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

Tilleke & Gibbins has contributed the Vietnam chapter to Fintech 2027, a global guide published by Lexology Panoramic that provides comparative insights into the legal and regulatory frameworks governing fintech businesses across multiple jurisdictions. The Vietnam chapter offers a comprehensive overview of the country’s rapidly evolving fintech landscape, examining both the regulatory environment and practical considerations for businesses operating in or entering the Vietnamese market. Topics covered include: Fintech landscape and initiatives: General innovation climate; government and regulatory support Financial regulation: Regulatory bodies; regulated activities; consumer lending; secondary market loan trading; collective investment schemes; alternative investment funds; peer-to-peer and marketplace lending; crowdfunding; invoice trading; payment services; open banking; robo-advice; insurance products; credit references Cross-border regulation: Passporting; requirement for a local presence Sales and marketing: Restrictions on the promotion and marketing of financial products and services Cryptoassets and tokens: Distributed ledger technology; cryptoassets; token issuance Artificial intelligence: Regulatory framework governing AI systems and AI-enabled financial services Change of control: Notification and consent requirements for regulated businesses Financial crime: Anti-bribery and anti-money laundering procedures; regulatory guidance Data protection and cybersecurity: Data protection obligations; cybersecurity requirements applicable to fintech businesses Outsourcing and cloud computing: Outsourcing of material functions; use of cloud computing in the financial services industry Intellectual property rights: IP protection for software; employee- and contractor-created IP; joint ownership; trade secrets; branding; remedies for infringement Competition: Competition law issues affecting fintech businesses Tax: Incentives for innovation and investment; developments affecting tax and compliance obligations Immigration: Immigration options for recruiting skilled foreign personnel; special measures available through Vietnam’s international financial centers The chapter also examines a number of significant recent developments shaping Vietnam’s fintech sector, including the introduction of the country’s first comprehensive regulatory framework for cryptoassets, the adoption of a dedicated law on artificial intelligence, implementation of the banking regulatory sandbox,

Vietnam has introduced an official list of high-risk AI systems, triggering more stringent compliance obligations for developers, suppliers, and deployers operating in the country. On June 30, 2026, the prime minister issued Decision No. 33/2026/QD-TTg (Decision 33), which establishes the List of High-Risk AI Systems under the Law on Artificial Intelligence (AI Law) and Decree No. 142/2026/ND-CP (Decree 142). Decision 33 takes effect on August 15, 2026. Decision 33 is significant because only AI systems included on the list will be subject to the heightened compliance obligations applicable to high-risk AI systems under the AI Law and Decree 142. These include, among others, local presence requirements for foreign providers, mandatory conformity assessment before deployment, comprehensive risk management and data quality documentation, and strict liability for damages even when the provider is fully compliant. Decision 33 also specifies the applicable conformity assessment pathway for each listed system, indicating whether the system must undergo mandatory third-party conformity certification before being placed into use, or whether the provider may self-assess conformity or voluntarily engage a registered or recognized conformity assessment body. Which AI Systems Are Covered? Decision 33 identifies high-risk AI systems across six sectors—the key attributes of which are summarized below. Education: AI systems used for automated assessment, learner ranking, behavioral monitoring, or generating educational content from uncontrolled data sources. Ethnic affairs and religion: AI systems used to automatically score, classify, or rank applications for government ethnic policies; approve or reject regulatory applications; suspend benefits on suspicion of fraud; allocate budgets; or infer and classify individuals by ethnicity or religion for administrative purposes. Healthcare: AI-assisted surgical systems and autonomous AI-powered surgical robots. Banking: AI systems that autonomously conduct electronic banking transactions or make credit approval decisions. Judicial proceedings: Certain large-scale biometric identification systems used in public-interest civil proceedings. Transport: Thirty-one categories

Vietnam’s AI regulatory framework has reached an important milestone. While the Law on Artificial Intelligence No. 134/2025/QH15 (AI Law) established the foundation for AI governance, many practical compliance requirements were left to implementing regulations. On April 30, 2026, the government issued Decree No. 142/2026/ND-CP (Decree 142), which took effect on May 1, 2026, and provides the first detailed guidance on the implementation of the AI Law. Although an official list of high-risk AI systems is still pending from the prime minister, Decree 142 provides valuable insight into how Vietnam’s risk-based AI regulatory framework will operate in practice. Risk Classification Framework The AI Law adopts a risk-based approach under which AI systems are classified as high-risk, medium-risk, or low-risk. Decree 142 builds on this framework by providing detailed guidance on how these classifications are determined. High-risk AI systems are determined based on factors such as (i) their potential impact on life, health, property, human rights, public interests, or national security; (ii) the sector in which they are deployed; and (iii) the scale of affected users or integration with critical infrastructure. The latest draft list of high-risk AI systems appears to follow these same principles. Medium-risk AI systems generally include systems that may mislead, influence, or manipulate users, particularly where users may not realize they are interacting with AI or AI-generated content. The focus is therefore on transparency and authenticity risks rather than broader societal or safety concerns. Low-risk AI systems are those that do not meet the criteria for either high-risk or medium-risk classification. Importantly, Decree 142 seeks to avoid over-classification. Certain systems may fall outside the high-risk or medium-risk regimes, including internal-use systems, office-support tools, technical editing applications, certain back-end processing systems, and AI systems used in artistic, gaming, cinematic, or other creative contexts. Providers must also review and