With the repeal of Circular 04 regarding motor vehicle insurance, are vehicle owners still required to purchase mandatory insurance?
From December 15, 2026, Circular 04/2021/TT-BTC on compulsory civil liability insurance of motor vehicle owners is abolished, but the obligation to buy this type of insurance is still maintained according to the Law on Insurance Business and Decree 67/2023/ND-CP.
Many car and motorcycle owners are wondering whether the repeal of Circular 04/2021/TT-BTC signifies the end of the mandatory civil liability insurance policy for motor vehicle owners.
Mandatory civil liability insurance for motor vehicle owners remains in effect following the repeal of Circular 04/2021/TT-BTC (Illustrative image).
Pursuant to Clause 39, Article 1 of Circular 158/2026/TT-BTC issued by the Ministry of Finance, the entirety of Circular 04/2021/TT-BTC is repealed effective December 15, 2026. The latter document provided detailed regulations for the implementation of certain articles of Decree 03/2021/NĐ-CP regarding compulsory civil liability insurance for motor vehicle owners.
However, the repeal of this guidance document does not mean that the mandatory insurance policy has been terminated. The obligation for motor vehicle owners to purchase insurance remains established under existing legal provisions.
Vehicle owners are still required to purchase mandatory insurance.
Specifically, Point a, Clause 2, Article 8 of the Law on Insurance Business No. 08/2022/QH15 identifies compulsory civil liability insurance for motor vehicle owners as one of the types of compulsory insurance.
Clause 3, Article 8 of the Law stipulates that organizations and individuals subject to mandatory insurance requirements are obligated to purchase insurance from an insurance company or a branch of a foreign non-life insurance company that is authorized to provide such insurance.
This regulation serves as an important legal basis for establishing the obligation to participate in insurance. The repeal of a guiding circular does not negate the obligation already stipulated by law.
Regarding the subjects and the obligation to participate, Articles 2 and 4 of Decree 67/2023/NĐ-CP stipulate that owners of motor vehicles participating in traffic or operating within the territory of Vietnam must purchase compulsory civil liability insurance from an insurance company authorized to provide such insurance services.
Decree 67/2023/ND-CP serves as the current regulatory basis.
It should be noted that Decree 03/2021/NĐ-CP ceased to be in effect upon the entry into force of Decree 67/2023/NĐ-CP on September 6, 2023. Consequently, Circular 04/2021/TT-BTC—which was issued to provide guidance for Decree 03—no longer serves as a basis for current policy guidance.
Decree 67/2023/NĐ-CP stipulates the subjects of insurance, insurance conditions, premium rates, minimum insurance coverage amounts, and the responsibilities of relevant parties. It serves as the direct legal basis for implementing the policy of compulsory civil liability insurance for motor vehicle owners.
Consequently, as of December 15, 2026, Circular 04/2021/TT-BTC will be officially repealed; however, owners of motor vehicles falling under the specified categories are still required to purchase compulsory civil liability insurance. It is important to distinguish between the repeal of a regulatory guidance document and the termination of the insurance policy itself, so as to avoid any misunderstandings or the oversight of legal obligations when participating in traffic.
