Scenario: a Chinese individual investor holds USD 5 million in a Hong Kong bank account. He prints his own statement from internet banking and files it with the IRC dossier. The agency returns the dossier: “invalid document”. Why was a statement clearly showing the balance rejected — and what does a compliant balance confirmation look like?
Legal position: a statement proves capacity, not statutory capital
Point (c), Clause 1, Article 32 of Decree 96/2026/ND-CP lists “other documents proving the investor’s financial capacity” as a valid option — and a bank balance confirmation or account statement is the most common document in this group, especially for individual investors with no financial statements. A sharp distinction is needed: this proves FINANCIAL CAPACITY, not statutory capital. Current law sets no general minimum capital requirement for foreign investors establishing enterprises in Vietnam — “statutory capital” survives only in certain specialized sectors under sectoral laws. Nobody may therefore demand that an investor hold a balance equal to some statutory floor that does not exist.
What a compliant balance confirmation contains
A balance confirmation accepted in practice must contain: issuance by the bank on its letterhead; the account holder’s name — matching the investor’s name in the dossier exactly; the account number; the balance as of the confirmation date; the currency; the issuance date (close to the filing date); and the signature of an authorized person plus the bank’s seal. That is why the self-printed internet banking statement in the opening scenario was rejected: without the bank’s seal and signature, the agency has no basis for authentication. Where the confirmation is issued by a foreign credit institution, practice treats it like other foreign documents: consular legalization (or Apostille certification since 11 September 2026), then translation into Vietnamese.
How much balance is “enough”?
The law sets no fixed ratio — nothing requires the balance to equal 100% of the registered investment capital. The agency assesses whether the confirmed balance is proportionate to the project’s capital scale, within the dossier as a whole (project proposal, capital mobilization plan). Practice shows: the closer the balance to the registered capital, the smoother the dossier; where the balance is significantly lower, the investor should present a clear capital mobilization plan in the project proposal. One note for the post-establishment phase: contributed capital must flow into Vietnam through a direct investment capital account (DICA) at a licensed bank, under the State Bank’s foreign-exchange rules for foreign direct investment — today’s capacity-proving balance and tomorrow’s actual capital inflow are two different things; do not confuse them.
Frequently asked questions
Is a self-printed internet banking statement acceptable?
Usually not. Agencies in practice require a confirmation bearing the authorized person’s signature and the issuing bank’s seal. A self-printed statement lacks authentication elements and is readily judged invalid.
Must the balance equal 100% of the registered investment capital?
No such fixed ratio exists. The agency assesses proportionality between the balance and the registered scale within the whole dossier. A balance below the registered capital is not automatically disqualifying if the mobilization plan is convincing.
Can the account be in a spouse’s or relative’s name?
No. The account holder’s name must match the investor’s name in the dossier exactly. Another person’s account, even a relative’s, does not prove the investor’s own financial capacity.
Must the funds be frozen after obtaining the confirmation?
No rule requires freezing. A balance confirmation reflects the balance at the confirmation moment only; the investor remains free to use the account afterwards. Withdrawing everything right after filing is, however, inadvisable as a practical matter.
