The MOF will begin its full audits under Circular 67/2023/TT‑BTC from Q4 2025. Penalties for cap breaches can reach ₫6 billion (approximately US $250,000) and may include a temporary halt on new policy sales. Our quick-scan checklist helps Vietnamese insurers confirm their capabilities to enforce the new product‑wise and aggregate caps across every channel before the audit window opens. Tick each item that is fully in place to measure your organization’s readiness on this front.
1. Product‑wise Cap Configuration (5 points)
| ✔ / ✘ | Item |
| 1.1 All product categories mapped to the correct first‑year and renewal caps (term, whole‑life, ULIP, riders, P&C). | |
| 1.2 Caps enforced uniformly across agency, bancassurance, digital, and brokers. | |
| 1.3 Rate tables updated in every quotation, policy‑issue, and payout system. | |
| 1.4 Exception workflow in place for legacy products during transition. | |
| 1.5 Unit tests confirm zero cap breaches in the last 3 months. |
2. Aggregate Compensation Controls (4 points)
| ✔ / ✘ | Item |
| 2.1 Total payout ceiling (commissions + bonuses + contests + non‑cash rewards) configured in core system. | |
| 2.2 Real‑time dashboard shows each agent’s cumulative earnings vs. cap. | |
| 2.3 Hard‑stop alert triggers when 90% of ceiling is reached. | |
| 2.4 Clawback routines recover overpayments automatically. |
3. Disclosure and Audit Readiness (3 points)
| ✔ / ✘ | Item |
| 3.1 Commission tables disclosed in all product brochures and digital journeys. | |
| 3.2 MOF approval letters for current incentive schemes archived and traceable. | |
| 3.3 Immutable audit trail captures rule changes, payout calculations, and approvals. |
4. System Capability and Analytics (3 points)
| ✔ / ✘ | Item |
| 4.1 Rule engine validates caps in <1 second at quote, issue, and payout. | |
| 4.2 Scenario “sandbox” models new compensation schemes before launch. | |
| 4.3 KPIs track agent quality (persistency, lapse ratio, etc) alongside sales volume. |
Your Score
Add one point for every box ticked.
| 15 – 13 points | Audit‑ready. Maintain quarterly reviews to stay ahead. |
| 12 – 9 points | Needs optimization. Address gaps within 90 days. |
| ≤ 8 points | At risk. Immediate remediation and system upgrade required. |
Tip: Accounts scoring below 10 points typically see payback from SymbioSys DMS in under nine months.
Next steps
- Share results with your compliance and distribution leads.
- Book a 30‑minute briefing to benchmark against peers and see SymbioSys DMS in action.
- Start a 30‑day pilot on one flagship product—risk‑free and data‑driven.