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Vanuatu's payment-system licensing and supervisory architecture is being re-founded: the Reserve Bank of Vanuatu Act No. 37 of 2025 (passed 6 November 2025, repealing RBV Act [CAP 125]) expressly brings payment system operators, e-money and digital-wallet providers within RBV's direct supervisory remit for the first time, but the Act had not commenced as of this cycle.
A distinct and so-far-unresolved issue flagged by legal commentary is the regulatory boundary this creates between the Reserve Bank and the Vanuatu Financial Services Commission. Once the RBV Act commences, e-money and digital-wallet providers would fall under RBV's licensing and prudential purview, while the VFSC continues to regulate virtual asset service providers under its own separate statute. Where an entity's digital-wallet or e-money activity overlaps with virtual-asset-service activity, which regulator's licensing regime takes precedence, or whether dual licensing would be required, has not been resolved in the material available this cycle. This overlap bears specifically on non-bank payment and e-money providers; banks already operating under established Reserve Bank prudential supervision are less directly affected by the boundary question.
Outlook
The gazette notice expected to commence the RBV Act's substantive provisions during 2026 is the development to watch for market access: its publication would activate the Reserve Bank's new licensing authority over payment-system operators and e-money/digital-wallet providers, and would be the point at which the unresolved RBV/VFSC regulatory boundary becomes a live operational question rather than a prospective one for non-bank providers entering or operating in this space.
Licensing, Authorisation & Market Access
Vanuatu's financial-sector licensing perimeter has moved during the parliamentary sitting that closed in late October 2026, as part of a package of financial-sector bills reported to number nineteen in total. The clearest development concerns the Financial Dealers Licensing (Amendment) Act, which is reported to remove the "exempted dealer" category from the Financial Dealers Licensing Act [CAP 70]. That category has historically allowed certain categories of dealer to operate outside the licensed-dealer perimeter; its removal narrows the population of market participants who can conduct dealing activity without becoming a licensed entity, and points toward a tightening of market access generally rather than a loosening of it.
Alongside that measure, the same legislative sitting is reported to have passed a Financial Institutions (Amendment) Act and an International Banking (Amendment) Act. Both are bank-adjacent instruments passed in the same reform package, but the substance of what each amendment actually changes has not yet been located in primary form — coverage to date rests on a secondary news account of the sitting rather than the gazetted text of either Act. Until that text is available, the practical effect of these two amendments on licensing conditions for banks and international banking entities operating in or from Vanuatu cannot be stated with confidence; what can be said is that the direction of the package as a whole, taken together with the Financial Dealers Licensing change, is toward a more credible and more tightly supervised financial-sector rulebook, consistent with Vanuatu's wider effort to meet external compliance expectations tied to its financial-sector standing.
For firms assessing market access, the immediate implication is that any reliance on the exempted-dealer route under the Financial Dealers Licensing Act should be treated as closed or closing, pending confirmation of the amendment's commencement terms. For bank and international-banking entities, the two companion Acts should be treated as a signal that licensing conditions are under active legislative revision, even though their specific content is not yet confirmed.
1 earlier distinct update(s)
Licensing, Authorisation & Market Access
Vanuatu's Parliament passed a Financial Dealers Licensing (Amendment) Act during its October 2026 sitting that is reported to remove the existing "exempted dealer" category from the Financial Dealers Licensing Act [CAP 70]. This category had previously allowed certain dealers to operate outside the full licensing perimeter established under that Act; its removal means that entities previously relying on the exemption will need to hold a Financial Dealer Licence to continue operating, narrowing the population that can lawfully provide financial-dealing services in or from Vanuatu without authorisation. The reform was reported by legal commentary tracking the parliamentary sitting, and the gazetted text of the amendment has not yet been located, so the precise scope of the removed exemption, any transitional arrangements for firms currently operating under it, and the commencement date all remain to be confirmed against the published instrument.
The same parliamentary session produced a Financial Institutions (Amendment) Act and an International Banking (Amendment) Act, both confirmed as passed by a separate press report, but without located detail on their substantive content. These two instruments plausibly bear on licensing and market-access requirements for banks and payment institutions operating under Vanuatu's financial institutions framework, but nothing can currently be said about their effect: whether they touch capital or prudential requirements, ownership and control tests for licensees, or market-access conditions for new entrants is unconfirmed. This is a genuine gap rather than a null finding, and it sits specifically within the licensing, authorisation and market-access space because both instruments by name address financial institutions and international banking directly.
Taken together, the confirmed exempted-dealer removal and the unconfirmed financial-institutions and international-banking amendments describe a legislative session clearly focused on tightening or reworking authorisation requirements across multiple categories of Vanuatu-licensed financial business. The pattern across the session, where confirmed detail is tightening rather than loosening, gives some basis for expecting the financial institutions and international banking amendments to move in a similar direction, but this is an inference about pattern rather than a finding about either instrument's actual text, and is not stated as a conclusion.
Outlook
The principal marker to watch is gazettal of all three Acts, which would allow the exempted-dealer removal's transitional arrangements to be assessed and would finally surface the substantive content of the Financial Institutions and International Banking Amendment Acts. Firms currently operating under the exempted-dealer category, or any payment or banking entity licensed under the instruments being amended, should treat the current legislative session as a live source of change to Vanuatu's authorisation perimeter, with the practical detail still pending publication of the Acts as passed.
Sources and findings (13)
- T1https://www.rbv.gov.vu/index.php/en/financial-stability/prudential-framework/70-legislation-for-banking-industryretrieved
- T4https://www.offshore-protection.com/vanuatu-international-banking-licenceretrieved
- T1https://www.rbv.gov.vu/index.php/en/?view=category&id=2&resetfilters=0&clearordering=0&clearfilters=0&group_by=exchange_rates___aud&start=20&limitstart1=160retrieved
- T1https://www.rbv.gov.vu/images/Financial_Inclusion/2025/Vanuatu%20MMSP%20Operating%20Guidlines.pdfretrieved
- T3https://www.pln.vu/single-post/modernising-the-resrve-bank-of-vanuaturetrieved
- T1https://www.vfsc.vu/virtual-asset-service-provider/retrieved
- T3Financial Dealers Licensing (Amendment) Act — Financial Dealers Licensing (Amendment) Act — Reported to remove the 'exempted dealer' category under the Financial Dealers Licensing Act [CAP 70], narrowing who may operate outside the licensed-dealer perimeter.retrieved
- T1Reserve Bank of Vanuatu Act No. 37 of 2025 — Reserve Bank of Vanuatu Act No. 37 of 2025 — Passed 6 November 2025, repeals and replaces RBV Act [CAP 125]; not yet commenced as of this cycleretrieved
- T1VANKLIA (National Payment System RTGS/ACH platform) — VANKLIA (National Payment System RTGS/ACH platform) — Administered by RBV under Part 2 of the National Payment System Act No. 8 of 2021; active participants are ANZ Bank, BSP Bank, Bred Bank, National Bank of Vanuatu and RBV itselfretrieved
- T3Reserve Bank of Vanuatu Act No. 37 of 2025 — Reserve Bank of Vanuatu Act No. 37 of 2025 — Payment system operators and e-money/digital-wallet providers newly fall within RBV's licensing and prudential purviewretrieved
- T3Reserve Bank of Vanuatu Act No. 37 of 2025 — Reserve Bank of Vanuatu Act No. 37 of 2025 — Act has been passed but has yet to commence; expected to come into effect in 2026 once a gazette notice is publishedretrieved
- T3E-money/digital-wallet providers — Under the new RBV Act, e-money/digital-wallet providers fall within RBV's purview while VFSC continues as VASP regulator, creating an overlap not yet fully resolvedretrieved
- T2Financial Institutions (Amendment) Act / International Banking (Amendment) Act — Financial Institutions (Amendment) Act / International Banking (Amendment) Act — Passed as part of the same financial-sector reform package; specific content not located this run.retrieved