Name
Global FinTech Guide
Country _ Name
Vietnam
SectionTitle
Payment services
Body
FinTechs belonging to this category offer alternative payment services which are supposed to provide a faster and cheaper way for national, European, and international payments for private and business customers by using new technologies.

For example, payment service providers hereby offer solutions to easily integrate several payment services in online shops.

Some FinTechs furthermore provide real cash register systems and online-reservation solutions for restaurants and shops providing their own payment services or making use of the payment services of FinTechs described above.

Introduction

Attitude of the country towards modern payment services

 

Overview

Vietnam has shown a strong and proactive attitude toward the adoption of modern payment services, positioning itself as one of the leading countries in Southeast Asia in the shift toward a cashless economy. The Vietnamese government has played a central role by issuing policies and enhancing the regulatory framework to promote non-cash payments as part of its broader national strategy for digital transformation. In parallel, businesses, especially those in the banking, FinTech, and retail sectors, have actively invested in and integrated advanced payment technologies to meet growing market demand. On the consumer side, Vietnamese people, particularly the younger and urban populations, have embraced digital payment methods enthusiastically, including mobile wallets, QR code payments, and contactless cards. This collective momentum reflects the country's determination to modernize its financial infrastructure and deepen its integration into the global digital economy.

Government Policy and Strategic Direction

At the heart of this shift is the Vietnamese government’s strategic commitment to digital transformation. The National Digital Transformation Program approved in 2020 by the Prime Minister outlines ambitious goals for expanding digital infrastructure and services by 2025, with a vision toward 2030. A key component of this strategy is the promotion of e-payments, with the goal that by 2025, more than 50% of the population would have electronic payment accounts, and by 2030, the rate would reach 80%. Supporting this, a national strategy on non-cash payments has been introduced to enhance the legal framework, expand payment infrastructure, encourage FinTech innovation, and adopt international best practices—particularly for the 2021–2025 period. Resolution No. 57-NQ/TW of the Politburo dated 22 December 2024, on breakthroughs in the development of science, technology, innovation, and national digital transformation, which is regarded as a strategic document and a guiding framework for development in the new era, also reaffirms the target of achieving 80% cashless transactions by 2030.

A major milestone is Decree No. 52/2024/ND-CP of the Government dated 15 May 2024 on cashless payments. This decree replaces earlier regulations and introduces a comprehensive legal framework for non-cash payment activities. It defines electronic money, regulates e-wallets and prepaid cards, and adds e-wallets to the list of non-cash payment instruments.

Further reinforcing Vietnam’s commitment to financial innovation, the Government issued Decree No. 94/2025/ND-CP dated 29 April 2025 (“Decree 94/2025”) establishing a regulatory sandbox for FinTech solutions in the banking sector. Effective from 1 July 2025, this decree provides a controlled testing environment for credit institutions, foreign bank branches, and eligible FinTech companies to pilot innovative models such as peer-to-peer (“P2P”) lending, credit scoring technologies, and open API-based data sharing. The sandbox aims to foster enhanced consumer protection and support the development of a responsive regulatory framework. 

On 14 June 2025, Vietnam became the first country to enact a dedicated law governing the digital technology industry. Set to take effect on 1 January 2026, the Digital Technology Industry Law aims to accelerate the country’s digital transformation, foster sustainable growth for domestic technology enterprises, and help elevate Vietnam’s position on the international stage.

Business Sector Engagement

Vietnamese businesses, especially in banking and retail, have embraced digital payment technologies. Banks and FinTech companies are investing heavily in digital platforms, offering services such as QR code payments, mobile banking, and contactless transactions.
As an example, in 2024, the National Payment Corporation of Vietnam (“NAPAS”) system processed 9.56 billion transactions, equaling 130% of the volume in 2023. Among these, NAPAS 247 recorded a 33.5% year-on-year growth in transaction volume, along with a 14.9% increase in the total value of transactions. Additionally, as reported by Mr. Nguyen Quang Minh, General Director of NAPAS, the NAPAS 247 fast transfer service utilizing VietQR codes saw a significant surge, growing by 118% compared to the same period in 2023, and accounted for roughly one-third of the service’s total transaction volume.

Data from the State Bank of Vietnam (“SBV”) on mobile money development as of June 2024 indicates that Vietnam had reached 9.13 million mobile money accounts, supported by nearly 275,600 payment acceptance points. During this period, the system facilitated approximately 128 million transactions, with a total value of around USD 191 million. In the first half of 2024, QR code payment transactions grew by 104.23% in volume and 99.6% in value compared to the same period in 2023. Over 70% of merchants across Vietnam now accept cashless payments, and partnerships with global firms like Visa and Mastercard are helping to expand infrastructure.

Consumer Behavior and Adoption
Vietnamese consumers are embracing digital payments at an impressive rate. According to Visa’s 2023 Consumer Payment Attitudes Study, 88% of Vietnamese consumers reported going cashless in 2023, with QR codes among the most popular methods. In addition, data from the SBV indicates that by May 2024, the value of cashless payments was 23 times the country’s GDP. Mr. Pham Anh Tuan, Director of the Payment Department at the SBV, noted that “with Vietnam’s 2023 GDP estimated at around USD 430 billion, the total value of cashless payments is estimated at approximately USD 9.89 trillion.” Previously, under Decision 1813, the target was set at 25 times GDP. According to Mr. Pham Anh Tuan, “this means the current level has reached about 90% of the target.”



Legal affairs

Obligations and requirements to provide payment services or ancillary services described above

In Vietnam, FinTech is primarily regulated by Decree No. 52/2024/ND-CP of the Government dated 15 May 2024 on cashless payments (“Decree 52/2024”), Decree 94/2025, and their guiding legal documents. Certain concepts under Vietnamese law which are relevant to fintech include “cashless payment services” and “intermediary payment service.”

Under Decree 52/2024, “cashless payment services” include payment services through clients’ payment accounts and payment services not through clients’ payment accounts. Cashless payment service providers (hereinafter referred to as “payment service providers”) are organizations providing one or several payment services, including the SBV, banks, and foreign bank branches.

Under the Law on the State Bank of Vietnam, intermediary payment service (“IPS”) is defined as an intermediary activity for connecting, transmitting and processing e-data on payment transactions between payment service providers and users. IPS providers are organizations that are not banks or foreign bank branches licensed by SBV to provide payment intermediary services.

Payment service providers and IPS providers are each subject to certain requirements to be eligible to provide the relevant payment services in Vietnam. In particular:

Payment Service Providers

Among other types of organizations entitled to provide cashless payment services, banks and foreign bank branches are more appropriate for foreign investors. To establish banks and foreign bank branches, the investors are required to obtain a banking license from the SBV; and for this purpose, are subject to stringent requirements, typically the legal capital of VND 3 trillion (approx. USD 120 million) for commercial banks and USD 15 million for foreign bank branches.

Meanwhile, for setting up foreign bank branches, the parent bank must have a valid banking license in its home jurisdiction, ensuring that the proposed operations in Vietnam are consistent with those permitted abroad, and demonstrating strong financial standing. In addition, Vietnamese law also requires that the competent authority of the country where the parent bank is headquartered must sign an agreement with the SBV on inspection and supervision of banking operations and have made a written commitment on consolidated supervision according to international practices. The parent bank must have total assets equivalent to at least USD 20 billion and have been profitable for the five consecutive years immediately preceding the year of application submission. For any second or subsequent branch, the existing branch must have complied with all legal requirements, maintained prudential ratios, and recorded profits for the three consecutive years prior to the application.

IPS Providers

To offer IPS, enterprises must obtain a license from the SBV, be legally registered in Vietnam, and meet strict organizational, capital, personnel, and technical standards. Minimum charter capital requirements range from VND 50 billion (approx. USD 1.92 million) for services like e-wallets and payment gateways to VND 300 billion (approx. USD 11.54 million) for switch and clearing services or international transaction processing. Key personnel must have relevant university degrees and at least five years of management experience in finance or banking. Licensed entities must maintain IT systems certified at security level 3 or higher and comply with rigorous technical and security requirements.

For e-wallet and collection/payment support services involving customers with accounts at multiple banks, the IPS provider must partner with a licensed financial switching and electronic clearing service provider approved by the SBV. Providers of financial switching and electronic clearing services must also meet additional requirements, such as having settlement of clearing results carried out by another organization, maintaining interconnection agreements with at least 50 banks or foreign bank branches and 20 IPS providers, and operating IT infrastructure meeting at least level 4 security standards with capacity for at least 10 million transactions per day. Each participant may connect with no more than two switching and clearing service providers.

For international financial switching services, the IPS provider must meet specific licensing, internal control, technical, and legal requirements, and the connected international payment system must be legally established and operated abroad.

Payment services and IPS for non-residents and foreign residents in Vietnam to implement payment transactions of goods and services in Vietnam of foreign service providers must be carried out through commercial banks or foreign bank branches approved by SBV to participate in international payment systems. Foreign organizations providing payment services or IPS to such customers must not make direct payments to local IPS providers.

Financial switch service providers may connect to international payment systems to carry out international financial switch services when they meet the requirements.
IPS providers (excluding financial switch service providers) may provide services for payment transactions for foreign goods and services, but payment and settlement must be through commercial banks or foreign bank branches approved by the SBV to engage in foreign exchange on international markets.

Payment service providers and IPS providers must also comply with anti-money laundering, foreign exchange control, and other regulations, including customer identification, risk assessments, and reporting suspicious transactions to the SBV.



Additional comments regarding the legal situation for payment services or what FinTech’s must be aware of in this business area

Vietnam’s regulatory landscape for FinTech is expanding rapidly, though it remains fragmented. While foundational regulations such as Decree 52/2024, Decree 94/2025 and Circular 40/2024 provide a framework for payment services (for example, Decree 94/2025 provides a controlled testing environment to pilot innovative models such as P2P lending, credit scoring technologies, and open API-based data sharing), many emerging FinTech models, like blockchain applications and mobile money, are still outside the scope of comprehensive regulation. This regulatory gap presents both growth opportunities and legal uncertainties for market participants.

Another initiative to promote cashless payments is the development of a legal framework for mobile money. Essentially, mobile money involves converting cash into electronic money at a 1:1 ratio. The service has been piloted under Decision No. 316/QD-TTg of the Prime Minister dated 9 March 2021. However, as the service is still in the pilot phase and lacks a formal legal framework, implementing organizations have remained cautious, which has somewhat hindered decisions to increase investment budgets for service development. In response, on 3 July 2024, the SBV released a draft decree on mobile money services for public consultation. Accordingly, a non-bank organization or a foreign bank branch must be granted a license by the SBV to provide mobile money services. Eligibility requires meeting and continuously maintaining specific conditions, including holding a valid license to operate IPS for electronic wallets and a license to provide telecommunications services with network infrastructure for terrestrial public mobile networks using radio frequency bands, or the entity may be a subsidiary or affiliated unit authorized by a licensed telecom provider to use its infrastructure, network, and data.
Currently, obtaining a new license in Vietnam for IPS is a slow and cautious process with stringent technical requirements, while mergers and acquisitions offer a quicker entry by leveraging existing licenses and infrastructure, though both approaches face challenges with aligning advanced technologies with regulatory requirements.



Economic conditions

Market size for payment services and biggest payment service providers

As reported by Mr. Le Anh Dung, Deputy Director of the Payment Department of the SBV in May 2024,
as of the end of 2023, Vietnam had over 182 million personal payment accounts, with 87.08% of the adult population holding a payment account. There were also more than 147 million bank cards in circulation and 32.77 million active e-wallets.

According to the Ministry of Information and Communications (“MIC”), as of July 2024, the number of Mobile Money (“MoMo”) payment points reached 275,879 nationwide, reflecting a 9.56% increase compared to April 2024. The MIC also announced that “the total number of transactions (including deposits, withdrawals, transfers, and payments) exceeded 119 million, up by 8%, with a total transaction value of over VND 4.462 trillion (approximately USD 186.5 million), representing a 7% increase.” In 2024, the total value of digital payments in Vietnam was estimated at approximately USD 21.9 billion, with projections indicating a near doubling to USD 42.8 billion by 2032.

The market is dominated by e-wallet providers, with MoMo leading the sector and accounting for 68% of the market share. Other major players include ZaloPay, ViettelPay, ShopeePay, and GrabPay.

In addition to e-wallet providers, NAPAS plays a critical role as the national switching and clearing provider, facilitating interbank transactions and QR-based payments across platforms. NAPAS operates the NAPAS 247 payment system, which connects over 40 banks nationwide. VietQR code transactions made up one-third of all transactions processed through NAPAS 247. At the end of 2024, the NAPAS system processed over 10 million transactions via VietQR codes every day.



Additional comments regarding the economic situation for payment services or what FinTech’s must be aware of in this business area

Vietnam’s payment services sector is undergoing a dynamic transformation, driven by strong economic fundamentals, digital adoption, and government support for financial innovation.

Economically, Vietnam offers a young, tech-savvy population, and increasing digital spending habits. This creates fertile ground for FinTech adoption, particularly in underserved and underbanked segments. Yet, FinTechs must navigate regulatory complexity, cybersecurity risks, and intense competition from both startups and traditional banks entering the digital space.

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