Vietnam (VN)

Licensing, Authorisation & Market Access

Vietnam operates a fully centralised, bank-gated licensing regime with the State Bank of Vietnam (SBV) as sole authority. Under Decree 52/2024/ND-CP (effective 1 July 2024, replacing Decree 101/2012), payment intermediary service providers are defined as non-bank organisations licensed by the SBV, while banks and foreign bank branches act as payment service providers. There is no EMI or PI passport regime; the Intermediary Payment Service (IPS) licence — a 10-year renewable term — is the only non-bank route to market. This bank-PSP versus non-bank-PI/EMI distinction is foundational: banks and IPSPs occupy separate licensing lanes with no passport option, defining the sole market-access route for non-bank payment firms.

The regime is capital-tiered. Minimum charter capital is set at VND 50bn (~US$1.96m) for e-wallet, payment-order, collection and gateway services, rising to VND 300bn for financial switching, international financial switching and electronic clearing. An IPSP cannot be a commercial bank or foreign bank branch. These floors materially raise the barrier to entry for switching and clearing operators relative to wallet and gateway firms. Circular 40/2024/TT-NHNN (effective 17 July 2024, replacing Circular 39/2014) implements Decree 52 at the service-category level across six IPS categories — financial switching, international financial switching, electronic clearing, e-wallet, collection-and-payment support, and electronic payment gateway — under the Law on Credit Institutions 2024.

The administrative procedure is set by Decision 1118/QD-NHNN (11 June 2024), which routes IPS licensing through the SBV Single-Window Department, with completeness confirmation within five working days, a ten-year renewable term and a six-month rollout requirement.

Outlook

The licensing perimeter is established and stable; the live pressure is enforcement of the perimeter rather than its redefinition. With no passport regime and capital floors tiered by service category, market entry for switching and clearing functions remains structurally gated, and the bank-gated architecture is the durable analytical spine for any non-bank operator assessing Vietnam.

Stablecoins & Digital Money

Vietnam's digital-money regime is bifurcated and restrictive. On the regulated side, e-money is a 1:1 prepaid instrument that is escrow-safeguarded. On the crypto side, Resolution 05/2025/NQ-CP (9 September 2025) establishes a five-year (2025-2030) crypto-asset trading-market pilot supervised by the Ministry of Finance. Vietnamese-issued crypto assets must be backed by real-world assets, with securities and fiat currency expressly excluded — effectively prohibiting fiat-backed stablecoins such as USDT and USDC from local issuance — and a VND 10 trillion (~US$400m) minimum charter-capital floor applies to market operators. Crypto is not legal tender and not a means of payment.

The Law on Digital Technology Industry (Law 71/2025/QH15), passed 14 June 2025 and effective 1 January 2026, recognises crypto assets as property but neither as legal tender nor as a usable means of payment in Vietnam. Property recognition therefore arrives without payment-medium status.

Against this restrictive backdrop, the Da Nang Basal Pay pilot (Alphatrue Solutions JSC) is the notable exception — the first Vietnamese city to pilot a digital-asset payment project, converting VND payments to USDT equivalent at point of sale while integrating AML/CFT and the FATF Travel Rule. It is a controlled, sub-national carve-out rather than a general liberalisation; illicit-finance dimensions of the pilot route to FIM.

Outlook

The regime closes off domestic fiat-backed stablecoin issuance and gates crypto-market operators behind a US$400m capital floor, marking a restrictive frontier for digital-money products. A Ministry of Finance draft crypto-sanctions decree signals enforcement will extend to the pilot market, while the Da Nang pilot is the surface to watch for any narrow practical accommodation of stablecoin-at-POS use.

Legal & Litigation

Enforcement in Vietnam is administrative-penalty-led and escalating. Decree 340/2025/ND-CP introduces administrative sanctions in the monetary and banking sector, effective 9 February 2026, covering illegal FX and gold trading, payment-service provision, IPS violations and unlicensed banking, with significantly higher fines plus confiscation, suspension and disgorgement of illegal profits. Sharply higher fines for unlicensed or IPS-violating payment activity raise the compliance cost of operating outside the licensing perimeter, affecting both bank PSPs and non-bank IPSPs.

The SBV has proposed fines of VND 150-200m for opening payment accounts allowing unlawful customer use and up to VND 200-250m for anonymous or fraudulent accounts, responding to police dismantling of account-trading rings (February 2025 arrests in Dong Nai, Hanoi and Da Nang). Enforcement of the biometric-verification mandate has been at scale: on 1 September 2025 the SBV deactivated over 86 million bank accounts — 43% of all accounts — for failing to complete biometric verification under Decision 2345.

Outlook

The defining forward event is Decree 340/2025 coming into force on 9 February 2026, registered as a material in-force change. Combined with a Ministry of Finance draft crypto-sanctions decree (18 November 2025), the enforcement trajectory is escalating, extending administrative penalties further across the payments and crypto perimeter.

AML/CFT & Financial Crime (Sentinel-fed)

This module is sourced from the Sentinel.gi feed; intelligence is carried, not re-analysed here, and original illicit-finance analysis belongs in FIM. Per Sentinel, Vietnam remains subject to FATF increased monitoring (the grey list); the 24 October 2025 FATF statement continued to list Vietnam as actively working to address strategic AML/CFT deficiencies, imposing heightened correspondent-banking scrutiny. Grey-listing raises the correspondent-banking due-diligence burden and de-risking risk for Vietnamese institutions, linking directly to the W12 access asymmetry.

Also carried from Sentinel: Circular 27/2025/TT-NHNN sets transfer-reporting thresholds — domestic transfers of VND 500m or more and international transfers of US$1,000 or more must be reported — with tighter risk-assessment criteria and mandatory electronic submission by 1 January 2026, anchored by the AML Law 2022 (Law 14/2022/QH15). Detailed illicit-finance analysis of these thresholds routes to FIM. See the Sentinel.gi feed for the underlying source material.

Outlook

The near-term marker is the 1 January 2026 commencement of mandatory electronic AML transfer-reporting. Persistent grey-list status keeps correspondent de-risking pressure elevated; any FATF re-rating would be the most consequential forward signal, and is tracked via Sentinel.

Conduct, Safeguarding & Promotions

The conduct and safeguarding layer is now fully defined and applies principally to non-bank PI/EMI operators. E-wallet providers must safeguard customer funds through a 1:1 payment-assurance (escrow) account held at an associated bank, are prohibited from receiving cash directly from customers, and may accept top-ups only via deposit to the payment-assurance account, from a VND bank account, or from another provider's e-wallet. This segregation mechanism is functionally analogous to UK safeguarding but is bank-account-escrow based, determining how non-bank wallet float is protected.

Decree 52/2024/ND-CP introduced Vietnam's first-ever legal definition of e-money — VND value stored on electronic media on a 1:1 prepaid basis — and broadened prohibitions to forbid buying, selling, renting or lending payment accounts and e-wallets and the illegal disclosure of account or wallet data, while removing electronic money transfer support services from the IPS list.

The live forward item is Circular 41/2025/TT-NHNN (dated 5 November 2025), amending Circular 40/2024, which mandates that IPSPs verify e-wallet holder identity in person or via biometric methods at account opening and verify customer phone numbers. The e-wallet opening, customer-authentication and information-provision provisions take effect 1 January 2026. Mandatory in-person or biometric KYC at wallet opening raises onboarding friction and cost for non-bank wallet operators from 2026.

Outlook

The January 2026 commencement of Circular 41's biometric KYC provisions is the defining near-term shift, raising onboarding cost for non-bank wallet operators. The escrow-based safeguarding model is settled, leaving conduct enforcement and KYC operationalisation as the active surfaces to monitor.

Operational Resilience & Critical Infrastructure

Vietnam's resilience regime is SBV-driven and authentication-centric rather than built on a single DORA-style instrument. Decision 2345/QD-NHNN (effective 1 July 2024) and Circular 50/2024 (effective January 2025) raise cybersecurity and authentication requirements, including liveness detection to address biometric fraud, app tampering and unauthorised data access. The requirements apply to both bank PSPs and non-bank IPSPs.

Infrastructure resilience has advanced at the national rail level. NAPAS completed a distributed TiDB/PingCAP platform upgrade (with Hyperlogy), migrating from centralised specialised hardware and enabling zero-downtime data-centre failover versus the prior roughly 30-minute manual switchover. This materially de-risks the national retail rail underpinning around 15 million daily VietQR transfers.

The SBV's centralised SIMO fraud-monitoring platform, deployed in 2025, allows credit institutions to block suspicious transactions instantly. As of 11 December 2025, 122 of 147 banking institutions reported data, logging 592,000 flagged accounts and issuing 2.13 million fraud alerts.

Outlook

Resilience and fraud-monitoring infrastructure is consolidating around centralised SBV platforms and a hardened national rail. The trajectory is establishment of a coordinated authentication-and-monitoring stack; continued onboarding of the remaining reporting institutions to SIMO is the near-term operational marker.

Scheme & Network Compliance

The domestic scheme layer is anchored on NAPAS and VietQR and is scaling rapidly. NAPAS 247 processed 8.9 billion instant transfers in 2024 (+33.8%) across 68 member organisations, while VietQR — launched 2021 and accepted across all Vietnamese banks — handles roughly 15 million transfers per day. VietQR is the national QR payment standard developed by NAPAS with 14 pioneering banks; a single VietQR code accepts payments from multiple banking apps and e-wallets including MoMo, ZaloPay, ShopeePay and MobiFone Money. Its lower fees and direct bank-account connection create competitive pressure on standalone e-wallets, with the low-fee account-to-account rail structurally displacing standalone wallet economics.

On the scheme-standards side, MoMo was the first domestic Vietnamese fintech to obtain PCI DSS v4.0 certification (reported January 2024) — a dated compliance milestone for a non-bank wallet rather than a structural shift.

Outlook

The interoperable national QR standard is intensifying competitive pressure on standalone wallets and consolidating value share around the largest super-apps. Scheme-compliance milestones for individual non-bank players will continue, but the dominant scheme dynamic is the structural advantage of the account-to-account rail.

Payment Corridor Dynamics

Vietnam's corridor build-out is anchored on NAPAS QR interoperability. NAPAS QR is interoperable with Thailand (2022), Cambodia (2023) and Laos (early 2025); China cross-border QR launched 2 December 2025 (with UnionPay, ICBC and Vietcombank), with reverse direction planned early 2026; and connections to Japan, South Korea, Malaysia and Singapore are planned for 2026. These expanding corridors open intra-ASEAN and China retail-payment flows, bypassing card-network rails for tourist spend.

On the inbound side, Vietnam received around US$16bn in remittances in 2024, with Ho Chi Minh City taking around US$9.6bn (roughly 60%) and Asia accounting for 54% of remittances, up 24% year-on-year. These flows move through remittance companies and credit institutions, a major inbound corridor for the economy.

Outlook

The corridor trajectory is opening, led by the live China connectivity and the planned 2026 ASEAN+ expansion. The VN-SG corridor remains a signed-MoU-but-not-active surface (NETS/NAPAS), with activation date and operational shape unknown, leaving that specific corridor trajectory uncertain.

Industry Structure & Commercial Dynamics

The Vietnamese PSP market is a maturing, moderately concentrated super-app structure. MoMo, VNPay and ZaloPay jointly account for more than half of total transaction value. As of 30 June 2024 there were 50 licensed IPS providers (48 e-wallet providers) with 58 million activated wallets and more than 34 million active wallets. Smaller wallets exited in 2024 after funding dried up, marking a shift from land-grab to profitability and capital discipline.

This structural picture — three super-apps dominating value share while smaller wallets consolidate out — reflects a capital-constrained market under pressure from the low-fee VietQR account-to-account rail, which is reshaping standalone wallet economics. Note the distinction from W13: the structural consolidation trend sits here, while specific announced deals and product launches are carried in commercial intelligence.

Outlook

Consolidation around the leading super-apps is the established trajectory, driven by the structural economics of the national QR rail and a tighter funding environment. Continued exits of sub-scale wallets, alongside the largest players' pivot to profitability, are the markers to track.

Merchant Acquiring & Risk

Merchant acquiring is being reshaped by NAPAS's P2M rollout. In 2025 NAPAS began deploying P2M (person-to-merchant) QR payments as a commercial payment standard with POS and e-invoicing integration and refund and complaint-handling features that P2P transfers cannot support; over 30,000 merchants were expected enabled for cross-border QR by end-2025, expanding in 2026. P2M adds acquiring-grade features — refunds, dispute handling, e-invoicing — to QR, formalising merchant acceptance economics.

The dispute and reconciliation framework is set by Circular 41/2025/TT-NHNN, which requires originating providers to share transaction details with beneficiary providers on request for transfers between e-wallets or between e-wallets and VND accounts or debit cards, facilitating dispute resolution, verification and reconciliation. This applies to inter-provider flows in the non-bank PI/EMI space.

Outlook

The acquiring surface is rollout-led, with P2M and cross-border merchant enablement expanding through 2026. Merchant-acquiring operational detail — chargeback rates, high-risk MCC treatment and acquirer stress — remains thin in the evidence base, so the risk-operations picture is a flagged gap rather than a settled position.

Product Innovation & Market Development

Vietnam's first banking-sector regulatory sandbox is established under Decree 94/2025/ND-CP (effective 1 July 2025), covering three solutions — credit scoring, Open API data sharing and P2P lending — under SBV supervision for up to two years. The mechanism is confined to Vietnam's territory, with cross-border supply by foreign providers excluded, and the official decree removed the cap on the number of participants. The sandbox establishes a supervised innovation pathway and an Open API standard, opening Vietnam's open-banking trajectory.

This is the thematic product-access regulatory view — open banking, BaaS and the like — distinct from discrete product launches carried in W13. On CBDC, there is no live retail CBDC and limited evidence on SBV research posture, so that surface cannot be populated for Vietnam beyond noting absence.

Outlook

The sandbox's Open API track underpins the open-banking build-out and is the principal forward theme. With participant caps removed, sandbox uptake over the two-year testing window is the marker to watch; CBDC research-stage signals remain a sparsely covered gap for the jurisdiction.

Consumer Protection & APP Fraud

Vietnam's consumer-fraud protection is structurally prevention-led rather than reimbursement-led. Decision 2345/QD-NHNN (effective 1 July 2024) sets a tiered authentication model: transactions under VND 10m use OTP (daily total under VND 20m), but transfers over VND 10m or daily totals over VND 20m require biometric authentication via chip-based ID, VNeID or stored biometric data — a response to around US$744m in 2024 online-fraud losses. The mandate was extended to corporate accounts in July 2025 and to e-wallets via Circular 41/2025. Critically, Vietnam lacks a UK-PSR-style mandatory APP-reimbursement scheme, making this a structurally different consumer-protection posture from the UK.

The reported outcome is material: by mid-September 2024 around 38 million bank accounts had biometric data collected (including around 4 million e-wallets), and the SBV reported a 72% reduction in fraud-related accounts following biometric authentication.

Outlook

The prevention-led model — biometrics, KYC and centralised monitoring — is the established posture and continues to expand across account types and instruments. The absence of a reimbursement scheme remains the defining contrast with the UK; whether enforcement shifts toward any liability-allocation framework is the open question.

Correspondent Banking, Settlement & Access

The analytical spine of this module is the bank versus non-bank access asymmetry. Under Decree 52/2024 Article 21, commercial banks and foreign bank branches may participate in international payment systems only after being licensed for basic FX operations and having AML and terrorism-financing risk policies in place; Decree 52 grants 24-month compliance windows for both bank participants and financial-switching providers connected to international payment systems. International settlement access is therefore bank-gated with FX-licensing and AML preconditions, channelling non-bank cross-border flows through approved commercial banks. This is a bank-PSP-reserved function: non-bank IPSPs cannot directly access international settlement.

Domestic settlement runs on two clearing layers. NAPAS is the main clearing facility for retail transactions under VND 500m, while CITAD/IBPS handles high-value interbank payments; NAPAS 247 is available 24/7. Vietnam is adopting ISO 20022 for both domestic and cross-border messaging.

Outlook

The bank-gated access architecture is structural and durable, and it is reinforced by FATF grey-list-driven correspondent de-risking pressure carried in W11. ISO 20022 migration is the principal infrastructure modernisation to track; the asymmetry between bank and non-bank settlement access remains the defining feature of the market's cross-border layer.

Commercial Intelligence (M&A, Investment & Product)

This module carries discrete commercial events. On 2 December 2025 NAPAS, UnionPay International, ICBC and Vietcombank launched bilateral QR-code retail payment connectivity enabling Chinese tourists to pay at Vietnamese merchants, following an MoU signed in October 2024 — a completed product release branded VIETQR Global cross-border QR (China connectivity). The deal value was not publicly disclosed. This live product opens China inbound tourist spend on the NAPAS rail and is distinct from the W5 corridor theme.

On 10 September 2025 MoMo partnered with iProov to safeguard Vietnamese users against digital fraud; MoMo has raised US$434m cumulatively at a roughly US$2bn valuation, with investors including Warburg Pincus, Standard Chartered and Goodwater Capital. The partnership terms were not publicly disclosed; the tie-up signals MoMo investing in onboarding and identity ahead of 2026 biometric KYC mandates.

Finally, Timo migrated to Mambu's cloud-native core in December 2024, reportedly reducing unit processing costs by 40% and enabling real-time ledgering; transaction value was not publicly disclosed. Visa's 2024 QR partnership with MoMo, VNPay and ZaloPay expanded international acceptance.

Outlook

Commercial activity centres on cross-border rail connectivity, anti-fraud tooling and core-banking modernisation. Deal values are undisclosed across all three events, so the true magnitude of M&A and investment in the Vietnamese payments market cannot be assessed — a flagged gap. The China cross-border QR product and pre-2026 anti-fraud investments are the surfaces to watch.