Abstract
This study analyzes the impact of internal auditing on model risk management in Vietnamese commercial banks in the context of digital transformation. It systematizes the theoretical foundations of internal auditing and model risk management in commercial banking, clarifies the localization of international standards such as SR 11-7 and Basel III through Circular No. 83/2025/TT-NHNN, and examines the current state of implementation as well as institutional gaps in Vietnam. Employing a qualitative approach that combines systematic document synthesis with comparative analysis against international standards, the study highlights the need to restructure internal auditing by integrating banking operations with data science, shifting toward a continuous auditing model, and strengthening the independent supervisory role of internal auditing in safeguarding digital trust in the era of digital banking.