To provide online banking services, CIs and foreign bank branches are subject to stringent requirements in respect of infrastructure requirements (including online and mobile banking application software), e-transaction confirmation via online banking, operation management, and protection of customers’ rights. An example includes server requirements: (a) resource utilization performance of the server, including: central processing unit (CPU), internal memory (RAM), data storage devices, and data access devices during storage or transmission, must not exceed 80% of the designed capacity on a monthly average basis; (b) the online banking system must have backup servers to ensure high availability; (c) must be logically or physically separated from other business operation servers; and (d) must be checked and hardened to enhance security for the operating system, and regularly updated with security patches. Additionally, the entity must prepare a list of software permitted to be installed on the servers. This list must be updated and reviewed at least once every 6 months to ensure compliance.
Currently, the list of Open APIs which could be implemented in Vietnam includes (i) Open API for querying the bank's exchange rates and interest rates; (ii) Open APIs for querying customer information; and (iii) Open APIs for initiating payments, depositing into e-wallets, and withdrawing from e-wallets. Banks are only allowed to deploy Open API as prescribed in point (iii) for third parties being banks and organizations providing IPS. To implement Open API, CIs and foreign bank branches are subject to stringent requirements in respect of technology, contracts, and transparency obligations.
Of note, for data sharing via Open APIs, parties can provide such services with the condition that they participate in the sandbox mechanism under Decree 94/2025 and obtain the Certificate of Participation in the Pilot Mechanism issued by the SBV.
Additional comments regarding the legal situation for online-banking services or what FinTech’s must be aware of in this business area
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Economic conditions
Market size for online-banking services and biggest companies in this business area
The online banking market in Vietnam has experienced rapid growth over the past decade. According to Lao Dong newspaper, following the reports from the SBV and market research organizations, as of 2023, many CIs in Vietnam have reported that more than 90% of their transactions were conducted through digital channels. Approximately 77% of Vietnamese adults have a bank account, with over 35 million payment accounts and around 14.9 million active cards issued via electronic Know Your Customer (eKYC) methods. Leading enterprises include major banks such as Vietcombank, BIDV, Techcombank, and VPBank.
Additional comments regarding the economic situation for online-banking services or what FinTech’s must be aware of in this business area