On June 27, 2025, the National Assembly of Vietnam officially adopted Resolution No. 222/2025/QH15 on International Financial Centers in Vietnam (Resolution 222), establishing the first legal foundation for the development and operation of international financial centers in Vietnam. At the same time, Resolution 222 laid the groundwork for specialized dispute resolution mechanisms applicable within these centers. This article provides an overview of the dispute resolution framework at International Financial Centers (IFCs) in Vietnam as stipulated under Resolution 222.
First, pursuant to Clause 1, Article 3 of Resolution 222, an International Financial Center is defined as a geographically delineated area established by the Government in Ho Chi Minh City and Da Nang, concentrating a diverse ecosystem of financial and supporting services, and operating under the specific mechanisms and policies prescribed in this Resolution. Accordingly, the establishment of an IFC represents the formation of a zone with a distinct and preferential legal and policy framework aimed at attracting investors providing financial products and services, as well as related non-financial services connected with international financial centers.5 However, a critical component of establishing an IFC is the development of an effective dispute resolution mechanism capable of meeting practical demands.6 Therefore, Resolution 222 sets out a comprehensive legal framework governing dispute resolution within IFCs in Vietnam.
In particular, in addition to dispute resolution mechanisms provided under Vietnamese law, Article 30 of Resolution 222 stipulates that disputes between Members, or between Members and investors outside IFCs, arising from investment and business activities conducted within IFCs, may be resolved by one of the following bodies or institutions:
(i) Foreign arbitration;
(ii) International arbitration;
(iii) The International Arbitration Center established under IFCs;
(iv) Vietnamese arbitration;
(v) Foreign courts;
(vi) Vietnamese courts.
Accordingly, one of the notable features of Resolution 222 is the establishment of an independent International Arbitration Center under IFCs to provide arbitration and commercial mediation services for parties involved in investment and business activities within IFCs, in accordance with the rules and regulations promulgated by such center. Currently, the Government is in the process of finalizing a Decree governing the International Arbitration Center under IFCs in Vietnam, as well as the applicable law and dispute resolution mechanisms within IFCs, in order to operationalize this form of dispute resolution.
In addition, Resolution 222 represents a significant breakthrough in dispute resolution regulation by permitting disputing parties to agree to waive their right to request the court to set aside a decision recognizing a successful mediation or a legally effective arbitral award rendered by the Arbitral Tribunal of the International Arbitration Center under IFCs. Accordingly, the court shall not entertain any application for setting aside such arbitral awards or decisions where the parties have entered into a written agreement waiving this right. This constitutes a fundamental departure from Vietnam’s Law on Commercial Arbitration 2010 and the practice of many jurisdictions adopting the UNCITRAL Model Law, which do not allow parties to completely waive their right to seek annulment of an arbitral award before the courts at the seat of arbitration.7
In addition to the International Arbitration Center established under IFCs in Vietnam, one of the notable dispute resolution mechanisms introduced by Resolution 222 is the establishment of a specialized court under IFCs to adjudicate and resolve cases arising within IFCs. At present, this specialized court-based dispute resolution mechanism has been concretized in the Law on Specialized Courts under the International Financial Center, adopted by the National Assembly on December 11, 2025, and effective as of January 1, 2026.
Overall, in order to adapt to the increasingly deepened process of globalization, the establishment of IFCs in Vietnam represents a strategic step toward integrating Vietnam into the global financial market, attracting foreign capital, and enhancing the country’s economic standing.8 Accordingly, the development of a clear and predictable legal framework for dispute resolution within IFCs has played a crucial role in creating momentum for the sustainable development of IFCs in Vietnam.
(5) Hai Lien (2025), International Financial Center in Vietnam: Modern financial ecosystem, global competitiveness, and breakthrough institutions, Vietnam Government Portal, https://baochinhphu.vn/trung-tam-tai-chinh-quoc-te-tai-viet-nam-he-sinh-thai-tai-chinh-hien-dai-canh-tranh-toan-cau-the-che-dot-pha-102250611104457767.htm.
(6) Vu Kim Hanh Dung & Tran Quoc Dat (2025), Dispute resolution at International Financial Centers, Saigon Economic Magazine Online, https://thesaigontimes.vn/giai-quyet-tranh-chap-tai-trung-tam-tai-chinh-quoc-te/.
(7) Bui Ai Gion (2025), Specialized courts in International Financial Centers in Vietnam: Roles, challenges, and organizational models, People’s Court Journal, No. 18/2025, https://tapchitoaan.vn/toa-an-chuyen-biet-tai-trung-tam-tai-chinh-quoc-te-tai-viet-nam-vai-tro-thach-thuc-va-mo-hinh-to-chuc14174.html.
(8) Vu Kim Hanh Dung & Tran Quoc Dat (2025), ibid.
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