a preparation structure under the principles of Resolution 222/2025/QH15, to be rechecked when the IFC governing authority publishes its dossier forms.
What steps and timelines does the IFC membership approval process include?
At framework level the process comprises registration with the IFC governing authority in the host city, appraisal of the legal and capability dossier, the membership recognition decision, and the post-recognition maintenance stage. On timelines, no document had published an approval period as at 21 October 2026, so this article fixes no deadline; enterprises should plan on being ready to supplement the dossier rather than relying on an unissued date.
What regime does a venture capital fund in the IFC enjoy that an ordinary fund does not?
The difference lies in the operating environment: cross-border contribution and exit flows through the centre are designed to be more open, the fund may test product structures within the IFC controlled testing mechanism, and projects in the centre’s priority categories are considered for the tax incentive frame under Resolution 222/2025/QH15. A fund does not automatically receive its own tax rate merely for being a venture fund; incentives attach to the specific registered activity dossier at the centre.
What conditions must an IFC member maintain, and what must it report periodically?
Maintenance duties include keeping the management team at the standard declared in the dossier, periodic reporting on assets under management and activity in the centre, notification of ownership and executive changes, and anti-money laundering compliance for investor capital. The detailed content and reporting cycle await the rules of the IFC governing authority; enterprises should build an internal compliance calendar from the outset so the rules, once issued, catch nothing unprepared.
Registering IFC membership for fund managers with FLAT Law Firm
FLAT Law Firm helps fund management companies build the dossier in the correct two-layer structure: the current licensing layer under the Law on Securities 54/2019/QH14 and the membership registration layer under Resolution 222/2025/QH15. We also set up the post-recognition maintenance calendar, so IFC membership is never put at risk by a single missed reporting cycle.
This article has been quality-reviewed by the FLAW AI Legal Council