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Table 4. Key financial indicators by bank cluster, 2024
Enterprise- Small/
Indicator State-owned Retail- oriented
oriented medium
~0.8–
ROA (%) ~1.2–1.5 ~1.8–2.5 ~1.5–2.0
1.2

ROE (%) ~15–18 ~18–26 ~16–22 ~10–15

CIR (%) ~40–45 ~30–38 ~35–42 ~45–55
Digital transaction >90 >90–95 >90–93 ~70–85
share (%)

Non-performing loan ~1.5–2.0 ~1.0–1.8 ~1.2–2.0 ~1.5–
ratio (%) 2.5

Note: CIR = cost-to-income ratio. Source: Author’s compilation from audited annual
reports (2024); Techcombank; FiinGroup.
The enterprise-oriented cluster outperforms on all financial indicators.
Techcombank sustains a high current account and savings account (CASA) ratio and digital
customer growth through consistent technology investment, confirming the direct link
between IT expenditure and business performance . ACB - the flagship of the retail cluster
- developed the ACB One application with full eKYC, QR payment, savings, and online
lending capabilities, achieving a high digital transaction share (SBV, 2024b). By contrast,
small and medium-sized banks record the highest CIR (45–55%) and lowest digital
transaction share (70–85%), reflecting technology resource constraints and limited
innovation capacity.
Alternative explanations should be considered. Performance differences across
clusters may also reflect variations in bank size, capital structure, risk appetite, and
market positioning rather than digital investment alone. Therefore, the observed patterns
should be interpreted as indicative correlations rather than causal relationships.
3.5. Regulatory framework: institutional catalyst for digital economic
transformation
A defining characteristic of Vietnam’s banking digitalisation is the proactive and
consistent regulatory framework from national to sectoral level. The National Digital
Transformation Programme (Prime Minister’s Decision No. 749/QD-TTg, 2020) designated
finance and banking as one of eight priority sectors. The Banking Sector Digital
Transformation Plan (SBV Decision No. 810/QD-NHNN, 2021) set 2025 targets: at least
70% of banking operations fully executable on digital channels, and 80% of adults holding
payment accounts.
Table 5. Key regulatory and policy milestones in Vietnam's banking digitalisation
Year Regulatory instrument / Policy Key impact

Decree No. 35/2007/ND-CP on electronic Legal foundation for digital banking
2007
transactions in banking operations
Decision No. 986/QD-TTg: Banking sector Digital transformation designated as
2018
development strategy to 2025/2030 strategic pillar for the sector
Decision No. 749/QD-TTg: National Digital Banking designated as one of eight
2020
Transformation Programme to 2025/2030 national digitalisation priority

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