On July 27, 2026, the State Bank of Vietnam (SBV) released a draft decree proposing amendments to Decree No. 52/2024/ND-CP dated May 15, 2024, on non-cash payments (Decree 52). The draft decree would amend 17 of Decree 52’s 38 articles, with several key changes directly affecting providers of intermediary payment service (IPS). The key proposed changes affecting IPS providers are outlined below.
Streamlining IPS Licensing Procedures
A central objective of the draft decree is to simplify regulatory procedures for IPS providers. Notably, it would significantly reduce IPS licensing documentation requirements by removing the need to submit enterprise registration certificates, investment registration certificates, and documents evidencing the qualifications of the legal representative and general director. Instead, the SBV would retrieve this information directly from national business registration and other specialized databases, requesting additional documents only where the relevant information cannot be verified electronically or is incomplete.
The draft decree also removes the current limit of two rounds for dossier supplementation and shortens processing timelines for several IPS licensing procedures such as issuance, amendment, and reissuance of IPS licenses. The processing time for new IPS license applications would be thereby reduced from 90 to 60 working days.
In addition, several continuing IPS business conditions would be removed. For example, IPS providers would no longer be required to maintain certain representations relating to corporate restructuring or the legality of contributed capital. Likewise, the IPS project plan (đề án) would become a one-time application document rather than an ongoing licensing condition. If retained in the final decree, this change could provide IPS providers with significantly greater flexibility to implement post-licensing technology upgrades, system integrations, and corporate restructuring transactions without needing to revisit the originally approved project plan. The draft decree also removes the requirement for the SBV to consult the Ministry of Public Security before approving amendments to an IPS license.
Further, the draft decree clarifies license validity, renewal procedures, and continuing notification obligations, providing greater certainty regarding the lifecycle of IPS licenses.
Operating Conditions for IPS Providers
While reducing licensing burdens, the draft decree also introduces several targeted refinements to the ongoing regulatory framework applicable to IPS providers. The most significant supervisory reform is the introduction of a new partial license revocation mechanism, in contrast to the current framework, which only contemplates revocation of an IPS license as a whole. Under the draft decree, the SBV would be able to revoke one or more specific licensed services where the provider commits violations relating to those services, such as failing to maintain sufficient guarantee account balances for e-wallet services or repeatedly submitting inaccurate reports. This would provide the SBV with a more proportionate enforcement tool while allowing compliant business lines to continue operating.
Before launching services, providers must submit documentation demonstrating that their information system has achieved at least Level 3 security classification. While this requirement already exists under Decree 52, the draft decree clarifies the relevant documentation that must be submitted. In addition, it introduces a new obligation requiring providers to notify the SBV and submit an updated technical description if the technical solution described in their licensing dossier changes before operations commence. According to the SBV, this amendment is intended to align the regulatory framework with existing supervisory practice of reviewing the technical solution ultimately deployed before an IPS is launched.
The draft decree reinforces existing safeguards applicable to e-wallet services by clarifying that IPS providers must maintain guarantee payment accounts whose aggregate balance is at least equal to the total balance of customers’ e-wallets. It also confirms that the linking of e-wallets with customers’ payment accounts and debit cards will continue to be governed by detailed regulations issued by the SBV.
The draft decree also removes the current restriction limiting participants in a financial switching system to connecting with no more than two financial switching service providers. This amendment would provide greater flexibility in connectivity arrangements and payment infrastructure design, including for participants engaging in international financial switching activities.
Expanding Cross-Border IPS Market Access Channels
Beyond administrative simplification, the draft decree introduces several substantive amendments relevant to IPS market access and infrastructure. One notable proposal concerns foreign payment service providers seeking to collaborate with Vietnamese IPS providers. Under the current framework, foreign payment service providers can access the Vietnamese market only through contractual collaboration with commercial banks or foreign bank branches approved by the SBV to participate in the relevant international payment system. The draft decree would expand this framework by also allowing foreign providers to connect through licensed international financial switching service providers established in Vietnam, such as NAPAS, MobiFone, and any future licensed providers. According to the SBV, this amendment is intended to facilitate emerging cross-border payment models, particularly regional QR payment connectivity initiatives.
Taken together, the introduction of a framework for international financial switching services and the removal of the current two-provider connectivity cap could facilitate a more interconnected cross-border payment ecosystem and provide greater flexibility for institutions participating in international payment networks.
Outlook
The draft decree reflects an evolutionary rather than revolutionary approach to reforming Vietnam’s non-cash payment framework. By combining administrative simplification with targeted updates to the legal framework and a more refined supervisory regime, the SBV seeks to reduce regulatory friction for IPS providers while maintaining appropriate oversight. If adopted in its current form, the draft decree should improve legal certainty for IPS providers and support the continued development of Vietnam’s digital payment ecosystem.
IPS providers should review the proposed amendments carefully, particularly those affecting licensing procedures, cross-border payment arrangements, and ongoing operational compliance. Banks that collaborate with IPS providers should also consider the implications for their existing arrangements.
