Why Don’t Vietcombank and Techcombank Produce Their Own Gold Bars? The Case for Outsourcing Production

The State Bank of Vietnam recently released a compilation and explanation of feedback from businesses and commercial banks regarding the draft Circular guiding Decree 24/2012/NĐ-CP, amended and supplemented by Decree 232/2025/NĐ-CP, on gold market management.

Among the feedback, several banks proposed allowing them to outsource the production of gold bars to domestic and foreign manufacturers before meeting the requirements for self-production.

Specifically, Vietcombank and Techcombank urged the State Bank to clarify that the production of gold bars by businesses and commercial banks may include outsourcing to domestic or foreign manufacturers, similar to the previous mechanism where the State Bank assigned SJC to produce gold bars.

Both banks argued that Decree 232 has eliminated the state monopoly on gold bar production, necessitating a similar legal framework for commercial banks to outsource production.

“Producing gold bars is a new mechanism for eligible commercial banks, requiring significant time to develop business plans, infrastructure, human resources, and production lines. During the transition to self-production, establishing a legal framework allowing banks to outsource to qualified manufacturers will alleviate pressure on banks,” stated Techcombank and Vietcombank.

Conversely, when outsourcing to foreign manufacturers, domestic businesses and banks cannot directly oversee production. Banks requested the State Bank to provide additional guidelines on monitoring and ensuring product quality when outsourcing abroad.

In response, the State Bank noted that outsourcing gold bar production domestically and abroad is already regulated under the 2005 Commercial Law and the Foreign Trade Management Law. Domestic outsourcing is governed by Articles 178, 181, and 181 of the 2005 Commercial Law, while foreign outsourcing follows Article 52, Clause 1, of the Foreign Trade Management Law.

Additionally, Clause 2, Article 49, of Decree No. 69/2018/NĐ-CP outlines the rights and obligations of traders outsourcing production abroad, including responsibility for trademark use and product origin labeling.

“Decree 232 clearly defines the responsibilities of businesses and commercial banks authorized to produce gold bars, holding them fully accountable for the gold bars they produce or outsource. They must also publish applicable standards, quantities, and gold content of their produced and outsourced gold bars,” the State Bank clarified.