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effect of digital investment intensity on financial outcomes. Second, the 2020–2022
COVID-19 period may have independently accelerated digital adoption across all clusters,
potentially compressing pre-existing inter-cluster differences. The pandemic years
represent a confounding structural break in investment behaviour, and any cross-cluster
comparisons spanning 2018–2024 should account for this discontinuity when interpreting
longitudinal trends. Third, the reliance on disclosed IT expenditure figures, while the most
systematic data available, may understate actual digital investment for banks that
capitalise technology assets rather than expensing them. These limitations
notwithstanding, the descriptive patterns documented across 189 bank-year observations
over a seven-year horizon are sufficiently robust to support the policy conclusions drawn.
Drawing on these findings, the paper proposes five policy recommendations. First,
the SBV should establish digital maturity standards and mandatory reporting
requirements on IT expenditure ratios, targeting the 15–20% operating cost threshold and
adopting a three-objective “digital portfolio” mechanism distinguishing maintenance,
scale-up, and innovation spending, following international best practice from DBS and
BBVA (Gomber et al., 2017; World Bank, 2022). Second, digital skills investment should be
accelerated under SBV Decision No. 2069/QD-NHNN (2024), with the aim of closing the
gap between the current IT staffing ratio (2.4–3%) and the ASEAN benchmark (4–6%).
Third, the fintech sandbox (Decree No. 94/2025/ND-CP) should be operationalised
effectively with simplified approval processes and an expanded scope covering BNPL,
open banking, and digital credit products. Fourth, state-owned banks require targeted
digital transformation acceleration programmes with specific performance milestones to
overcome institutional inertia and legacy system constraints. Fifth, investment in Mobile
Money and rural connectivity should be treated as a national digital financial inclusion
policy, not a purely commercial calculation.
Implemented in concert, these recommendations can position Vietnam’s banking
sector as the leading engine of digital economic transformation - not only within the
financial sector itself but as a foundational platform for inclusive national economic
development in the AI era and digital economy.

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