Vietnam

Licensing, Authorisation & Market Access

Vietnam advanced two distinct market-access and licensing developments this cycle, one opening a narrow innovation channel and the other tightening non-bank payment-instrument conduct. Decree 94/2025/ND-CP, effective 1 July 2025, established a banking-sector regulatory sandbox limited to three use cases: credit scoring, open-API data sharing, and peer-to-peer lending. The sandbox explicitly excludes cross-border supply by foreign providers, meaning it functions as a domestic-innovation channel for licensed banks and their partners rather than a market-entry route for foreign fintech providers seeking to serve Vietnamese users from abroad. This is assessed confidence, single-sourced to specialist legal commentary, and classified at elevated impact.

Separately, and on a different regulatory track, Circular 41/2025/TT-NHNN, issued 5 November 2025, amends the existing e-wallet licensing framework set out in Circular 40/2024/TT-NHNN. Most of the amended provisions took effect immediately upon issuance, but the account-opening, customer-authentication and information-provision requirements for e-wallets, along with a new restriction limiting providers to a single trade name, do not become effective until 1 January 2026. This is also assessed confidence and elevated impact, and it applies specifically to the non-bank payment-institution and e-money-institution layer, the entities licensed as intermediary payment-service providers rather than as banks.

The bank-versus-non-bank distinction that structures this monitor's approach to licensing is directly visible in how these two instruments are scoped: the sandbox sits inside the banking-sector regulatory perimeter, while the e-wallet circular governs the non-bank PI/EMI layer. Read together, the two developments describe a market-access environment that is cautiously opening on the bank side, through a narrowly scoped sandbox, while simultaneously tightening on the non-bank side, through stricter e-wallet authentication and branding rules. Neither development changes the fundamental market-access question for a foreign payments provider seeking to enter Vietnam directly: the sandbox's foreign-provider exclusion and the e-wallet circular's domestic-licensing framework both presuppose an already-licensed or already-domestic operator rather than opening a new foreign-entry pathway.

For operators already licensed as e-wallet or intermediary payment-service providers in Vietnam, the practical compliance runway is short: the account-opening, authentication and single-trade-name provisions become effective on 1 January 2026, meaning any operator currently trading under multiple trade names, or relying on account-opening or authentication flows that do not meet the new standard, has a defined and imminent deadline to remediate.

Neither instrument was corroborated this cycle beyond a single specialist-commentary source, Tilleke & Gibbins for the sandbox decree and Indochine Counsel for the e-wallet circular, both assessed at Tier 3. That single-source basis is a sourcing characteristic of the current Vietnam dispatch rather than evidence the underlying findings are unreliable, but it means the precise mechanics beyond the headline scope and effective dates, for example the sandbox's application process or the e-wallet circular's specific authentication standards, should be read as indicative pending broader corroboration or direct retrieval of the underlying decree and circular texts.

The sandbox's narrow scope, credit scoring, open-API data sharing and peer-to-peer lending only, is consistent with a cautious regulatory posture toward financial innovation that prioritises testing specific, bounded use cases within the existing banking-licensed perimeter rather than creating a general-purpose fintech authorisation track. For a foreign payments or lending-technology provider evaluating Vietnam, the practical implication is that partnership with an already-licensed Vietnamese bank, rather than direct sandbox participation, remains the more realistic near-term market-access route, since the sandbox's foreign-provider exclusion forecloses direct participation by an offshore entity regardless of the use case it wishes to test. The single-trade-name restriction taking effect alongside the authentication rules is a conduct-and-market-structure provision as much as a licensing one: it will require any e-wallet group operating multiple consumer-facing brands under a single licence to consolidate branding ahead of the 1 January 2026 deadline, an operational change with commercial as well as compliance dimensions.

It is also worth noting what this module's findings do not cover this cycle: neither instrument addresses card-scheme rules, safeguarding of customer funds, or financial-promotions conduct, all of which sit in adjacent modules (W1b, W4) that carried no material findings for Vietnam this cycle and are accordingly silent in this dispatch.

Outlook

The most consequential open question for this module is whether the Decree 94 sandbox's scope will be expanded in a future cycle to cover cross-border supply, which would represent a materially different market-access signal for foreign providers than the current domestic-only scope. Separately, the 1 January 2026 effective date for Circular 41's e-wallet provisions is the nearest-term compliance checkpoint in this module, and the next cycle's dispatch should confirm whether affected e-wallet providers achieved compliance with the single-trade-name and authentication requirements by that date, or whether enforcement or transitional relief followed.

Payment Corridor Dynamics

Vietnam's cross-border payment-corridor network expanded materially this cycle, anchored by NAPAS's completion of QR-payment connectivity with Weixin Pay. Delivered jointly by NAPAS, BIDV and Weixin Pay, the linkup is the third major Chinese platform to connect with NAPAS's network in 2026, following UnionPay and Alipay, and NAPAS and its partners have publicly framed the milestone as targeting a combined addressable user base in excess of one billion. This finding is held at high confidence given direct trade-press corroboration and is classified at high impact.

The Weixin Pay connection sits within a broader pattern that NAPAS itself has confirmed: the operator states it has completed bilateral QR connectivity with Thailand, Laos, Cambodia and China, alongside a separately launched Vietnam-Singapore cross-border QR service. The Vietnam-China corridor specifically has been built in stages, an Alipay-side linkup with Vietcombank and Ant International launched on 3 April 2026, followed by the Weixin Pay linkup this cycle, with reciprocal UnionPay-side outbound connectivity targeted for ongoing rollout. Both the Alipay-stage and Weixin Pay-stage findings are independently sourced, the former to Vietnam Briefing commentary and the latter to a combination of trade press and NAPAS's own official channel, the latter a Tier-2 source that materially strengthens confidence in the overall corridor-expansion pattern.

The Vietnam-Singapore leg follows a similar structure: NAPAS's own official announcement confirms the cross-border QR payment service has launched, with the outbound, Vietnam-to-Singapore leg planned as the next phase of the partnership. Taken together, the Thailand, Laos, Cambodia, China and Singapore linkages describe a payments infrastructure strategy that treats regional and cross-border QR interoperability as a core growth vector rather than an incidental feature, and the tempo of announcements, three within a matter of months, indicates this is an active and accelerating build-out rather than a mature, settled network.

Architecturally, these are scheme-to-scheme and switch-to-switch connections, NAPAS acting as Vietnam's national payments switch in partnership with commercial banks on the Vietnamese side, and the major domestic wallet and card platforms, UnionPay, Alipay, Weixin Pay and Singapore's equivalent schemes, on the counterparty side. This is bank-and-scheme-anchored infrastructure rather than a non-bank payment-institution access channel, and the corridor risk and settlement questions that follow from that structure are different from those that would apply to a non-bank cross-border remittance or e-money corridor.

The reciprocal, inbound-then-outbound sequencing visible across both the China and Singapore corridors, inbound connectivity launching first, with outbound flagged as a subsequent phase, suggests a deliberate rollout discipline on NAPAS's part: proving inbound scan-to-pay functionality for foreign visitors and platforms before extending Vietnamese consumers' own outbound spending capability. That sequencing has a plausible commercial logic, inbound tourist and cross-border consumer spend is more immediately monetisable for Vietnamese merchants and platforms than outbound Vietnamese consumer spending abroad, though this cycle's evidentiary record does not directly confirm that rationale and it should be read as an inference from the observed pattern rather than a stated NAPAS objective.

Sourcing quality across this module's findings is mixed but improving: the Thailand, Laos, Cambodia, China and Singapore confirmations rest partly on NAPAS's own official Tier-2 channel rather than solely on Tier-3 trade press, which is a stronger evidentiary basis than is typical for this jurisdiction's other modules this cycle, and it is the primary reason this module's overall confidence is held at High rather than Assessed.

Outlook

Two specific forward legs are flagged directly in NAPAS's own material: a reverse-direction, Vietnam-to-China outbound QR connectivity leg following the Weixin Pay inbound launch, and the Vietnam-to-Singapore outbound leg following the inbound launch earlier in 2026. Both are loosely targeted for the fourth quarter of 2026, though the China-outbound leg is held at low confidence given its single-source basis while the Singapore-outbound leg is held at assessed confidence given NAPAS's own official confirmation. The corridor-dynamics module should be watched next cycle for confirmation of either outbound leg actually launching, and for whether NAPAS extends the same bilateral-QR model to additional source markets beyond the five already connected.

Industry Structure & Commercial Dynamics

Vietnam established its first banking-sector fintech regulatory sandbox this cycle. Decree No. 94/2025/ND-CP, effective 1 July 2025, covers credit scoring, Open API data-sharing and peer-to-peer lending, with the peer-to-peer lending vertical carrying specific safeguards: exposure caps, use of Credit Information Centre data, routing through licensed accounts, and a two-year term cap. Participation in the sandbox is formalised through a Certificate of Sandbox Participation, and cross-border testing is explicitly excluded from the framework's scope. This exclusion, read alongside the 49 percent foreign-ownership cap set for crypto-asset service provider licensees under the parallel Decision 96/QD-BTC framework, signals a continued protectionist calibration of market-access structure even as Vietnam's fintech and digital-asset product scope expands under new licensing regimes. The structural effect is that Vietnam is building formal regulatory infrastructure for innovation (sandbox participation, licensing pathways) while keeping foreign participation and cross-border testing constrained at the perimeter.

Outlook

Watch for the first cohort of sandbox participants and any early findings from the credit-scoring, Open API or peer-to-peer lending pilots, and for whether the foreign-ownership and cross-border exclusion settings are revisited in the pending amendment to Decree 52/2024 and Circular 41/2024.

Product Innovation & Market Development

VietQRGlobal, a joint NAPAS-Payoo product, launched this cycle as a dedicated inbound cross-border QR payment product aimed at foreign visitors to Vietnam. The product was introduced at Digital Finance Day 2026 in Ho Chi Minh City in June 2026, and the launch was demonstrated live using Alipay-side scanning, allowing a foreign visitor to pay a Vietnamese merchant by scanning a VietQR code with their home-market Alipay app rather than requiring the visitor to hold a Vietnamese bank account or e-wallet. This is assessed confidence, sourced to Vietnam Briefing commentary, and classified at elevated impact.

VietQRGlobal is distinct from, and sits on top of, the underlying scheme-to-scheme connectivity agreements tracked separately under this monitor's payment-corridor-dynamics module: those agreements establish the technical and commercial interoperability between NAPAS and counterparty schemes such as Alipay, UnionPay and Weixin Pay, while VietQRGlobal is the merchant-facing product layer that packages that connectivity into a usable inbound-payment experience for foreign visitors and the Vietnamese merchants accepting their payments. The distinction matters for how this development should be read: it is a specific, discrete product launch rather than a structural market-access or licensing change, which is why it is tracked here under product innovation rather than under licensing or corridor dynamics.

The choice to demonstrate the launch using Alipay-side scanning specifically, rather than a generic or hypothetical foreign wallet, signals that the product's initial and most immediate commercial target is Chinese inbound visitor and consumer spend, consistent with the broader pattern of NAPAS's cross-border QR corridor build-out this cycle prioritising Chinese platform connectivity. Whether VietQRGlobal will be extended to accept scanning from Singapore, Thai, Lao or Cambodian wallets and apps, the other markets with which NAPAS has confirmed bilateral QR connectivity, was not addressed in this cycle's sourcing and remains an open product-development question.

Product launches of this kind sit at the intersection of this monitor's product-innovation and commercial-intelligence framing: a specific, named, dated product launch such as VietQRGlobal is squarely a W9 finding under this cycle's module-spec guidance, distinguishing it from a structural market-wide trend, which would instead be tracked as a W6 industry-structure finding, or a discrete disclosed commercial transaction, which would be a W13 commercial-intelligence finding. No W13-qualifying discrete deal or investment round was identified for Vietnam this cycle, and no W6 structural market-concentration finding was identified either, leaving VietQRGlobal as this cycle's sole product-innovation finding for the jurisdiction.

The product's technical premise, that a foreign visitor's home-market wallet can scan a Vietnamese merchant's standard VietQR code without the visitor opening a local account, is itself the more significant innovation than the specific Alipay demonstration: it implies VietQRGlobal is designed as a platform-agnostic acceptance layer that could, in principle, extend the QR-scanning experience to any wallet with which NAPAS establishes underlying scheme connectivity, rather than being an Alipay-specific integration that would need to be rebuilt for each new partner wallet. This cycle's sourcing does not confirm the technical architecture directly, however, and this reading should be treated as an inference from the demonstrated product behaviour rather than a confirmed technical fact.

Commercially, the timing of the launch alongside the Weixin Pay corridor completion and the earlier Alipay corridor launch suggests VietQRGlobal is being positioned as the retail-facing complement to NAPAS's wholesale scheme-connectivity build-out, converting corridor-level interoperability into a visible, marketed consumer product rather than leaving the connectivity purely as back-end infrastructure.

Outlook

The clearest forward signal for this module is whether VietQRGlobal's merchant and foreign-wallet acceptance is extended beyond the Alipay-side demonstration to the other platforms NAPAS has connectivity with, Weixin Pay, UnionPay, and the Thailand, Laos, Cambodia and Singapore corridors, which would convert the product from a single-platform demonstration into a genuinely multi-market inbound-payments product. Next cycle's dispatch should also confirm merchant-acceptance uptake data for VietQRGlobal, which was not available this cycle, since that data point would be the clearest evidence of the product's commercial traction beyond the launch demonstration itself.