World Watch/Vietnam/Digital Payments & Fintech

Digital Payments & Fintech · Vietnam

Digital Payments & Fintech - Vietnam

Licensing regimeState Bank of Vietnam (SBV) under the Law on Credit Institutions 2024 and Decree No. 52/2024/ND-CP on non-cash payments (in force 1 July 2024), implemented by Circular 40/2024/TT-NHNN as amended by Circular 41/2025/TT-NHNN; Decree 94/2025/ND-CP establishes a fintech regulatory sandbox.

Vietnam has a dedicated, in-force licensing regime for payments and e-money administered by the State Bank of Vietnam. Decree 52/2024 (effective 1 July 2024) introduced the country's first legal definition of e-money and governs licensing of intermediary payment service providers (IPSPs), including e-wallets, payment gateways, switching and clearing; over 40 non-bank entities are licensed. Open banking and P2P lending are only being piloted under the 2025 fintech sandbox, and BNPL still lacks a dedicated framework.

Regulator & primary law

The State Bank of Vietnam (SBV) is the sole licensing authority. Decree 52/2024/ND-CP (issued 15 May 2024, effective 1 July 2024) replaced Decree 101/2012 and is synchronized with the Law on Credit Institutions 2024, both effective 1 July 2024.

Intermediary payment service (IPSP) license

Non-bank providers must hold an SBV intermediary payment services license covering financial switching, electronic clearing, e-wallets, payment gateways, and collection/payment order services. The license runs 10 years and is renewable, with processing up to 60 working days.

E-money definition & capital requirements

Decree 52 gave Vietnam its first statutory e-money definition (VND value prepaid and stored electronically via banks or licensed e-wallet providers). Minimum paid-up capital for switching/clearing services was raised to VND 300 billion (from VND 50 billion).

Instant-payment rails (NAPAS / VietQR)

The National Payment Corporation of Vietnam (NAPAS) operates the core 24/7 instant retail transfer system and the interoperable VietQR standard (launched 2021), with a person-to-merchant (P2M) QR standard being rolled out from 2025.

Open banking & fintech sandbox

No standalone open-banking law exists; instead Decree 94/2025/ND-CP (effective 1 July 2025) created an SBV-supervised regulatory sandbox of up to two years for three solutions: credit scoring, open-API data sharing (open banking), and peer-to-peer lending.

BNPL — no dedicated regime

Buy-now-pay-later is growing rapidly but has no dedicated framework; the SBV has signalled future rules (late-fee caps, mandatory repayment disclosures, credit checks) anticipated around 2025–26, leaving BNPL currently outside a specific licensing regime.

Machine-assisted translation · verified 5/25/2026 · orientation, not legal advice. English version →