The title of this article uses an outdated word: DICA. That was the familiar shorthand for the direct investment capital account under the era of Circular No. 06/2019/TT-NHNN — a document replaced by Circular No. 38/2026/TT-NHNN with effect from 18 August 2026, and the current term is the investment capital account, internationally abbreviated ICA. The renaming is not a language matter: this account is the single gateway through which every direct investment money flow into Vietnam is recognised by the State as a lawful capital flow — contributions, transfer proceeds, profit distributions and capital withdrawals must all pass through it. Using the wrong account, even with the right money but the wrong door, does not lose the money immediately but destroys the investor’s most valuable asset: the file proving lawful capital entry, the very file the bank will demand to see at exactly the moment the investor wants to take profits home. This article distinguishes the two investment capital account types — direct and indirect — under the current frame, and explains the consequence mechanism of using the wrong one.
Two account types, two investment worlds: direct (ICA) and indirect
The investment capital account for direct investment activity — which the market used to call DICA under Circular No. 06/2019 and which now operates under Circular No. 38/2026/TT-NHNN — is the foreign-currency and Vietnamese dong payment account that foreign-invested enterprises and foreign investors participating in direct investment open at one authorised bank in Vietnam. The operating principle is the single-gateway principle: every receipt and payment relating to direct investment activity — the investor contributing capital in, receiving capital transfer proceeds, receiving dividends and distributed profits, withdrawing capital on reduction or dissolution, transferring money for related capital transactions — must be executed through this account, and the investor opens the investment capital account at only one authorised bank to ensure the continuity of the money flow file. The indirect investment capital account belongs to a different world: a foreign investor conducting indirect investment into Vietnam (trading securities and valuable papers, contributing capital or buying shares not within direct investment scope, and other indirect forms under the rules) must open an indirect investment capital account in Vietnamese dong at an authorised bank, and every receipt and payment of the indirect activity passes through that dong account, with foreign currency sold to the bank into dong before investing. The decisive boundary between the two accounts lies not in the investor’s wish but in the legal nature of the investment: direct investment is where the investor participates in management, holding a capital portion in an FDI enterprise under the Investment Law frame; indirect investment is financial investment not attached to that direct management right. An investor buying shares in an unlisted enterprise and sitting on the board is in the direct world, however much the transaction looks like buying stock.
Using the wrong account: money is not lost, but the capital file is broken
The consequence of using the wrong account is rarely immediate loss of money; it is a chain of blockages appearing at exactly the moments the investor needs money flows most. When an investor contributes capital through an ordinary payment account instead of the investment capital account, that money is not recorded, for foreign exchange administration purposes, as a lawful capital contribution of the direct investment activity: the bank has no basis to confirm the contribution history, and the enterprise cannot complete the file proving capital contributed on schedule under the investment registration certificate. At profit distribution time or when the investor sells capital or withdraws it, the bank handling the outward remittance reconciles the entire history of money in — an off-channel capital entry makes the file mismatch, and profit repatriation is blocked until the investor completes regularisation with the bank and the foreign exchange authority under the current mechanism (including converting and adjusting the account and explaining the money flow, in many cases together with the risk of administrative sanctions in the foreign exchange and monetary field). The reverse direction is equally dangerous: indirect investment money passing through a direct account, or direct investment money running through a dong indirect account, distorts each type’s reporting and supervision regime and is refused by the bank when detected. Opening and closing accounts also carry their own discipline to know in advance: the investment capital account is opened at an authorised bank (not every bank may perform this business — it must be a bank authorised for foreign exchange operations under the rules); when the investor ends the investment activity in Vietnam, having withdrawn all capital, received profits and completed related obligations, the investment capital account is closed under the bank’s procedures and foreign exchange administration rules, and the closed account’s history remains a file the investor must keep for every future proof need.
Investment capital accounts: five rules that must not be broken
- Current terminology: the investment capital account (ICA) under Circular No. 38/2026/TT-NHNN replacing Circular No. 06/2019 from 18 August 2026 — “DICA” is the old frame’s name.
- Direct investment: every receipt and payment (contributions, transfers, dividends, withdrawals) through the investment capital account at ONE authorised bank, in both foreign currency and dong accounts.
- Indirect investment: through a separate dong indirect investment capital account — foreign currency must be sold into dong before investing.
- Classification follows the investment’s nature (management participation and FDI enterprise or not), not what the transaction looks like.
- Wrong account use means the capital file is unrecorded: blocked profit distribution and withdrawals later, plus regularisation and FX sanction risk; close the account only when investment has ended and obligations are complete.
Frequently Asked Questions
Which account must investment money be transferred through?
Through an investment capital account opened at an authorised bank in Vietnam, matched to the investment type. For direct investment — the investor contributing capital into an FDI enterprise and participating in management — the account is the investment capital account for direct investment (the frame formerly under Circular No. 06/2019 that the market called DICA; from 18 August 2026 Circular No. 38/2026/TT-NHNN replaces it and the current term is the investment capital account — ICA), comprising foreign-currency and dong accounts, and every receipt and payment of the direct activity (contributions, capital transfers, dividends and profits received, capital withdrawals) must pass through them. For indirect investment (buying securities and valuable papers, financial investment outside direct scope), the investor must open a separate dong indirect investment capital account and every indirect transaction passes through that account.
Using the wrong account — can profits still be repatriated?
Usually not, until the file is sorted out. The bank remits profits and capital abroad only when it can reconcile the entire investment money flow history through the correct investment capital account under the rules: a capital contribution that once travelled through a wrong-type account or an ordinary payment account will mismatch the file, and the outward remittance is held while the investor performs explanation, account conversion and regularisation under the current foreign exchange administration mechanism — not to mention the risk of administrative sanctions for foreign exchange violations. This is why a wrong-account mistake, even one caused by a bank employee or an inexperienced accountant years earlier, is always classed by buyers in M&A transactions as a defect to be fixed before the deal: it does not lose the money, but it locks the ability to take money out.
Can the investment capital account be opened at any bank?
No. The investment capital account must be opened at an authorised bank — that is, a commercial bank permitted by the State Bank to perform foreign exchange transactions relating to investment activity under current rules — and under the current administration principle the investor opens the investment capital account for direct investment activity at a single authorised bank for each corresponding account relationship, so the entire capital flow history sits in one continuous file. Choosing the bank is therefore not only about good fees: it must be a bank with investment capital account operations and experience handling FDI files, because that very bank will be the one confirming every capital flow for profit distributions, transfers and withdrawals throughout the project’s life.
How is the capital account closed when withdrawing investment?
The investment capital account is closed when the corresponding investment activity has ended: the investor has completed withdrawing all capital or transferring the entire capital portion, received all distributed profits, and completed related obligations (including the tax obligations of the divestment transaction) — with all those final money flows also passing through the investment capital account itself before closing, so the capital flow file closes neatly from entry day to exit day. The closing procedure is performed at the bank where the account was opened under current foreign exchange administration rules (Circular No. 38/2026/TT-NHNN) and the bank’s process. The investor should keep all statements and confirmations of the closed account: they are the historical proof of lawful contribution and withdrawal that banks, tax authorities or buyers in future transactions may demand at any time.
This article has been quality-reviewed by the FLAW AI Legal Council