Fintech & digital payments rules in Vietnam (2026)

Vietnam's first fintech regulatory sandbox formally activates, allowing credit institutions, foreign bank branches, and wholly Vietnamese-owned fintech firms to pilot credit scoring, Open API data-sharing, and P2P lending under SBV supervision for up to two years. This operationalises the sandbox mandate embedded in the 2024 Law on Credit Institutions and eliminates the earlier cap on the number of participating entities.

The SBV replaced Circular 39/2014 with Circular 40, updating operational requirements for financial switching, electronic clearing, e-wallets, and payment gateways. Key changes include a revised clearing-loan commitment mechanism, monthly clearing-limit resets, and new carve-outs from the VND 100 million monthly e-wallet cap for essential services (utilities, insurance, education).

Decree 52 superseded the foundational Decree 101/2012, introducing Vietnam's first statutory definition of electronic money (VND-denominated value stored electronically on a prepaid basis), raising minimum capital for financial switching/clearing licences to VND 300 billion, and explicitly excluding virtual currencies from its scope.

The National Assembly ratified a comprehensive overhaul of the 2010 banking law (effective July 1, 2024), authorising online lending, electronic banking transactions, and — for the first time — mandating a legal basis for a fintech regulatory sandbox; this gave legislative grounding for the subsequent Decree 94/2025.

NAPAS and Thailand's NITMX launched bilateral QR code payment interoperability, enabling real-time retail payments between Vietnamese and Thai bank accounts; this was Vietnam's first cross-border QR linkage and was followed by Cambodia (2023) and Laos (2025), building a regional payment corridor.

The Prime Minister approved a five-year cashless-payment roadmap targeting non-cash transaction values at 25× GDP, annual service growth of 20–25%, and cash's share below 10% of transactions by 2030; it drove major infrastructure investment, with actual outcomes exceeding targets — mobile-payment volumes grew 73% annually and QR-payment volumes 106% annually through 2025.

The National Payment Corporation of Vietnam (NAPAS) deployed VietQR, the country's first EMVCo-compliant unified QR code payment standard, connecting over 40 banks and enabling interoperable P2P and retail QR transactions nationally; by 2025 it had become the dominant retail payment interface, growing at over 100% annually.

The SBV's circular (issued December 3, 2020; effective March 5, 2021) authorised banks to open individual payment accounts via remote electronic identity verification without branch visits, capped at VND 100 million/month; by end-2022 over 40 banks had deployed eKYC and 11.9 million accounts were opened remotely, dramatically accelerating financial inclusion.

Amendments to Circular 39/2014 imposed stricter customer due diligence on e-wallet providers, requiring full real-name registration and mandatory bank-account linkage for all e-wallets, and enhanced consumer protection requirements; this directly addressed AML/CFT concerns raised by the rapid, lightly regulated growth of non-bank e-wallet services.

The first significant amendment to Decree 101/2012 expressly recognised e-wallet services as a permitted intermediary payment product, giving clear legal footing to a rapidly growing industry (MoMo, ZaloPay, VNPay, etc.) and establishing the operational framework that would govern them until Decree 52/2024.

The SBV's Circular 39 (issued December 11, 2014; effective March 1, 2015) established Vietnam's primary regulatory rulebook for non-bank payment intermediaries, defining licensing conditions, capital requirements, AML obligations, and consumer protections for payment gateways, e-wallets, financial switching, and electronic clearing — the principal operating framework for a decade.

The cornerstone decree establishing Vietnam's legal framework for non-cash payments, creating the SBV licensing regime for all payment intermediary service providers, setting a minimum charter capital of VND 50 billion, and defining the initial taxonomy of licensed payment services — this decree governed the sector for 12 years before being superseded by Decree 52/2024.