17.09.2026 
Non-bank fintech providers must secure a payment license in Vietnam before launching regulated intermediary services. Vietnam's central bank, the State Bank of Vietnam (SBV), has sole responsibility for issuing licenses and supervising these providers under rules distinct from those for banks. Its remit covers clearing infrastructure, payment gateways, e-wallets and services for collecting and disbursing funds. To prevent financial fraud and serious disruptions caused by system failures, the regulator requires competent staff, secure technology and charter capital funded through actual contributions or allocations.
This guide examines eligibility, the evidence applicants need and the sequence of regulatory decisions.
Regulatory framework
Decree 52/2024/ND-CP revised the rules governing payment intermediaries and non-cash transactions. Two statutes underpin this framework: the 2024 Law on Credit Institutions and the 2010 Law on the SBV.
Applicants seeking a Vietnam payment license must also follow the SBV's implementing circulars. These prescribe dossier formalities and translations, time allowed for technical assessment, arrangements for payment guarantee accounts and anti-money laundering (AML) reports. Circular 40/2024/TT-NHNN sets out the operational rules. Relevant amendments appear in Circular 41/2025/TT-NHNN and the later Circular 22/2026/TT-NHNN.
The SBV performs three principal supervisory functions:
- before issuing a license, the SBV reviews management suitability, available financial resources and how the charter capital was funded;
- its IT specialists assess the proposed software and the measures protecting it;
- once services are running, the SBV monitors compliance with transaction limits and anti-money laundering rules.
If, after notice from the SBV, a provider fails to remedy breaches of its operating conditions or departures from its approved Service Provision Plan, the SBV may revoke its license on the applicable statutory grounds. A provider whose license has been revoked may reapply three years later, provided all outstanding obligations have been discharged.
Choosing services for a Vietnam payment license
The regime recognizes six services with different technical demands and customer risks. Three are primarily customer-facing; the others provide systemically important infrastructure between payment systems.
|
Regulated service |
Function and users |
Minimum charter capital, billions of VND |
Approximate USD millions |
|
Electronic payment gateway |
Transmits and processes payment data, providing the technical link between customers, merchants and participating institutions |
50 |
2 |
|
E-wallet |
Holds customers' electronic money for payments and withdrawals, with facilities for topping up |
50 |
2 |
|
Collection and payment support services |
Receives funds for third parties and carries out customer payment instructions, including bulk disbursements |
50 |
2 |
|
Electronic clearing |
Reconciles participants' transaction records and calculates the net amount payable to or by each participant; settlement takes place through SBV accounts |
300 |
12 |
|
Financial switching |
Processes transaction data and routes it among domestic participating institutions |
300 |
12 |
|
International financial switching |
Links foreign payment infrastructure to the domestic network to route and process transaction data across borders |
300 |
12 |
Several customer-facing activities may be licensed together, provided the proposed technology supports each activity to the required standard. When providing switching or clearing, payment intermediaries in Vietnam must not conduct unrelated commercial business.
Eligibility: funding, management and technology
The SBV uses eligibility tests to screen out shell companies and protect customer balances. Before filing, applicants therefore need documentary evidence of lawful establishment, financial resources and operational capability.
Establishment and capital
To apply, a Vietnamese LLC (limited liability company) or JSC (joint stock company) must already hold its enterprise registration certificate. The applicant is ineligible while undergoing reorganization, dissolution or bankruptcy proceedings initiated by a formal decision.
How much charter capital an applicant needs for a Vietnam payment license depends on the planned services. Contributions or allocations must be real and lawfully sourced. Owners must submit a written undertaking to preserve the capital's actual value, with supporting documents. For a cash contribution, account statements document the money received. Recycling the same funds to create an apparent capital contribution does not satisfy this requirement.
The capital requirements appear in the service table above. All applicants must have the required capital in place before filing and document its lawful source. Providers collecting and disbursing funds must segregate customers' money from their own.
Senior appointments and staff
Both the general director and the legal representative must possess a degree in law, economics, IT or business administration at university level or above. Each must also have spent five years or longer managing or directing a financial or banking organization and be free of statutory disqualifications.
A college qualification is the minimum for deputies and other key staff, including technical personnel and department heads. Their qualification must be in one of the disciplines listed for the senior appointees or another field relevant to their duties. Staffing must be sufficient for the intended operation, including engineers with appropriate information-security qualifications.
Resident representation is mandatory: one or more legal representatives must live in Vietnam but need not have permanent residence status. If only one legal representative resides in Vietnam, that person must arrange a written delegation to another local resident before traveling abroad, while retaining responsibility.
Technical capability
Applicants must design their systems for continuous operation, with data backups and redundant servers. Reviewers examine how the platform resists DDoS attacks, protects data during transmission and encrypts personal information.
Information systems, including their servers and data centers, generally need security level 3. Switching and clearing infrastructure requires level 4 or above, with conformity assessed in both design and implementation.
E-wallet connections and protection of customer money
No segment of Vietnamese fintech is regulated more closely than e-wallets. Because wallet providers hold customers' prepaid funds, the rules govern customer balances and the providers' bank connections in detail. An e-wallet stores electronic money for spending; its balance earns no interest, and the provider may not lend to wallet customers.
Serving customers at different banks
No fintech service operates in isolation from Vietnam's banking network. Wallet providers serving customers across several banks must connect through a licensed switching and clearing operator; the same applies to collection and payment support services. Applicants must give the SBV a preliminary connection agreement before the license is issued. They must establish the connection before processing payments or wallet top-ups.
Guarantee account and permitted withdrawals
Before launch, the wallet provider must open its payment guarantee account with a cooperating bank. The SBV requires wallet providers holding a payment intermediary license in Vietnam to keep their operating funds separate from the money backing customers' wallets.
At any given time, the guarantee accounts together must contain enough to meet all outstanding wallet balances. Regulations restrict withdrawals to expressly authorized purposes. These include refunds, payments made on customers' instructions and associated settlement, together with the fee withdrawals discussed below. The provider must not use customers' money to cover its costs, make loans or finance investments.
In addition, the provider may withdraw service fees already deducted through wallet transactions, provided it substantiates the amount under arrangements agreed with its bank. Banks and providers perform daily reconciliation; the SBV supervises their compliance.
Evidence accompanying the application
Applicants must supply accurate information and the prescribed documents when seeking a Vietnam payment license. The dossier must be in Vietnamese. Foreign-issued documents need translation and, unless exempt, consular legalization. Copies must be certified, drawn from official registers or presented with originals for comparison; signatures on self-prepared CVs must be authenticated.
Applicants assemble eight groups of material:
- the prescribed form, together with corporate approval for the proposed service and technical solution;
- corporate records, including the charter, enterprise registration certificate and investment documents where applicable;
- undertakings concerning capital and evidence that lawful funding was actually provided;
- staff qualifications and employment records; criminal record evidence concerning the two senior appointees described above; and proof of resident representation;
- technical specifications explaining the architecture, deployment of servers and security measures;
- evidence demonstrating that the system meets its required security level;
- preliminary agreements with cooperating banks and the infrastructure operator providing the required connection;
- the Service Provision Plan, supplemented by any evidence specifically required for infrastructure services.
Bank statements and relevant audit material substantiate funding. The technical documentation must include encryption protocols and information-security assessment results.
What the service plan must explain
Drafting the plan is usually the most labor-intensive stage of preparing the application. Applicants must explain the proposed financial, technical and operational arrangements. The SBV examines:
- the movement of funds from payer to recipient, every intermediate account and the stages at which fees arise;
- how customers, merchants and banks interact with the provider;
- the processing sequence and the technology used at each stage;
- how financial, operational and technological risks will be managed, and the internal controls proposed;
- the compliance policy, including customer identification under KYC procedures and AML controls;
- what staff will do if servers fail, an outage occurs or the system suffers a cyberattack.
During appraisal, the SBV may request explanations or revisions to address technical inconsistencies or failures to meet the circulars' requirements.
Have questions about this material? Contact our consultant directly and receive a high-quality consultation!
Payment license in Vietnam: submission through to launch
Inspection of the provider's readiness to operate comes after licensing, not before. Serving customers is prohibited until the pre-launch procedure is complete.
Filing and initial review
Applicants may file by post or in person at the SBV's Hanoi single-window service. Online applications can be submitted through the SBV public services portal or the national public services portal. Registry staff record the submission date, allocate a reference number and forward the dossier for initial screening. The Payment Department coordinates the procedure.
Alongside the technical proposal, the SBV examines corporate records, funding sources and management arrangements. Its Information Technology Department gives a written opinion on architecture and security. An amendment effective from 19 May 2026 introduced the IT assessment deadline shown in the table below.
Deadlines for review and launch preparation
The following periods are measured in working days, and the starting point differs for each step.
|
Step |
Days |
Starting point and required action |
|
Completeness check |
5 |
From receipt: the SBV checks whether further dossier components are needed |
|
IT assessment |
20 |
The IT Department must give its written opinion after receiving the Payment Department's request |
|
Initial appraisal |
90 |
The SBV assesses the application after receiving every required component in valid form |
|
Appraisal after corrections |
90 |
From arrival of the corrected dossier: SBV reassessment and a decision |
|
Licensing fee |
15 |
From the license's issue date: the provider must pay the fee |
|
Readiness notification |
At least 30 |
Provider's advance notice before the intended launch |
|
Inspection and written findings |
15 |
From receipt of the full readiness package: inspectors must finish the inspection and issue written findings |
Corrections and physical inspection
If the SBV sends a written notice of deficiencies, the applicant has 60 days to provide explanations and amend the plan or software as required. Once the corrected dossier arrives, the SBV must complete the further appraisal within the period shown above.
After issuing the Vietnam payment license, the SBV checks the installed servers, engineering team and platform against the approved Service Provision Plan. The provider must launch within six months of the license's issue date. Before launch, it must meet the technical requirements, publish the required information and complete the other pre-launch formalities.
Operating under the license
The license identifies the provider's permitted payment activity in Vietnam. While the license remains valid, the provider must stay within that scope, comply with the governing rules and disclose the information specified below.
Public information
Before launch, the provider must list its authorized services, delivery methods and service brands on its website. Those particulars must be kept current.
An e-wallet provider must announce any change of brand or trading name on its website and give the SBV written notice at least one month before it takes effect.
Records, AML controls and tax treatment
A payment intermediary in Vietnam must account for each authorized service separately, recording its income and costs. Any permitted business outside that licensed activity must also be recorded separately.
Under the 2022 Anti-Money Laundering Law and relevant SBV rules, providers must use software that verifies customer identities under KYC procedures, automatically analyzes transfers and retains transaction records. For customer and transaction files, Article 38 of the AML law requires retention for five years, starting from transaction completion, account closure or reporting, as applicable. Providers must submit tax returns and regulatory reports according to the responsible authorities' timetables, including monthly or quarterly filing where required.
Corporate income tax normally applies at 20%, with reduced rates available to eligible enterprises under statutory conditions. VAT exemptions for specified financial services, including lending and securities transactions, do not automatically cover fees for payment processing or IT support. Taxable supplies normally attract 10% VAT, unless a reduction applies.
Annual financial statements must undergo independent audit where the enterprise belongs to a category specified by law, including foreign-invested companies.
Extending services or losing the license
To add a service, the provider submits another application, updates its plan and demonstrates that its technology can perform the additional work. The provider must also contribute any amount needed to meet the applicable capital threshold. Once it approves the additional service, the SBV records this in a supplementary document forming part of the Vietnam payment license.
Following a corporate division, a provider may retain its license; it must notify the SBV in writing within 30 days of the event and continue to meet all licensing conditions.
A provider that misses the six-month launch deadline risks losing its license after the required notice and opportunity to remedy the failure. Separately, a provider risks revocation if it supplies none of its licensed services for six consecutive months.
The SBV may also revoke the license for serious unlawful use of payment accounts, instruments or services, including money laundering. A provider that repeatedly submits false reports of wallet counts or balances also risks revocation.
The affected services must stop immediately when the revocation decision reaches the provider. Written notices must go to customers and counterparties within 30 days of the decision, so that contracts can be terminated and remaining obligations discharged.
Expenditure and implementation risks
Applicants budgeting for a Vietnam payment license should distinguish the required capital from the cost of preparing to operate. Charter capital remains available to the business and is separate from safeguarded customer money; the required amounts appear in the service table.
Preparation costs cover:
- designing and testing the platform, with assessment at security level 3 or, where applicable, the higher infrastructure standard;
- renting local data-center facilities and purchasing specialist servers;
- recruiting qualified technical personnel and senior managers with the requisite experience;
- paying the VND 10 million initial licensing fee under the published tariff and obtaining legal support.
Applicants face particularly demanding technical scrutiny: the SBV is unlikely to approve a generic plan. Recruiting suitable local managers presents a further difficulty. Applicants address both by engaging local legal teams with banking-sector experience.
Conclusion
The procedure for obtaining a payment license in Vietnam is demanding but clearly defined. In return, the license confers access to a dynamic cashless payments market in Southeast Asia. Applicants must build a credible technical platform and actually contribute the required capital. They must comply with the governing legislation before launch and throughout their operations.
