Update on Circular 50/2026/TT-NHNN on prudential limits and ratios in banking operations

• On September 30th, 2026, the SBV issued Circular 50/2026/TT-NHNN (Circular 50), which sets out prudential limits and ratios for the operations of commercial banks and foreign bank branches, replacing Circular 22/2019/TT-NHNN (Circular 22) after roughly five months of consultation on the draft (published in late April 2026). Circular 50 takes effect on December 1st, 2026; the new liquidity ratios (LCR, NSFR) and the LDR under the new methodology become mandatory no later than October 1st, 2028.
• Circular 50 replaces a wide range of key prudential limits and ratios, moving closer to Basel III standards, as already previewed in the draft, including: (1) a brand-new ratio, the leverage ratio (LEV); (2) three upgraded liquidity ratios: (i) the Liquidity Coverage Ratio (LCR), replacing the liquidity reserve ratio and the 30-day solvency ratio; (ii) the Net Stable Funding Ratio (NSFR), replacing the maximum ratio of short-term funding used for medium- and long-term lending; (iii) the loan-to-deposit ratio (LDR), which keeps its name from Circular 22 but is calculated in a fundamentally different way.
• Compared with Circular 22, Circular 50 does not “raise the LDR cap from 85% to 95%”, as commonly understood in the market: the 95% cap (Circular 50) and the 85% cap (Circular 22) apply to two ratios with different definitions and therefore cannot be compared directly. Circular 50 removes from the denominator most interbank deposits (counting only net borrowing) and bonds that do not qualify as Tier 2 capital, while also deducting corporate bond investments and non-loan credit extensions; the additions (net equity, foreign borrowing) only partly offset this. Based on our estimates from 2Q26 data, 27/27 banks meet the 85% LDR under Circular 22, but only 14/27 meet the 95% LDR under Circular 50; the LDR under Circular 50 is higher than under Circular 22 for all 27 banks in our estimates, with a median increase of +15 ppts – larger than the 10-ppt cap increase – and the average headroom to the cap narrows from 10 ppts to 1 ppt – in other words, a tightening, not a loosening.
• Compared with the draft, Circular 50 is looser on all three fronts: (i) a 95% LDR cap instead of an 85% CDR – the estimated number of compliant banks rises from 8/27 (CDR) to 14/27 (LDR under Circular 50) thanks to the higher cap, while the methodology change on its own has mixed effects (the ratio falls at 14 banks and rises at 13); the new LDR methodology may disadvantage banks reliant on non-Tier 2 bonds and net interbank lenders; (ii) the LCR roadmap is extended to 6 years with a 50% starting threshold (draft: 70%); (iii) deposit behaviour assumptions are aligned with domestic practice, reducing cash outflows in the LCR calculation.
• Binding constraints roadmap: until October 2028, the 85% LDR under Circular 22 remains the main binding constraint. From October 2028 (or earlier if a bank registers), the LDR under the new definition and the NSFR (90% in 2028, 100% from October 2030) are the two most notable structural constraints. The LCR, starting at 50%, is unlikely to be a bottleneck.
• Structural shifts in the sector to watch: (i) a push for equity-raising activities; (ii) a shift in issuance mix from ordinary bonds to Tier 2-eligible bonds/international bonds (to enlarge the LDR denominator); (iii) a reduction in net interbank lending positions; (iv) a lengthening of retail funding tenors to increase available stable funding (ASF). These adjustments are likely to raise the sector’s funding costs in 2027–2028. The list of banks registering for early adoption of the LCR/NSFR in 2027 is a catalyst to watch.

Rubber industry – Risk scenario plays out as supply deficit looks set to worsen in 2027

• ANRPC forecasts that the year of rubber supply in 2026 will be short by about 213 thousand tons, which is the fourth consecutive year of deficit. Looking to 2027, supply is likely to suffer "two shocks in a row": 1/ Rain will cause the loss of shaving days during this year's peak season; 2/ Drought will reduce yields at the beginning of next year's crop. The orchard has almost no break to recover, so the deficit is expected to stretch into the fifth year.
• Rubber selling prices react to oil price movements and supply deficits, and are expected to maintain a higher price level than the pre-war level, instead of returning to the old balance.
• Demand is not the driving force at the moment, but in the long term it is estimated to remain a slight increase during the transition from gasoline to electric vehicles. Due to the heavy payload of electric vehicles that causes tires to wear out 20% to 30% faster, periodic tire replacement pressure will keep rubber demand expected to increase slightly over the next 3 to 5 years.

Real Estate – Transit-Oriented Development anchored on urban rail expansion

• Transit-Oriented Development (TOD) is an urban planning, redevelopment and investment approach that uses rail transit nodes (metro stations) as focal points for residential density, commercial services, offices and other functions.
• Over 2026–2030, metro is the strategic infrastructure priority for Hanoi and HCMC, particularly after the National Assembly's Resolution 188/2025/QH15 approved pilot special mechanisms and policies to fast-track the development of urban rail (metro) networks in the two cities. Vietnam has laid the foundational legal framework for developing TOD land banks based on urban rail infrastructure planning; however, next steps still require more detailed implementing guidance and a pilot on a single metro line with its corresponding TOD land bank.
  

Banking sector Q3-2026 Earnings Preview: Profit Up 23% YoY on Credit Growth; Provision Costs Likely to Rise Again to Rebuild Buffers

• Aggregate 3Q26 PBT of the 11 banks under our coverage is expected to exceed VND85,000bn (+23% YoY, -7% QoQ off a high 2Q26 base); 9M26 cumulative PBT is up 26% YoY, fulfilling 73% of our full-year forecast. CTG leads in projected profit (VND14,143bn, +33% YoY), followed by VCB and VPB; HDB (+43%), CTG and BID (both +33%) lead in growth.
• Net interest income rises 23% YoY, driven mainly by volume: credit growth is expected to reach 13.0% YTD (18.6% YoY), led by the banks that took over compulsorily transferred banks, namely MBB, VPB and HDB. NIM is forecast to edge down 3bps QoQ to 3.18% (+10bps YoY), as deposit growth outpaced credit in Q3 (from the start of the quarter to September 23rd, deposits grew 3.8% versus 1.9% for credit) and funding costs continued to creep up versus Q2. However, the rise in cost of funds is partly offset by repricing effects and banks' shift toward a higher share of medium- and long-term loans in their credit books.
• Net NPL formation is expected to cool to around VND31,600bn (0.25% of loans) from VND41,100bn (0.34%) in 2Q26, partly due to seasonality. We forecast provision expenses to rise 23% YoY to VND35,800bn, exceeding net NPL formation and lifting LLR to 92% from the 2Q26 trough of 90%; the NPL ratio is expected to stay flat at 1.65%.
• Sector valuation has yet to turn attractive again despite a deep discount. The sector P/B stood at 1.42x as of September 28th, 2026, approaching the -1 STD band (1.39x) and below the 5-year average (1.63x), as the spread between ROAE and cost of equity narrowed to 1.6 ppts, the lowest since 2020. Foreign investors net sold VND9,500bn of bank stocks in Q3 (9M26 cumulative: VND37,500bn, exceeding full-year 2025). The FTSE upgrade effect proved short-lived, as the VND2,300bn of net buying by foreign investors during the week of September 14th–18th was fully unwound right after the effective date.
• We recommend selective accumulation, favoring banks with a stable, low-cost funding base, thick provision buffers and valuations at a discount to history. Our top picks are CTG and MBB (expected returns of 49% and 31%, respectively; ROAE above 22%). ACB and VCB are defensive picks given the best asset quality in the group (LLR of 114% and 253%).

NKG – Expecting stability after peak quarter

• In Q2/2026, NKG recorded net revenue and NPATMI of VND 4,150 billion (+9% YoY) and VND 104 billion (compared to a loss of VND 3 billion in the same period last year), respectively. Business results recovered positively with the gross margin expanding strongly to 10.5% thanks to improved selling prices, increased export volume, and low-cost inventory, while a sharp decline in net financial income caused the net margin to only recover to the same level as the previous year.
• We expect NKG's Q3/2026 business results to remain flat compared to the previous quarter, with projected net revenue and NPATMI of VND 4,171 billion (0% QoQ; +11% YoY) and VND 100 billion (-4% QoQ; +101% YoY), respectively. Average selling prices are expected to remain stable as input costs (coke, energy) have increased again since September, while the gross margin narrowing to 8.3% will be offset by export volume estimated at 97 thousand tons (+5% QoQ; +71% YoY) driven by the Brazilian market and financial revenue recovering from new loans.

Understanding the diagnostic lab services market – Long Chau’s expansion opportunities

According to several independent studies, the Vietnam diagnostic laboratory services market is projected to increase from USD 1.12 billion (equivalent to nearly VND 30 trillion, or around 20% of the private pharmaceutical retail market) in 2025 to USD 1.83 billion by 2031, representing a projected CAGR of 8.53% per year. Growth during the forecast period is expected to be driven by:

• From an macro perspective, the rising prevalence of chronic diseases in Vietnam – particularly diabetes, cardiovascular diseases, and cancer – is increasing demand for regular testing and long-term monitoring, while also shifting healthcare consumption toward prevention and early detection.
• From an operational perspective, two trends are reshaping the industry’s supply structure: the increasing outsourcing of lab testing services by hospitals and clinics, and the automation of processes within labs. These developments aim to improve operating efficiency and scale, while creating opportunities for specialized providers to enter and expand their market share.

In US, the laboratory testing market has widely adopted the “B2B referral” model, whereby hospitals, clinics, and healthcare facilities send specimens to external labs rather than conducting in-house. This represents a major source of revenue and testing volume for clinical laboratories. Over the past 15 years, companies in this sector have recorded gross margins of around 30–40% and net margins of 4-15% (typically above 8%), highlighting the efficiency of a centralized model once sufficient scale is achieved.

In the case of Long Chau and FRT’s investment opportunity, the rollout of sample collection points and partnerships with specialized laboratories (LabHouse & Gene Solutions, since Aug26) allow the chain to test demand and expand its portfolio before making deeper investments in centralized lab capabilities. At sufficient scale, this model could support expansion from B2C collection points to healthcare facilities and corporate clients. We see significant growth potential for Long Chau, supported by its customer reach through ~3,000 pharmacies and VCs. However, given that the business is still at an early stage of implementation, the laboratory testing segment is unlikely to make a significant contribution to financial results over the next 1-2 years.

US-CHINA SUMMIT: FROM TRADE WAR TO CHINA'S CAPITAL FINANCING MODEL

• The recent US-China summit was essentially a meeting between two growth models facing different constraints. The US faces a cost-of-capital issue; while China faces a capital-allocation issue.
• The US has strong demand and immense financial power, but the capital market is demanding higher yields while fiscal policy and inflation remain critical variables. China has massive production capacity and the ability to provide supply-side financing, but domestic demand is not growing fast enough to absorb that capacity. Both sides have leverage, but both also have limits.
• In this context, the paradox of trade war is that the more countries erect barriers to restrict Chinese goods, the more incentive China has to export capital to create demand for its own goods.

PVD - A temporary pause, with growth still ahead

• First-half 2026 results show continued growth in core operations, although one-off costs weighed on near-term profit. Revenue reached VND 6,429 billion (+63% YoY), while net profit attributable to parent-company shareholders reached VND 469 billion (+19% YoY), fulfilling 57% and 59% of the full-year targets, respectively. In Q2, revenue rose 25% YoY, but attributable net profit fell 32% YoY due to upgrade costs for PVD VIII and PVD IX and additional costs at the Song Doc project.
• Profit may remain under pressure in Q3/2026 before improving from Q4. Remaining costs for the PVD VIII and PVD IX upgrades and the Song Doc project are expected to affect margins in Q3; However, we expect these costs to have a much smaller impact from Q4, allowing earnings to better reflect the strength of core operations.
• Capacity expansion, rather than higher rig day rates, is expected to drive growth in 2026–2027. Drilling demand in Vietnam and Southeast Asia remains healthy, and most of PVD’s owned rigs have secured work. PVD IX should contribute for a full year from 2027, while PVD X is expected to begin drilling in Q2/2027. This will increase operating days and support growth in drilling and well technical services.

DCM – Q2/2026 Earnings Update and New Gas Pricing Mechanism

• Consolidated revenue in Q2/2026 reached VND 6,881 billion (+10.1% YoY), mainly driven by 60% growth in the Urea segment as both sales volume and selling prices improved (export volume surged 130%, offsetting the decline in domestic volume). Meanwhile, the trading segment rose slightly by 6%, while the NPK segment fell 35% due to a sharp decline in sales volume. The blended gross margin expanded to 30% (from 20% in the same period last year), driven by an increase in the Urea margin to 44% as selling prices rose faster than input gas costs. The NPK margin, however, edged down as DAP and potash feedstock prices increased faster than selling prices.
• Selling and administrative expenses in Q2/2026 nearly doubled, driven by higher export volumes, increased advertising spending, and larger contributions to the science and technology development fund. Financial income declined due to lower foreign-exchange gains. Nevertheless, the significant improvement in gross margin lifted NPAT-MI by 35.5% to VND 1,067 billion. For the first six months of 2026, revenue reached VND 11,998 billion (+27% YoY), while NPAT-MI reached VND 1,856 billion (+55% YoY), equivalent to 54% and 67% of our full-year forecasts, respectively.
• In the second half of 2026, revenue is expected to grow by 20% YoY, supported by higher domestic sales volume as selling prices decline sharply to an average of VND 13,100/kg from a peak of VND 17,000/kg. However, the gross margin in H2 2026 is projected to narrow from H1 2026 as selling prices gradually decline while input gas costs remain elevated amid persistently high Brent oil prices.
• On 23 September 2026, the Company approved a new gas-pricing mechanism that incorporates supply from the Nam Du – U Minh field, gradually replacing supplementary gas purchased from Petronas from 2028 onward. The specific gas-supply portion from 2028 has not yet been finalized and will depend on the timing of gas availability, the outcome of negotiations with Petronas, and movements in Brent oil prices.
• The new pricing formula will help reduce the Company’s exposure to Brent oil price volatility. In addition, the mechanism is expected to benefit the Company if Brent prices in 2028 exceed the USD 75.8/barrel threshold, compared with Petronas gas priced at 13.7% of Brent, assuming that Nam Du – U Minh gas represents the same share of the gas mix as gas currently purchased from Petronas.

HSG - Traditional segment expected to recover, with additional contributions from Hoa Sen Home

• In Q3 of the 2026 fiscal year (FY), HSG recorded net revenue and profit after tax (PAT) of the parent company of 9.993 trillion VND (+5% YoY) and 382 billion VND (+39% YoY), respectively. Business performance recovered positively with the gross margin expanding significantly to 15.3%, as the average export price improved due to an increased proportion of sales to the South American market and the company's effective utilization of low-cost inventory (despite continuing to set aside an additional 17.7 billion VND in provisions for inventory devaluation).
• Business operations are expected to recover more clearly in FY 2026-28, thanks to the traditional steel segment benefiting from domestic construction demand and the strategy of expanding into new export markets (India, Middle East, etc.). Regarding long-term drivers, the Hoa Sen Home retail model is expected to break through due to the potential for construction material consumption and the ability to expand into rural areas, maintaining a revenue and operating profit growth rate of 50-60%/year, thereby increasing their respective contribution ratios to 10% and 20% of the Company's overall business results.
  

HAX – Intensifying industry competition eroding profit margin

• In H1-2026, HAX recorded NPAT-MI of VND19 bn (vs only VND 1 bn in the same period last year), exceeding our expectation of VND 13 bn, corresponding to a slight improvement in net margin to 1.4%. The results reflected the recovery in EBIT margin of the MBZ segment to 1.1% (+188bps YoY) thanks to reduced pressure from hard-to-sell inventory and more positive consumer sentiment following the brand’s restructuring initiatives, combined with large incentive/support payments from manufacturers (MBZ VND 14 bn, MG VND 21 bn, Vinfast & others VND 87 bn). However, EBIT margins of MG and Vinfast remained significantly negative due to deep discounting policies and the high cost structure of VinFast electric vehicles, while interest expenses surged 95.7% YoY to VND 34 bn under the impact of higher average interest rates and expanded debt scale following the VFG acquisition. On a positive note, the minority interest ratio declined markedly thanks to the recovery of the fully-owned MBZ segment, improving the quality of earnings attributable to parent company shareholders.
• Following Q2-2026 results and a 14% price decline over the past three months (broadly in line with global peers), HAX is currently trading at a trailing P/B of 0.8x (half of the book value comes from the Vo Van Kiet land plot with historical cost of VND90-100mn/m²). Overall, the stock appears inexpensive relative to the company’s business outlook in H2-2026 – a period of accelerated new model launches across MBZ, MG and VinFast, accompanied by continued high manufacturer incentives. The completion of the purchase of ~1 million HAX shares by Mr. Do Tien Dung, Chairman of Haxaco, during 5 Aug – 3 Sep 2026, as well as the Board’s proposal to the AGM for a 5-million-share buyback, serve as additional catalysts that could help stem the stock’s downward momentum in the near term.

HDG – Hydrology conditions to weigh on 3Q earnings

• In 1H2026, Ha Do Group JSC posted a recovery that nonetheless fell short of our expectations, with net revenue and NPAT-MI of VND1,175bn (flat YoY) and VND301bn (+132% YoY; the reviewed figure is 86% above the company's self-prepared report). Hydropower output fell 24% YoY on the negative impact of the El Nino phase, alongside one-off provisioning charges for the renewables projects (Hong Phong 4 and Infra 01).
• With sales at Charm Villa phase 3 yet to be pushed, 3Q earnings will again be driven mainly by the energy segment and will remain exposed to weather, with the El Nino phase now at its strongest (drier conditions and a negative read-through to hydropower output). We therefore estimate 3Q revenue and NPAT-MI of VND640bn (-10% YoY) and VND210bn (-26% YoY) respectively.