Obtaining a payment system license in Vietnam is not as difficult as it seems if you study the registration procedure in advance and prepare all the documents. Opening and running a business in the field of financial technologies in Vietnam is becoming increasingly relevant. Against the backdrop of the active development of digital payments, the country demonstrates a stable economy, a growing domestic market and a high level of mobile penetration. All these factors make Vietnam especially attractive for companies interested in opening a payment system in Vietnam. The main focus of entrepreneurs is the opportunity to legally provide payment services, which means going through the full licensing process in accordance with current legislation.
Since July 1, 2024, a new regulatory framework has been in force in the country, regulating the entire process of licensing a payment system in Vietnam. Government Resolution No. 52/2024 and Circular No. 40/2024 of the State Bank of Vietnam introduced clear requirements for applicants, a list of mandatory documentation, and updated the technical audit procedure. These documents replaced the outdated standards enshrined in the previous regulation and now serve as the only official basis for obtaining a payment service license in Vietnam. The changes concern not only the application format, but also sustainability criteria, financial reporting, and storage of user data.
This material is written for entrepreneurs starting their path in the financial sector of Southeast Asia. The article provides a step-by-step analysis of the process of registering a payment system in Vietnam, from creating a legal entity to passing an audit and approval by the State Bank. In addition, practical recommendations and a brief overview of all the key conditions required to obtain a PI license in Vietnam are provided.
Vietnam as a Growing and Promising Market for Payment Solutions
Vietnam is firmly establishing itself as one of the key hubs of digital transformation in Asia. Rapid growth in domestic demand for non-bank payment services is coupled with large-scale reforms in legal regulation. The country with a population of over 100 million people creates conditions for organic expansion of fintech businesses, especially in the early stages. The penetration rate of mobile payments exceeds 70%, and the traditional banking network remains open to external integration.
The fintech market is not yet saturated, which means that a participant who has obtained a license for a payment system in Vietnam gets the opportunity to take a position before the large global players enter. Unlike mature but overloaded jurisdictions such as Singapore or Hong Kong, Vietnam offers real access to the client, government support and flexibility in regulation at the formation stage. At the same time, the country continues to follow the course towards a digital economy, investing in national projects, including the introduction of digital currency and the development of open-banking platforms. This opens access to the innovative ecosystem at the moment of its formation.
Advantages of opening a payment system in Vietnam :
- The centralized settlement system, the widespread use of QR payments and digital dong initiatives make the market convenient for the implementation of new solutions.
- Transparent procedure for licensing a payment system in Vietnam - the process is clearly described, the applicant gets the opportunity to officially gain access to the banking infrastructure.
- Low basic corporate tax rate - with the standard CIT being 20%, with the potential to be reduced to 10-15% if conditions are met.
- Preferential rates and tax holidays apply for projects in digital technologies, fintech, e-wallet ecosystems and API integration.
- The government systematically supports the development of digital services, creating a favorable climate for registering a payment system in Vietnam.
- Foreign founders may participate in the capital, with priority given to companies with local registration and a transparent structure.
- Geographical location and access to the ASEAN market - Vietnam is a member of many free trade agreements, which opens the way to scaling the project to Southeast Asia.
Obtaining a payment services license in Vietnam not only gives the right to conduct settlement activities, but also a strategic advantage. It is expressed in the ability to scale up across Southeast Asia through a market that is in the growth stage, but already has mature regulatory institutions.
Technological priorities: QR, open banking and digital dong
Against the backdrop of the active implementation of digital solutions, the Vietnamese market is demonstrating a rapid transition to new payment formats. The leading position is occupied by QR payments, which are supported at the national level and are actively implemented by both banks and private providers. Along with this, the open banking infrastructure is developing, which involves the use of API for direct integration of services and banking platforms.
Of particular interest is the project to introduce a central bank digital currency (CBDC). The State Bank of Vietnam has already begun testing the digital dong, and participants with valid licenses will be able to participate in the experiments. Having a permit to operate a payment platform in Vietnam gives the right to participate in pilot projects and implement new technological solutions that are in line with the country's digital development strategy.
Legislative Framework: The Basis for Regulation of Payment Services in Vietnam
The non-cash payment sector in Vietnam is regulated by a system of internal legal acts aimed at controlling financial technologies. The main provisions concern not only the registration of a legal entity, but also the processes of technical certification, reporting, protection of user funds and interaction with banks.
The key sources of regulation are Decree No. 52/2024/ND-CP, which entered into force on 1 July 2024, and Circular No. 40/2024/TT-NHNN, which entered into force on the same month. Decree No. 52/2024 covers general conditions - the status of the company, types of payment transactions, scope of liability, requirements for the corporate structure. This act determines who is entitled to apply, which services are subject to licensing, and which documents are submitted to the SBV.
Circular No. 40/2024 complements the regulation. It details the procedures for registering a payment system in Vietnam, including the composition of the document package, the application format, and the requirements for personnel. The circular includes provisions on information security, reporting procedures, and the method of storing customer funds. Together, these two documents form the complete legal framework on which a payment service provider license is issued in Vietnam.
The main regulatory body in this area is the State Bank of Vietnam (SBV). This institution has all the functions of a supervisory body in relation to non-bank payment service operators. It is the one that reviews applications, issues licenses, monitors activities and takes measures in case of violations. SBV acts on the basis of the Law on the Banking System and government regulations, retaining the exclusive right to license the payment system in Vietnam.
In practice, interaction with SBV includes preliminary approval of the service architecture, IT infrastructure verification, financial model audit, and testing of the functionality of the future platform. When applying for a license in Vietnam, the applicant must ensure compliance with not only legal but also technical requirements. Particular attention is paid to privacy policy, system resilience to failures, and physical location of servers.
Types of payment services subject to licensing
The legislation clearly distinguishes between the types of settlement activities that require a license for a payment system in Vietnam. Each area is associated with a specific transaction processing mechanism and the architecture of interaction between participants. The license is issued strictly for a specific category of services, which must be indicated in the application when submitting documents to the State Bank.
Such services provide users with the opportunity to store funds in a digital account that is not directly linked to a bank account. Wallets can be used to pay for goods, services, and transfer money to other clients. Replenishment is carried out through bank cards, terminals, or direct transfers. Licensing conditions include requirements for client identification, personal data protection, reserving client balances, and daily reporting to SBV.
Payment gateways serve as a technological interface for securely transmitting transaction data between parties — the merchant, the bank, and the buyer. They do not process funds, but provide encryption, routing, and transaction confirmation. Gateways are considered intermediary providers when licensing a payment system in Vietnam and are required to maintain compatibility with banking APIs and certified payment channels.
These platforms perform settlements between participants of the payment system, mainly legal entities. The task of the service is to aggregate data, determine the net obligations of the parties and send the results to the settlement bank. Clearing is widely used in the B2B environment - marketplaces, corporate services, aggregators. To register a payment system in Vietnam with a clearing function, it is necessary to confirm the level of automation, protection from failures and the presence of an independent settlement architecture.
This category covers transactions where payment information is transferred through international channels. The provider integrates with global payment systems — Visa, UnionPay, JCB and others — and ensures correct interaction with foreign financial operators. Even without registering a legal entity in Vietnam, such services require a license if the transactions involve Vietnamese users.
Services that accept funds from one person and transfer them to another without participating in the transaction are subject to separate regulation. This applies to both international transfers and domestic settlements between individuals. Such platforms are required to strictly comply with the rules on combating illegal income, identifying users and preserving transaction data. Obtaining a payment service license in Vietnam is mandatory for any type of such activity, even if the transactions are only carried out within the country.
Requirements for recipients of payment license in Vietnam
Before the start of the registration processes, it is necessary to determine who has the right to obtain a permit for a payment system in Vietnam, what requirements are imposed. This allows you to eliminate the risks of rejection of the application at an early stage and build a legal model that meets regulatory requirements.
Requirements for the applicant: legal entity
The applicant must be a resident company registered under the Enterprise Law. Sole proprietors and non-profit associations are not allowed. When registering a payment system in Vietnam, the company must indicate the relevant type of activity related to financial technology or provision of settlement services. In addition, the legal entity must have an office in the country and meet data management requirements, including the conditions for localization of information.
To pass the initial check, the legal structure of the company must be simple and transparent. The state bank considers the composition of the founders, the distribution of shares and the presence of affiliates. All information is verified with state registers, which makes it impossible to obtain a license through nominal schemes. Only companies with an open structure can obtain permission to operate a payment platform in Vietnam e.
Participation of foreign investors
The law allows foreign capital to participate in the founders. However, certain restrictions apply. Thus, foreign owners cannot fully control the company. They are required to take into account the established limits on the share of participation and follow the rules of currency regulation. To obtain consent to issue a payment license in Vietnam, preliminary approval for investments and compliance with the procedure for cross-border transfers are required.
In practice, foreign participants often involve a local partner to comply with formal requirements. This can be either a management structure or a qualified shareholder. This model allows for faster licensing of the payment system in Vietnam and reduces the number of legal obstacles. At the same time, the actual control over the business can be retained by the investor through corporate agreements.
Authorized capital and financial guarantees
The applicant’s financial stability is considered one of the key criteria for obtaining a payment services license in Vietnam. The main condition is the availability of paid-up authorized capital in an amount corresponding to the declared type of activity. For basic services, including e-wallets or gateways, the minimum capital is 50 to 100 billion VND (approximately 2-4 million US dollars). If the company plans to carry out financial routing (switching), international transaction routing or electronic clearing services, the authorized capital must be at least 300 billion VND, which is equivalent to about 12 million US dollars.
All funds must be deposited into the company's bank account before the application is submitted. The use of borrowed funds, temporary transfers or unsecured deposits is not permitted. The sources of origin of capital are subject to verification by the SBV, especially in the case of participation of foreign investors or multi-structure holdings.
Key figures: director and staff
The CEO of the company plays a key role in the process of obtaining a payment services license in Vietnam. The law requires that the director be a resident of the country, have a relevant education and proven experience in the field of finance or IT. He must be available for inspections and interaction with regulatory authorities. The participation of formal or technical directors is excluded.
The qualifications of the staff also affect the outcome of the application. The company must employ specialists in information security, technical support and data processing. At the same time, employees are required to undergo internal training and act in accordance with approved protocols. These parameters are included in the list of conditions that are analyzed when obtaining a payment operator license in Vietnam.
Technical infrastructure and IT base
To conduct business, you need to have your own or rented technical platform. The equipment must comply with SBV standards and support continuous operation of the service. The software is tested for resistance to external threats, scalability and correct integration with banking systems. Without meeting these requirements, it is impossible to pass the audit.
Additionally, it is necessary to provide an architectural diagram of the platform, descriptions of the protocols used, as well as copies of certificates for the technologies used. The applicant must test the system's functionality in advance and conduct an internal audit. Only after this is it allowed to submit documents for registration of a license for a payment system in Vietnam.
Control and security
Last but not least, information and operational security is a requirement. The law requires secure storage of user data, restriction of access to key functions, and backup systems. The company must comply with the rules for processing personal information and act in accordance with the provisions of the cybersecurity law.
SBV has the right to conduct unscheduled inspections, including with the participation of IT security specialists. Violation of the requirements entails suspension of activities. Therefore, even at the preparation stage, the company is obliged to implement internal regulations, conduct a risk assessment and record all procedures. This is included in the mandatory list of conditions required to obtain a license for a payment service provider in Vietnam.
Required documents for obtaining a payment license in Vietnam
Obtaining a license requires not only compliance with formal conditions, but also the collection of a voluminous package of documents. It reflects both the legal status of the company and its technical and financial capabilities. In order for the application to be accepted for consideration, all materials must be complete, up-to-date and meet the requirements of the State Bank.
- First of all, a set of constituent documents is required. This includes the organization's charter, registration certificate, decision on creation and confirmation of the type of activity related to payment services. If the system uses banking interfaces (API), copies of agreements with financial institutions are attached.
- The applicant must submit the architecture of the payment service in Vietnam - the logical scheme of the service, description of the software and server infrastructure, encryption methods used, security protocols. Additionally, the information security policy and emergency recovery regulations are submitted. If available, software certificates.
- A bank statement confirming the minimum authorized capital is required. A financial model of the company's development and documents confirming the origin of investments (especially in the case of foreign founders) are attached. For electronic wallets, confirmation of the availability of a security account is required.
- The provider must justify how the KYC and AML algorithms will be implemented. The personal data processing policy, the scheme for their protection, as well as the method of localizing all information in Vietnam are separately described.
- The company provides information about the director (a Vietnamese resident with financial or technical education and experience is required) and leading specialists. The application specifies the team structure, employee qualifications, and the presence of IT experts responsible for the stability and security of the system. When using external support, an agreement with a technical provider is required.
This list is not exhaustive, as the final requirements may depend on the type of services provided, the source of investment and the specifics of the chosen model. However, these documents form the basis without which it is impossible to begin the process of obtaining a payment service provider license in Vietnam.
Step-by-step algorithm for obtaining a payment license in Vietnam
After choosing a business model and analyzing regulatory requirements, the action phase begins. The process of obtaining a license for a payment system in Vietnam is a precise sequence. Each step is reviewed by the State Bank and must meet the established criteria.
To obtain a payment operator license in Vietnam, it is necessary to establish a legal entity. The most suitable form is considered to be a limited liability company (LLC), as it allows the participation of both individuals and legal entities, including foreign investors.
Already at this stage, it is important to lay down the correct type of activity related to the provision of financial or intermediary payment services. The authorized capital is formed simultaneously with registration. These funds must be contributed before submitting the license and confirmed by a bank statement.
The documents reflect the legal, technical and operational basis of the future service. The applicant must not only assemble a standard package, but also demonstrate to the regulator the sustainability of the business model, transparency of flows, platform security and readiness for internal control. Preparation includes the creation of regulations, description of the system, data storage models and interaction with banks.
Once the documentation is prepared, the application for a payment license in Vietnam is submitted to the State Bank of Vietnam (SBV). Both paper and electronic formats are accepted, depending on the filing structure determined for a specific category of payment services. Administrative fees stipulated by the current legislation are additionally paid. The official countdown of the review period begins from the moment of registration.
The regulator conducts a comprehensive examination of all submitted materials. The analysis covers financial stability, origin of capital, IT system architecture and composition of key specialists. Particular attention is paid to policies in the field of combating illegal income, protection of personal data and mechanisms for reserving operations.
In some cases, the State Bank initiates a technical audit of the payment platform. Such an audit may include a demonstration of the interface, server architecture, encryption systems and communication channels. This is especially relevant for services related to electronic wallets, gateways or clearing. The audit allows the regulator to ensure that the provider is ready to provide payment services in Vietnam in compliance with security, reliability and regulatory standards. Based on the results of all audits, a decision is made - to issue a permit or to return the documents with a recommendation for revision.
Once approved by the regulator, the application receives official status. SBV sends the applicant a notification of the issuance of the permit. Next, a payment service license in Vietnam is registered in the state register and receives a unique identification number. From this moment, the company is considered to be admitted to the provision of payment services and can begin operating activities in accordance with the declared functionality.
What to do after receiving permission
Obtaining a license for a payment system in Vietnam opens access to the market, but does not end the legal obligations. From this point on, regular operational activities related to connecting to the financial infrastructure, fulfilling reporting requirements and adhering to the standards of the State Bank begin.
Reporting, accounting and auditing
After obtaining a license in Vietnam, the company switches to a regular reporting regime. First of all, it is necessary to register for tax purposes and maintain financial documentation in accordance with the requirements of the Ministry of Finance. All movements of funds are recorded, and transactions are classified by type of service. Accounting is conducted in local currency, with the possibility of parallel reflection in foreign currency in case of international activity.
Every quarter and at the end of the year, reports are submitted to the State Bank. In addition to financial data, information on transactions, assets, operational stability and violations (if any) is requested. Depending on the volume of transactions and the nature of the business, the SBV may appoint unscheduled audits. These concern both the technical platform and settlement operations. Failure to submit reports may result in the suspension of the payment license in Vietnam or a warning.
Maintaining compliance with regulatory requirements
Licensing of a payment system in Vietnam is not limited to issuing a permit. Once launched, the activity must constantly comply with legal requirements and internal regulations. This concerns the protection of personal data, compliance with KYC/AML procedures, ensuring the availability of the service, as well as the relevance of the technical parameters of the platform.
The regulator monitors whether the provider has deviated from the conditions specified in the application. If the company has changed the structure, scale of the business or functionality of the service, it is necessary to notify the SBV. Any updates - in the interface, in the rules for working with clients, in the methods of integration - are subject to approval. This is especially important when introducing new functions or switching to updated protocols.
There are also requirements for staff training, internal controls and security. The SBV may request documents confirming the qualifications of employees or readiness for disaster recovery of operations. Without these mechanisms, it is impossible to maintain the status of an active provider. This is why maintaining compliance after obtaining a PI license in Vietnam becomes an ongoing management task.
Taxation of payment services in Vietnam
All companies registered in Vietnam, including digital and payment service providers, are subject to taxation at the national level. The basic corporate income tax (CIT) rate is 20%. This applies to both domestic and foreign income. However, the tax system does not use the concept of residency - if an organization is registered under Vietnamese law, it is taxed on global income.
Payment companies registered as legal entities are subject to general taxation unless they receive special incentives. Obtaining a license for a payment system in Vietnam does not in itself entail tax preferences, but it can open access to incentive regimes if additional criteria are met - for example, for investments in high-tech solutions or regional digital infrastructure.
Transactions related to the provision of payment services, depending on their nature, may be subject to VAT at rates of 0, 5 or 10%. The new regulations adopted under Law No. 48/2024/QH15 clarify the taxation of digital transactions. For foreign companies operating through e-commerce, the VAT rate will be increased from 5 to 10% from mid-2025.
Companies that have obtained a payment system license in Vietnam are required to use electronic invoices and apply the tax credit method if they operate under the full settlement model. This entitles them to deduct input VAT on purchased goods and services related to the licensed activity.
Conclusion
The process of obtaining a license for a payment system in Vietnam involves several levels of legal, technical and organizational preparation. It is necessary to establish a legal entity, ensure that the authorized capital meets the established threshold, prepare a comprehensive package of documents and pass a platform architecture review. Particular attention is paid to internal security policies, team qualifications, and the financial stability of the applicant. After submitting the documents, the State Bank conducts a comprehensive examination and makes a decision on issuing a permit. Only then can the company officially provide payment services in Vietnam. From this point on, it is obliged to comply with the control regime, maintain records and ensure the continuous operation of the platform.
To correctly complete all stages, it is recommended to involve specialists familiar with the mechanisms of payment system licensing in Vietnam. Independent legal and technological expertise will help to avoid refusal, reduce approval times and correctly build interaction with the regulator. Mistakes at an early stage can lead to a license denial or suspension in the future. Therefore, support from experienced consultants becomes not an expense, but a factor in protecting the project. This is especially important in the presence of foreign investors, a complex shareholder structure or a cross-border service architecture.