Country _ Name
Vietnam
SectionTitle
Online banking services
Body
FinTechs belonging to this area offer traditional banking services in a modern way, usually through online services or mobile applications as well as ancillary services – e.g. enabling customers to manage their giro- or custody-accounts online and in real time or offering e-wallet services. Keywords in this context are also API-Banking or Banking as a Service (BaaS)/ Bank as a Platform (BaaP).

API-Banking:

API stands for application programming interface and is offered to access data banks and to extract and insert information. API-Banking consequently means the access to data banks of banks to offer new and innovative banking applications.

Through these services FinTechs offer services with new functions, e.g. enabling customers to manage their accounts online and in real time.

BaaS – Bank as a Service/BaaP – Bank as a Platform:
 
The API-based Bank as a Service platform has a full banking licence, but merely serves as the back end for standalone independent FinTechs, which “use” the licence and the back end of the bank to offer new financial services, launch additional financial products or expand into additional markets.

Introduction

Attitude of the country towards online-banking services

Vietnam is witnessing strong development in online banking services and digital banking. Both the government and commercial banks have an open and proactive attitude toward applying digital technology to the financial and banking sectors.

Many banks, in both the private and public sectors, have invested heavily in digital banking platforms, allowing users to open accounts, transfer money, and manage finances quickly and easily through mobile applications without visiting physical branches. Simultaneously, FinTechs like MoMo, ZaloPay, and VNPay also play important roles as IPS providers, partnering with banks to help expand financial access for the population.



Legal affairs

Obligations and requirements to provide online-banking services described above

Online banking services are primarily regulated by the Law on Credit Institutions and its guiding legal documents such as Circular No. 50/2024/TT-NHNN for the provision of online services in banking industry (online banking) and Circular No. 64/2024/TT-NHNN regulating the implementation of open application programming interface (Open API) in the banking sector.

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

N/A



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

The economic situation in Vietnam's online banking sector is currently developing positively, driven by strong digital transformation trends in the financial-banking industry and a young demographic structure with high technology adoption rates. The usage of digital banking services and cashless payments is expected to rise rapidly, creating favorable conditions for banks and FinTech companies to expand their offerings.

Despite these promising trends, the market still presents significant challenges. New entrants must navigate stringent legal requirements related to licensing, information security, personal data protection, and anti-money laundering regulations. Moreover, the substantial investment needed for technology infrastructure, cybersecurity systems, and ongoing regulatory compliance poses considerable pressure.



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