Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the State Bank's licence, including banking and payment rails.
Get a payment license in Vietnam.
Vietnam rewrote its payment rules in Decree 52/2024/ND-CP, in force since 1 July 2024, and put six services under a single intermediary payment services licence issued by the State Bank of Vietnam. Charter capital is VND 50 billion for e-wallets, collection and disbursement support and payment gateways, and VND 300 billion for switching, international switching and electronic clearing. The regulator confirms a complete dossier in five working days, allows two supplements inside sixty days, then appraises for ninety working days. The licence runs ten years and the service has to launch within six months of the grant.
27 yrs
on the international marketon the market
60+
in-house specialistsspecialists
400+
Licenses obtainedlicenses obtained
Updated
Vietnam in brief
One licence, six services, two capital tiers and a clock written into the decree.
Decree 52/2024/ND-CP on non-cash payment was signed on 15 May 2024 and took effect on 1 July 2024, replacing Decree 101/2012 and Decree 80/2016. It sits under the Law on Credit Institutions of 2024 and the Law on the State Bank, and Circular 40/2024/TT-NHNN, effective 17 July 2024, carries the operating detail. Article 22(1) lists six intermediary payment services under one licence: financial switching, international financial switching, electronic clearing, e-wallet, collection and disbursement support, and payment gateway. The old electronic money transfer support service was dropped. Article 22(2)(b) sets paid-in charter capital at VND 50 billion for the e-wallet, collection and disbursement support and payment gateway services, and at VND 300 billion for the three switching and clearing services, and a switching or clearing provider may carry on no other line of business. There is no registration tier beneath the licence. A Vietnamese product either holds the State Bank's authorisation or works through a bank.
The clock in Articles 23 and 24 rewards a file that is right the first time. The regulator has five working days to confirm the dossier is complete; the applicant may then supplement it at most twice, within a total of sixty days; appraisal takes ninety working days from the completed file. The licence runs ten years, renewed on an application filed at least sixty days before expiry and decided in thirty working days. Service must start within six months of the grant, and technical readiness is proved at least thirty working days before launch. For wallets, Article 6(3) requires the payment-assurance account at the partner bank to hold at all times no less than the total balance of every wallet issued, and Article 25(5) of Circular 40/2024 forbids cash top-ups, credit to wallet users and interest on wallet balances. No statutory balance cap exists: the provider fixes limits per customer segment. Corporate tax is 20%, dropping to 15% below VND 3 billion of revenue and 17% up to VND 50 billion, with VAT at 10% on financial services. We run the file from Dubai and plan on nine to twelve months.
Decree 52/2024/ND-CP, in force 1 July 2024, puts six intermediary payment services under one State Bank licence. Charter capital is VND 50 billion for wallet, gateway and collection services and VND 300 billion for switching and clearing. Five working days to the completeness check, two supplements inside sixty days, ninety working days of appraisal.
The licence runs ten years and the service must launch within six months. Wallets carry no statutory cap, no cash top-up, no credit and no interest, and the payment-assurance account must cover every wallet balance. Tax 20%, VAT 10%. Nine to twelve months realistic. We run it from Dubai.
The routes
One authorisation, priced at two levels.
The decree does not split payment businesses into licence classes. It splits them by capital: VND 50 billion for the customer-facing services, VND 300 billion for the infrastructure ones. We fix the service list first, then build once.
One authorisation, priced at VND 50 billion or VND 300 billion by service.
01 - WALLET, GATEWAY, COLLECTION
Dịch vụ ví điện tử, cổng thanh toán, hỗ trợ thu hộ chi hộ
The three customer-facing services under Article 22(1) on VND 50 billion of paid-in charter capital - e-wallet, collection and disbursement support, and payment gateway - with the payment-assurance account at a partner bank and wallets linked to the customer's own account.
The three customer-facing services under Article 22(1) on VND 50 billion of paid-in charter capital - e-wallet, collection and disbursement support, and payment gateway - with the payment-assurance account at a partner bank and wallets linked to the customer's own account.
- ✓E-wallet, payment gateway, collection and disbursement support
- ✓Charter capital VND 50,000,000,000 (Article 22(2)(b))
- ✓Payment-assurance account covering all wallet balances
- ✓No cash top-up, no credit, no interest (Circular 40/2024)
- ✓Limits set by the provider, not by the decree
- ✓Licence for 10 years, launch within 6 months
02 - SWITCHING AND CLEARING
Capital - VND 300 billionChuyển mạch tài chính, chuyển mạch quốc tế, bù trừ điện tử
The infrastructure services on VND 300 billion of charter capital, with the additional conditions of Article 22(2)(g): reach across the banking system, at least twenty connected providers, level-4 information-system security and capacity for ten million transactions a day.
Switching and clearing: VND 300 billion capital, no other business, level-4 security, 10 million transactions a day, at least 20 connected providers.
- ✓Financial switching, international switching, electronic clearing
- ✓Charter capital VND 300,000,000,000 (Article 22(2)(b))
- ✓No other line of business permitted
- ✓Banks holding over 65% of banking-system charter capital
- ✓At least 20 connected intermediary providers
- ✓Level-4 security · 10 million transactions a day
Costs and timelines are confirmed for your case before any work begins. Decree 52/2024 sets no foreign-ownership cap - the 49% figure discussed at draft stage is not in the enacted text - and no licence fee amount is published, so state charges are itemised in your quote once the regulator confirms them.
Why Vietnam
A hundred-million market on a decree that prints its own deadlines.
Vietnam is the largest wallet market in mainland Southeast Asia and the rules were rewritten two years ago. Six reasons founders pick it, and the honest limits of each.
✓
One licence, six services
Article 22(1) puts switching, international switching, clearing, wallets, collection and disbursement support and gateways under a single authorisation, so a product can widen without a second application.Widen without a second application.
✓
A deadline in the text
Five working days to the completeness notice and ninety working days of appraisal are printed in Article 24, not offered as a service standard.90 working days in Article 24.
✓
Ten-year term
The licence runs ten years under Article 24(5) and is re-issued for another ten on an application filed sixty days before expiry.Re-issued for ten more.
✓
No wallet cap
The decree sets no statutory balance or monthly ceiling. Article 25(6)(a) leaves the limits to the provider's own risk rules and customer agreement.Provider sets its own limits.
✓
No ownership cap in the enacted text
The 49% foreign-ownership limit discussed while the decree was in draft did not survive into Decree 52/2024. The enacted text prints none.The 49% draft figure was dropped.
✓
NAPAS and the interbank system
Retail switching runs through NAPAS and settlement through the State Bank's Inter-bank Electronic Payment System; connection is planned with the licence rather than after it.Retail switching and interbank settlement.
How it compares
How Vietnam differs from its ASEAN neighbours.
Vietnam asks for more capital than Thailand and less domestic control than Indonesia, and it is the only one of the four with no printed wallet ceiling. The honest comparison is below.
Vietnam vs other jurisdictions
| Feature |  Vietnam | Other jurisdictions |
|---|---|---|
| Capital | VND 50bn or 300bn by service | Tiered floors, often lower |
| Licence tiers | One licence, no registration below it | Small or registered routes common |
| Wallet cap | None in the decree | Printed ceilings across ASEAN |
| Licence term | 10 years, renewable | Perpetual or annual elsewhere |
Capital
VietnamVND 50bn or 300bn by service
Other jurisdictionsTiered floors, often lower
Licence tiers
VietnamOne licence, no registration below it
Other jurisdictionsSmall or registered routes common
Wallet cap
VietnamNone in the decree
Other jurisdictionsPrinted ceilings across ASEAN
Licence term
Vietnam10 years, renewable
Other jurisdictionsPerpetual or annual elsewhere
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Vietnam | Intermediary payment services (SBV) | 20% · VAT 10% | VND 50bn / 300bn · 10-year licence |
 Indonesia | PJP licence (Bank Indonesia) | 22% · VAT 11% effective | IDR 15bn / 5bn / 500m · 51% domestic control |
 Thailand | Licence / registration (BOT · MOF) | 20% · 15% small | THB 100M e-money · 60 business days |
 Philippines | EMI (BSP) | 25% · 20% small | PHP 100-200M · trust at least 50% |
VietnamLicense typeIntermediary payment services (SBV)
Taxation20% · VAT 10%
RequirementsVND 50bn / 300bn · 10-year licence
IndonesiaLicense typePJP licence (Bank Indonesia)
Taxation22% · VAT 11% effective
RequirementsIDR 15bn / 5bn / 500m · 51% domestic control
ThailandLicense typeLicence / registration (BOT · MOF)
Taxation20% · 15% small
RequirementsTHB 100M e-money · 60 business days
PhilippinesLicense typeEMI (BSP)
Taxation25% · 20% small
RequirementsPHP 100-200M · trust at least 50%
Before you apply
Requirements for the SBV licence.Requirements for the licence.
Article 22 sets the conditions, Article 23 the dossier and Article 24 the procedure; Circular 40/2024 adds the operating rules. The checklist below is what a passing file contains.
01
A Vietnamese organisation that is not a bank or a foreign bank branch, holding an establishment licence or enterprise registration certificate and not undergoing division, merger, conversion, dissolution or bankruptcy.
02
Paid-in charter capital of VND 50 billion for the e-wallet, collection and disbursement support or payment gateway services, or VND 300 billion for financial switching, international switching or electronic clearing.
03
A single line of business where the application covers switching or electronic clearing - Article 22(2)(a) bars those providers from any other activity.
04
A legal representative and general director with a university degree in economics, business administration, law or information technology and at least five years as a manager or executive in finance or banking.
05
Deputy directors, department heads and technical staff holding at least a college degree in those same fields, none of them disqualified persons.
06
A technical solution statement approved by the competent body, describing the system the licence will run on.
07
For wallet services, a payment-assurance account at a bank or foreign bank branch whose total balance never falls below the total balance of the wallets issued.
08
Product rules matching Circular 40/2024: wallets linked to the customer's own VND account or debit card, no cash top-ups, no credit and no interest on balances.
09
A dossier in Vietnamese, two sets plus six data copies, with foreign documents consularised and translated before filing.
10
A launch plan that starts the service inside six months of the grant, with technical readiness notified to the regulator at least thirty working days beforehand.
01
Vietnamese non-bank organisation, clean corporate status.
02
Capital VND 50bn or VND 300bn, paid in.
03
Switching and clearing: no other business.
04
Director with degree and 5 years in finance.
05
Key staff with college degrees in the named fields.
06
Technical solution statement approved.
07
Payment-assurance account covering all wallets.
08
Wallets linked; no cash, credit or interest.
09
Dossier in Vietnamese, 2 sets and 6 data copies.
10
Launch within 6 months; 30 working days' notice.
Reflects Decree 52/2024/ND-CP (signed 15 May 2024, in force 1 July 2024) and Circular 40/2024/TT-NHNN (17 July 2024), read in the Official Gazette, as of 2026.Decree 52/2024/ND-CP (1 July 2024) and Circular 40/2024/TT-NHNN (17 July 2024).
How it works
From first call to the SBV licence.
01
Service list and capital
Which of the six services you need, and therefore whether charter capital is VND 50 billion or VND 300 billion - fixed in writing with the budget.VND 50bn or 300bn - in writing.
02
Company and funding
Vietnamese company formed or adjusted, charter capital paid in, management documented to the degree and experience the decree names.Formed, paid, management documented.
03
The dossier
Two sets and six data copies in Vietnamese, foreign documents consularised, technical solution statement approved - complete before filing.Two sets, six data copies, Vietnamese.
04
Completeness and appraisal
Five working days to the completeness notice, at most two supplements inside sixty days, then ninety working days of appraisal.5 working days, then 90.
05
Licence and launch
Fee paid within fifteen working days of grant, technical readiness notified thirty working days before launch, service live inside six months.Fee in 15 days; live inside 6 months.
Quick facts
RegulatorState Bank of Vietnam
LawDecree 52/2024 · Circular 40/2024
LicenceIntermediary payment services
CapitalVND 50bn · VND 300bn
Appraisal90 working days
Licence term10 years
Timeline9-12 months realistic
Corporate tax20% · VAT 10%
Two supplements inside sixty days is the whole margin the decree gives you. A dossier that survives the completeness check without using them is what keeps the appraisal on its ninety-working-day track.
Your Vietnam desk
Run from our Asia-Pacific desk.
Prifinance - Asia-Pacific desk
Dubai · coordinating Vietnamese mandates
33 Level, Al Saqr Business Tower, Dubai
01
Vietnamese company formation
A company with charter capital paid to the Article 22 figure and an enterprise registration certificate clean of any division, merger or conversion.Charter capital paid to the Article 22 figure.
02
The SBV dossier
Two paper sets and six data copies in Vietnamese, foreign documents consularised, the technical solution statement approved - drafted by us and defended through the two permitted supplements.Vietnamese, consularised, two supplements.
03
Bank account and rails
The payment-assurance account opened at the partner bank before launch, and NAPAS and interbank settlement planned with the licence.Payment-assurance account; NAPAS.
04
Substance in Vietnam
A legal representative and general director who meet the degree and five-year test, plus the technical staff the decree names.Director, deputies, technical staff.
We also have offices in
Tallinn
Estonia
Roseni 13
Vilnius
Lithuania
Gedimino pr. 2
Prague
Czech Republic
Vlkova 532/8, Žižkov
London
United Kingdom
7 Bell Yard
Madeira
Portugal
Rua da Alegria 31, 1F
Budapest
Hungary
Korányi Sándor u. 4
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of payment companies in Vietnam.
A 20% corporate rate with two lower brackets for small revenue, VAT at 10% on financial services, and one figure the tax authority does not publish.
Corporate tax 20%
The standard rate under the 2025 Corporate Income Tax Law, in force since 1 October 2025. Revenue up to VND 3 billion is taxed at 15% and revenue up to VND 50 billion at 17%.15% and 17% brackets below VND 50bn.
VAT 10%
The standard rate. The two-point cut to 8% running to the end of 2026 expressly excludes finance, banking, securities and insurance, so payment services stay at 10%.The 8% cut excludes finance.
A relief for 2026 and 2027
Enterprises with revenue up to VND 10 billion get a 30% reduction in corporate income tax for the 2026 and 2027 tax years.30% cut under VND 10bn revenue.
Dividends to non-residents
The withholding rate on dividends paid to non-resident corporate shareholders is not published on the official sources we can read, so it is confirmed in writing for your structure.Rate not published; confirmed per case.
Payroll
Personal income tax and social insurance on Ho Chi Minh City or Hanoi salaries; the operating budget prices them with the technical staff the decree requires.Income tax + social insurance.
Licence fee
Payable under the law on fees and charges within fifteen working days of the grant. The amount is not published, so it enters the quote once the regulator states it.Due in 15 working days; amount unpublished.
Tax summary
Corporate tax20% · 15% and 17% brackets
Small-revenue relief30% cut for 2026-2027 under VND 10bn
VAT10% on financial services
Dividend withholdingNot published on official sources
PayrollIncome tax + social insurance
Licence feeAmount not published
*Figures as of 2026 per the Corporate Income Tax Law 67/2025/QH15 and the VAT Law 48/2024/QH15. Positions not printed by the authorities are confirmed per structure.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: Vietnamese company, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, licensed provider.
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The Vietnamese payment licence, answered.
What licence does a payment business need in Vietnam?+
One licence: the intermediary payment services licence granted by the State Bank of Vietnam under Decree 52/2024/ND-CP. Article 22(1) covers six services under it - financial switching, international switching, electronic clearing, e-wallet, collection and disbursement support, and payment gateway. There is no lighter registration tier beneath it.
How much capital is required?+
Article 22(2)(b) sets paid-in charter capital at VND 50 billion for the e-wallet, collection and disbursement support and payment gateway services, and at VND 300 billion for financial switching, international switching and electronic clearing. No ongoing own-funds ratio is prescribed on top of it.
How long does the State Bank take?+
Five working days to confirm the dossier is complete, then up to two supplements within a total of sixty days, then ninety working days of appraisal. With drafting, translation and consularisation, plan on nine to twelve months from first call to launch.
How long does the licence last?+
Ten years from the date of grant under Article 24(5). Re-issue is applied for at least sixty days before expiry with three sets of documents and decided within thirty working days, and the new licence again runs ten years.
How are wallet balances protected?+
Article 6(3) requires the provider to keep the total balance across its payment-assurance accounts at a bank no lower than the total balance of all wallets it has issued. A wallet may be used only where it is linked to the customer's own payment account or debit card.
Are there limits on a wallet balance?+
No statutory cap. Article 25(6)(a) of Circular 40/2024 makes the provider set the scope of use and the transaction limits for each customer segment in its own risk rules and the customer agreement. The circular does prohibit cash top-ups, credit to wallet users and any interest on balances.
Can foreigners own a Vietnamese provider?+
The enacted decree prints no foreign-ownership cap. The 49% limit discussed while Decree 52/2024 was in draft is not in the final text. Investment approvals for the specific structure are still checked before the corporate work starts.
What does the licence cost?+
A fee is payable under the law on fees and charges, at the State Bank, within fifteen working days of the grant under Article 4 of Circular 40/2024. The amount is not published on the sources we can read, so we confirm it in writing before it goes into the budget.
What do the switching licences require beyond capital?+
Article 22(2)(g) adds a reach test: the system must serve banks holding over 65% of the banking system's total charter capital and at least twenty intermediary payment service providers, meet level-4 information-system security and handle at least ten million payment transactions a day. A participant may connect to no more than two switching or clearing providers.
Why Vietnam rather than Indonesia or Thailand?+
Vietnam is the bigger wallet market of the three and the only one whose rules print no balance ceiling, and its capital sits between the other two. Indonesia asks for less capital at the entry tier but requires 51% domestic control; Thailand decides in sixty business days and asks THB 100 million for e-money. Groups that need scale first license here.
Which licence?+
SBV intermediary payment services licence, six services.
Capital?+
VND 50 billion or VND 300 billion by service.
How long?+
90 working days appraisal; 9-12 months realistic.
Licence term?+
10 years, renewable; launch within 6 months.
Client funds?+
Payment-assurance account covering all wallets.
Wallet cap?+
None in the decree; provider sets limits.
Foreign ownership?+
No cap in the enacted decree.
Fee?+
Due in 15 working days; amount not published.
Switching extras?+
65% of bank capital, 20 providers, level 4.
vs Indonesia / Thailand?+
Bigger market, no wallet ceiling.
Client notes
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the State Bank of Vietnam or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.