Policy and Regulatory Analysis of the Payments Industry in Vietnam

The policy and regulatory environment of Vietnam's payments industry has undergone rapid changes in recent years to adapt to the booming digital economy and the innovative needs of fintech. The following analyses the policy framework, regulators, key regulations, market dynamics and challenges:

I. Policy and regulatory framework

  1. Core legal basis

    • Non-Cash Payments Act (entered into force in 2017): The cornerstone of Vietnam's payment system, clarifying the legality of electronic payments and regulating payment services (e.g., e-wallets, mobile payments) by banks and non-banking organisations.
    • National Bank Act (amended in 2010): Give the State Bank of Vietnam (SBV) full supervisory authority over the payment system.
    • Decree No. 101/2022/ND-CP(Effective 2023): Refinement of cross-border payment rules to require foreign firms to operate through local partnerships or set up entities.

  2. Key regulatory areas

    • Licence Management: Non-banking institutions are required to apply for an "Intermediate Payment Service Provider" licence issued by the SBV (five categories, e.g., e-wallet, money transfer aggregator, etc.).
    • Anti-Money Laundering (AML): Follows the Anti-Money Laundering Act (amended in 2022), which requires payment platforms to implement KYC and transaction monitoring.
    • Data localisation: User data shall be stored in Vietnam and cross-border transmission shall be subject to SBV approval.

II. Main regulatory authorities

  1. State Bank of Vietnam (SBV)*
    Lead policy development and day-to-day supervision, responsible for approving licences and monitoring compliance.
  2. Other departments, such as the Ministry of Finance, collaborate in the management of taxation and cross-border capital flows.

III. Market status and development trends

  • rapid growth:
    The market size is expected to reach USD 50 billion by 2025, with local platforms such as MoMo (with a market share of more than 50%) dominating the market, followed by ZaloPay and others.
  • Foreign Capital Restrictions:
    Foreign ownership is capped at 30% and requires technology transfer to the Vietnamese partner; however, co-operation models are encouraged (e.g. Grab's co-operation with Moca).

IV. Challenges

  1. Regulatory lag:
    Existing frameworks struggle to cover emerging areas such as cryptocurrencies.
  2. Inadequate rural coverage:
    Cash still accounts for more than 80% of township transactions; the
  3. International compliance pressures:
    Enforcement still needs to be strengthened to meet FATF standards.

V. Future prospects

More open pilot policies may be introduced to attract investment, while enhanced consumer protection provisions may be introduced to balance the risks of innovation. Enterprises should pay close attention to the upcoming revision of the E-Commerce Law, which will further regulate online payments.

Further targeted analyses can be provided if a specific area of depth is required (e.g. e-wallet licensing process or cross-border business case).

VI. Regulatory details of e-wallets and payment licences

Regulation of non-bank payment services such as e-wallets in Vietnam is becoming increasingly stringent, focusing mainly on access licensing, operational norms and risk management. Here are the key details:

1. Types of licences and conditions of application

According to the SBV, payment services are divided into five categories and companies need to apply for the appropriate licences according to their business scope:

  • Category 01: E-wallet issuance (e.g. MoMo, ZaloPay)
  • Class 02: Electronic payment gateways (e.g. VNPAY)
  • Category 03: Clearing and settlement services
  • Category 04: Prepaid card issuance
  • Category 05: Cross-border remittance agents

Application RequirementsIncluded:
✅ Minimum registered capital of VND 20 billion (about US$850,000);
✅ Locally incorporated entity with foreign ownership ≤ 30%;
✅ Technical system certified for SBV safety;
✅ Submission of AML/CFT internal control programmes.

2. KYC and transaction limits

To balance convenience and risk control, SBV implements a tiered KYC system:
| Account Level | Authentication requirements | single-stroke limit | Monthly Cumulative Limit |
|————–|—————————–|——————|——————|
| Level 1 | Mobile No. + Basic Information | ≤ VND 5 million | ≤ VND 20 million |
| Level 2 | +ID/Passport | ≤VND20 million | ≤VND100 million |
| Level 3 | + Face Recognition or Bank Account Binding | ≥ VND20 million No limit |

be an exception:: Partial scenario exemption limits (e.g., utility contributions).

VII. Regulatory barriers and modes of co-operation in cross-border payments

(1) Compliance Paths for Foreign-Owned Enterprises

Subject to Decree 101, foreign payment platforms are required to choose one of the following methods to enter Vietnam:
🔹 JV (Vietnamese holding ≥ 70%) + technology transfer agreement;
🔹 Access to local licensees (e.g. Stripe in conjunction with VPBank) via API;
🔹 Servicing cross-border B2B transactions only (full licence not required but separate filing required).

Typical cases.
✔️ PayPal operates as a "cross-border export collection", avoiding domestic retail payment restrictions;
✔️ Alipay enables Chinese tourists to scan and pay in Vietnam through a partnership with NAPAS.

(2) Foreign exchange control risk

All settlements involving foreign currencies must be made through a designated bank channel, and enterprises are required to report the flow of funds to SBV on a monthly basis. Non-compliance may result in.
⚠️ Up to VND 5 billion fine (individual)/suspension of licence (business).

8.Industry Controversies and New Regulation Trends

Recent policy games have focused on two areas.

  1. The grey area of cryptocurrency-related payments
      Although the SBV reaffirmed the ban on using cryptocurrencies as payment tools in 2024, some P2P platforms still support it in disguise (e.g., USDT exchange) through virtual commodity trading, and there is a regulatory lag.

  2. Open Pilot Signal
      At the end of 2023, the draft proposed to allow wholly foreign-owned enterprises to carry out restricted digital payment experiments in special economic zones (similar to the model of China's Hainan FTZ), but it has not yet come to fruition.

9.Suggestions and Strategy References

For companies planning to enter the Vietnamese market.
📌 Priority for Class 02/05 licences reduces compliance costs;
📌 Rural markets can leverage the postal network (VNPost) or telecom agents to expand coverage;
📌 Focus on the Ho Chi Minh City Digital Finance Sandbox (expected to launch in 2025).

For specific case studies (e.g., how GrabPay bypassed shareholding restrictions), expand further.