Circular No. 41/2025/TT-NHNN amends and supplements certain Articles of Circular No. 40/2024/TT-NHNN on the operation of providing payment intermediary services.

CIRCULAR

Amending and supplementing certain Articles of Circular No. 40/2024/TT-NHNN on intermediary payment service activities

provisions on the operation of providing payment intermediary services

 

Pursuant to the Law on the State Bank of Vietnam No. 46/2010/QH12;

The Governor of the State Bank of Vietnam hereby promulgates this Circular amending and supplementing certain provisions of Circular No. 16/2021/TT-NHNN dated November 10, 2021 issued by the Governor of the State Bank of Vietnam on the organization of credit institutions and foreign bank branches purchasing and selling corporate bonds.

Pursuant to the Law on Anti-Money Laundering No. 14/2022/QH15;

Pursuant to Decree No. 52/2024/NĐ-CP of the Government on non-cash payments;

Pursuant to Decree No. 19/2023/NĐ-CP of the Government detailing certain provisions of the Law on Anti-Money Laundering;

Pursuant to Decree No. 26/2025/NĐ-CP of the Government stipulating the functions, tasks, powers, and organizational structure of the State Bank of Vietnam;

Pursuant to Decree No. 26/2025/NĐ-CP of the Government stipulating the functions, tasks, powers, and organizational structure of the State Bank of Vietnam;

The Governor of the State Bank of Vietnam promulgates this Circular amending and supplementing certain Articles of Circular No. 40/2024/TT-NHNN on intermediary payment service activities.provisions on the operation of providing payment intermediary services.

Article 1. Amending, supplementing, and abolishing certain Points of Article 8

1. Amending and supplementing Point a Clause 5 as follows:

"a) Provisions on measures to ensure the ability to pay for providing collection and disbursement support services such as opening a guarantee account or other security measures in accordance with the law;"

2. Abolishing Point c Clause 7.

Article 2. Amend and supplement some clauses of Article 9

1. Amending and supplementing Clause 4 as follows:

"4. Before providing services to customers, organizations that have been granted a License by the State Bank must publicly announce and update on their official website when there are changes the following contents: intermediary payment services that have been granted a License by the State Bank; forms of intermediary payment service provision by the organization; trade name or brand of intermediary payment services provided by the organization.

In case of ceasing to provide one or more intermediary payment services after being granted a License by the State Bank, the intermediary payment service provider must follow the procedures for amending and supplementing the License as stipulated in Clause 1, Article 26 of Decree No. 52/2024/NĐ-CP; publicly announce on their official website at least three months before the cessation date of one or more intermediary payment services."

2. Supplementing Clause 5a as follows:

"The intermediary payment service provider must regularly review and ensure that customers can only use funds from their bank accounts, bank cards, or e-wallets to conduct transactions through intermediary payment service applications in accordance with the law."

Article 3. Amending and supplementing Point b (ii) Clause 4 of Article 11

"(ii) In case at least one settlement member does not have sufficient balance to settle the results of electronic netting, the electronic netting host organization will only update the current electronic netting limit value previously reduced for settlement members who have sufficient balance to cover the settlement difference until the completion of low-value electronic netting through the Interbank Electronic Payment System and upon receipt of information from the State Bank confirming the completion of low-value electronic netting through the Interbank Electronic Payment System."

Article 4. Amend and supplement Point c Clause 2 Article 15

"c) Coordinate with banks to build mechanisms ensuring payment capability, at a minimum including the following contents:

(i) Mechanism for opening and maintaining a guarantee account balance and the purpose of using the guarantee account for collection and disbursement services, ensuring that it is not shared with other service guarantee accounts and other bank accounts; or

(ii) Regulations on the value of other security measures to fulfill obligations;"

Article 5. Amend and supplement some Points and Clauses of Article 18

1. Amend and supplement Point a Clause 2 as follows:

"a) In case the individual customer is a Vietnamese citizen: Citizen identification card, identity card, electronic identity card, or birth certificate for individuals under 14 years old who have not obtained an identity card;"

2. Amend and supplement Point c (i) Clause 2 as follows:

"(i) Passport or other documents proving identity issued by competent authorities abroad, for foreigners residing in Vietnam must also have an entry visa or a document substituting for a visa or a document proving exemption from entry visa;"

3. Amend and supplement Clause 3 as follows:

"3. Documents, information, data of organizational customers: Documents, information, data to verify customer identification information according to the Anti-Money Laundering Law, along with the documents, information, data of the legal representative, chief accountant, or accounting officer (if any) according to Clause 2 of this Article. In case the organization uses an electronic identity account, the electronic wallet service provider does not require providing documents, information, and data already available in the organization's electronic identity account."

Article 6. Amend and supplement some Clauses of Article 21

1. Amend and supplement Clause 2 as follows:

"2. Electronic wallet service providers shall conduct legality and compliance checks; ensure the accuracy and correctness of the documents, information, and data provided by customers; carry out customer identification verification according to laws on anti-money laundering and the following provisions:

a) For individual customers' electronic wallets:

(i) In cases where the electronic wallet owner or representative is an individual using an identity card, electronic identity card, citizen identification card (with information storage section), or digital identity, the electronic wallet service provider must meet the electronic wallet owner or their representative in person and perform identity document checks, matching biometric information of the electronic wallet owner or their representative according to Point b Clause 1 of this Circular;

(ii) In cases where the electronic wallet owner or representative is an individual using a citizen identification card (without information storage section) or birth certificate for individuals under 14 years old who have not obtained an identity card or passport, the electronic wallet service provider must meet the electronic wallet owner or their representative in person and perform identity document checks, matching biometric information of the electronic wallet owner or their representative with biometric information displayed on their identity document;

(iii) In cases where the electronic wallet owner is an individual foreigner not present in Vietnam, the electronic wallet service provider may verify customer identification information through a third party or by hiring another organization;

(iv) In cases where the representative is an organization, they shall follow the provisions of Point b of this Clause;

b) For organizational customers' electronic wallets:

(i) In cases where the electronic wallet owner is an organization established and operating in Vietnam (except as provided in c of this Clause), the electronic wallet service provider must meet the legal representative of the electronic wallet owner in person, and verify the legal representative's information according to Points a(i), a(ii), a(iii) of this Clause;

(ii) In cases where the electronic wallet owner is a foreign legal entity (except as provided in Point c of this Clause), the electronic wallet service provider may verify the legal representative's information through a third party or by hiring another organization, but the third party or organization must meet the legal representative in person and perform identity document checks, matching biometric information of the legal representative with biometric information displayed on their identity document;

c) Electronic wallet service providers are not required to comply with the provisions of Point b of this Clause for the following organizations:

(i) State agencies, public service units;

(ii) Organizations listed according to the Securities Law;

(iii) Organizations included in the Fortune Global 500 list published by Fortune Magazine in the previous year;

The electronic wallet service provider must ensure accurate verification of the electronic wallet opening customer and bear full responsibility for verifying the electronic wallet opening customer at their organization;

d) In cases where customers register transactions on the application software of the electronic wallet service, the electronic wallet service provider must check the information about the mobile number of the electronic wallet owner or their representative (for individual customers), the legal representative of the electronic wallet owner (for organizational customers) to ensure that the user's mobile number matches the information on their identity document."

2. Add Clause 6 as follows:

"6. The provisions of Clause 2 of this Article do not apply to cases of opening electronic wallets as stipulated in Article 22 of this Circular."

Article 7. Amend and supplement some points and clauses of Article 22

1. Amend and supplement Point c Clause 2 as follows:

"c) Store and preserve in full detail all customer identification documents, information, and data during the process of opening and using electronic wallets via electronic means, such as: customer identification information; biometric factors of individual wallet owners and legally authorized representatives of organizations opening electronic wallets; sound, images, video recordings, audio recordings; phone numbers registered on the application software of the electronic wallet service; unique identification information of transaction devices; transaction logs; results of biometric information verification according to the provisions of Point b Clause 1 of this Article. All information and data must be stored securely and confidentially, backed up for disaster recovery purposes, ensuring the completeness and integrity of the data to serve inspection, verification, and authentication of wallet owners during the use of electronic wallets, resolution of inquiries, complaints, disputes, and provision of information upon request from competent authorities. The storage period shall be carried out in accordance with the laws on anti-money laundering and electronic transactions."

2. Amend and supplement Clause 3 as follows:

"3. The opening of electronic wallets via electronic means does not apply to individual customers as stipulated in Clause 4 Article 18 of this Circular."

Article 8. Repeal Clause 4 of Article 24

Article 9. Amend, supplement, and repeal some points and clauses of Article 25

1. Repeal Clause 1.

2. Amend and supplement Point a, Point b Clause 2 as follows:

"a) Withdraw money from the electronic wallet to a Vietnamese dong account or a debit card linked to a Vietnamese dong account at a linked bank;

b) Transfer money to a Vietnamese dong account or a debit card linked to a Vietnamese dong account opened at a bank, foreign bank branch, except in cases provided for in Point a of this clause;"

3. Amend and supplement Clause 5 as follows:

"5. Organizations providing electronic wallet services shall not accept cash from customers to recharge electronic wallets; shall not allow customers to withdraw cash from electronic wallets at organizations providing electronic wallet services; shall not permit credit to customers using electronic wallets or pay interest on the balance of electronic wallets."

4. Amend and supplement Point d Clause 6 as follows:

"d) Apply forms of electronic transaction confirmation for each type of transaction in electronic payment according to the regulations of the State Bank on security and confidentiality for the provision of online services in the banking sector."

Article 10. Amend, supplement, and repeal some clauses of Article 26

2. Amending and supplementing Clause 5 as follows:

"1. The total transaction limit through individual electronic wallets of one customer at one organization providing electronic wallet services (including transfer and payment transactions as specified in Points b, c, d, đ Clause 2 of Article 25 of this Circular) shall not exceed 100 million Vietnamese dong in one month.

This provision does not apply to individual electronic wallets of persons who have signed contracts or agreements to become payment acceptance units with organizations providing electronic wallet services."

2. Repeal Clause 2.

3. Amend and supplement Clause 3 as follows:

"3. For individual electronic wallets of one customer at one organization providing electronic wallet services, in addition to the limits specified in Clause 1 of this Article, the organization providing electronic wallet services may set additional limits for payment transactions including: online payments on the National Public Service Portal; electricity; water; telecommunications; various fees, charges, and service fees related to road traffic activities; tuition fees; medical expenses; social insurance contributions, health insurance premiums; insurance premium payments as stipulated in the Insurance Business Law; repayment of overdue debts, interest, and other costs incurred for credit institutions, foreign bank branches according to the law; but the total limit for these payment transactions shall not exceed 300 million Vietnamese dong in one month."

Article 11. Amend, supplement, and abolish certain points of Article 27

1. Abolish Point b Clause 2.

2. Amend and supplement Point a, Point b Clause 3 as follows:

"a) Transfer money to a Vietnamese dong account or a debit card linked to a Vietnamese dong account of the electronic wallet owner at the associated bank;

b) Transfer money to a Vietnamese dong account or a debit card linked to a Vietnamese dong account at a bank or foreign bank branch (for use with the electronic wallets specified in Point b Clause 2 of this Circular);"

3. Amend and supplement Point đ Clause 3 as follows:

"đ) Make payments through banks to payment acceptance units or public service providers corresponding to transactions using electronic wallets for payment as stipulated in Point đ Clause 2 of this Circular;"

Article 12. Amend and supplement certain points of Article 28

1. Amend and supplement Point a (i) Clause 1 as follows:

"(i) Measures to check the legality and validity, and ensure the accuracy of matching between documents, information, and data in the application dossier for opening an electronic wallet; periodic checks, verifications, and updates of customer identification information during the use of the electronic wallet;"

2. Amend and supplement Point c (iii) Clause 1 as follows:

"(iii) Cases where refusal or temporary suspension of transactions specified in Clause 2 of Article 25 of this Circular via electronic means shall be applied; including cases where there are electronic wallet transactions but the customer cannot be contacted based on the contact information provided;"

Article 13. Amend and supplement certain clauses of Article 30

1. Amend and supplement Clause 2 as follows:

"2. By the 10th day of each month, electronic wallet service providers must provide the State Bank of Vietnam with information about suspected fraudulent, deceptive, or illegal electronic wallets according to Appendix No. 01 and Appendix No. 02 issued together with this Circular. The provision of information shall be done electronically following the technical connection guidelines of the State Bank of Vietnam.

In case of changes to the information in Appendices No. 01 and No. 02, electronic wallet service providers must promptly update and submit such changes to the State Bank of Vietnam; they are responsible for the truthfulness and accuracy of the information and data provided to the State Bank of Vietnam."

2. Supplement Clause 3 as follows:

"3. When conducting transactions to transfer funds between electronic wallets or between an electronic wallet and a Vietnamese dong account or a debit card linked to a Vietnamese dong account opened at a bank or foreign bank branch, the service provider serving the transaction initiator has the responsibility to provide the service provider serving the transaction beneficiary with minimum information related to the transaction initiator's information upon request, including: name of the transaction initiator; electronic wallet number or account number of the transaction initiator; registered residence address or identification number of the transaction initiator or transaction reference number (if there is no account)."

Article 14. Supplement Clause 3 of Article 32

"3. Payment intermediary service providers must notify the State Bank of Vietnam (through the Payment Department) in writing at least one month before the start of service provision."

Article 15. Amending and supplementing certain points and clauses of Article 37

1. Amending and supplementing point d of Clause 1 as follows:

"d) Updating customer information periodically or when the customer notifies changes to their information in the e-wallet opening file or when there is suspicion regarding the accuracy and completeness of previously collected customer identification information, ensuring that updated information is fully verified according to regulations and promptly updating, verifying customer identification information when determining that the customer has a high risk level based on criteria established by the e-wallet service provider. Safeguarding and storing e-wallet files and transaction documents through e-wallets in accordance with the provisions of the law;"

2. Amending and supplementing point i of Clause 1 as follows:

"i) Issuing and implementing internal regulations on opening and using e-wallets at the e-wallet service provider organization. Internal regulations must include at least the following contents:

(i) Regulations on the file, procedure, and process for opening e-wallets, including cases of opening e-wallets electronically and the opening of e-wallets for customers who are persons with disabilities, those without full civil capacity, and those who have lost or are restricted in their civil capacity;

(ii) Regulations on agreements for opening and using e-wallets;

(iii) Regulations on the use of e-wallets;

(iv) Regulations on handling inquiries, complaints, and complaint forms;

(v) Regulations on managing risks in the opening and use of e-wallets in accordance with the provisions of Clause 1 of Article 28 of this Circular;

(vi) Requiring customers to have a Vietnamese dong account opened at a bank or foreign bank branch before using the service; requiring customers to complete the linking of the e-wallet to their Vietnamese dong account and/or debit card linked to their own Vietnamese dong account in accordance with the provisions of Article 24 of this Circular;"

3. Supplementing point k into Clause 1 as follows:

"k) Guiding and publicly announcing regulations on the file, procedure, and process for opening and using e-wallets and regulations on handling inquiries, complaints, and complaint forms so that customers are aware and can comply."

4. Supplementing Clause 8 as follows:

"8. An e-wallet service provider may only use one trade name or e-wallet brand after obtaining a License from the State Bank."

5. Supplementing Clause 9 as follows:

"9. In case of changing the trade name or e-wallet brand after obtaining a License from the State Bank, the payment intermediary service provider must send a written notice to the State Bank (through the Payment Department) and publicly announce on its official website at least one month before the date of changing the trade name or e-wallet brand."

"Article 41. Responsibilities for coordination in the licensing process

1. After receiving a complete and valid file in accordance with Clause 2 of Article 24 of Decree No. 52/2024/NĐ-CP, the Payment Department shall issue a document to seek opinions from relevant Departments, Bureaus, and units within the State Bank (if necessary) in accordance with Clause 2 of this Article.

2. From the day of receiving the request document from the Payment Department:

a) Within 30 working days, the Information Technology Bureau shall provide a written opinion to the Payment Department evaluating and examining the application file, technical conditions of the organization applying for the License: the file specified in points c, d, đ (file about personnel of technical staff implementing the payment intermediary service project), h (for financial switching services, electronic settlement services), i (for international financial switching services) of Clause 2 of Article 24 of Decree No. 52/2024/NĐ-CP;

b) Within 15 working days, the Anti-Money Laundering Bureau shall provide a written opinion to the Payment Department evaluating and examining compliance with anti-money laundering laws for the application file of the organization applying for the License specified in point c of Clause 2 of Decree No. 52/2024/NĐ-CP, including general principles and internal regulations on anti-money laundering, terrorist financing, and proliferation of weapons of mass destruction;

c) Within 15 working days, relevant Departments, Bureaus, and units within the State Bank (if applicable) shall provide a written opinion to the Payment Department on matters related to their functions and responsibilities.

3. After receiving opinions from relevant Departments, Bureaus, and units within the State Bank in accordance with Clause 2 of this Article, the Payment Department shall compile opinions and handle:

a) Issuing a document requesting the organization to explain and perfect the file in cases where the file lacks sufficient information to assess compliance with Clause 2 of Article 22 of Decree No. 52/2024/NĐ-CP, requiring supplementation and perfection; or

b) Submitting a report on the examination results of the application file of the organization applying for the License to the Governor of the State Bank, sending a document to seek opinions from the Ministry of Public Security and other relevant agencies (in cases where the application file is assessed as compliant with Clause 2 of Article 22 of Decree No. 52/2024/NĐ-CP). After receiving opinions from the Ministry of Public Security and other relevant agencies, the Payment Department shall compile and submit to the Governor of the State Bank for a decision to issue the License in accordance with regulations or issue a document rejecting the issuance of the License (specifying the reasons).

4. Within 60 days from the date the State Bank issues a document requesting explanations and perfection of the file in accordance with point a of Clause 3 of this Article:

a) If the organization does not provide a document explaining and perfecting the file, the Payment Department shall submit a document returning the file to the organization to the Governor of the State Bank;

b) If the organization provides a document explaining and perfecting the file, the Payment Department shall lead the examination, seeking opinions from relevant units within the State Bank (if necessary) in accordance with the procedures stipulated in Clause 2 of this Article and handle:

(i) Report to the Governor of the State Bank for a report on the results of reviewing the application file of the organization requesting permission, send a document to seek opinions from the Ministry of Public Security and relevant agencies (in cases where the application file is assessed as meeting the provisions of Clause 2, Article 22 of Decree No. 52/2024/NĐ-CP). After receiving the opinions of the Ministry of Public Security and relevant agencies, the Payment Department will compile and submit to the Governor of the State Bank for a decision to issue a License according to regulations or send a document refusing to issue a License (specifying the reasons).

(ii) In cases where the application file is assessed as not meeting the provisions of Clause 2, Article 22 of Decree No. 52/2024/NĐ-CP, the Payment Department will report to the Governor of the State Bank on the results of reviewing the application file of the organization requesting permission, and send a document refusing to issue a License (specifying the reasons).

"1. In cases where the License has expired:

a) After receiving a complete and valid application file in accordance with Clause 1 of Article 25 of Decree No. 52/2024/NĐ-CP, the Payment Department will send a document to seek opinions from relevant Departments, Bureaus, and units under the State Bank (if necessary), the Ministry of Public Security, and relevant agencies;

b) Within seven working days from the date of receipt of the request document from the Payment Department, the Information Technology Bureau, the Anti-Money Laundering Bureau, relevant Departments, Bureaus, and units under the State Bank (if applicable) will provide their opinions in writing to the Payment Department;

c) After receiving the opinions of relevant Departments, Bureaus, and units under the State Bank, the Ministry of Public Security, and relevant agencies, the Payment Department will compile and submit to the Governor of the State Bank for a decision to reissue a License according to regulations or send a document refusing to reissue a License (specifying the reasons).

"Article 43. Responsibilities in the coordination process for amending and supplementing Licenses

1. After receiving a complete and valid application file in accordance with Clause 1 of Article 26 of Decree No. 52/2024/NĐ-CP, the Payment Department will send a document to seek opinions from relevant Departments, Bureaus, and units under the State Bank (if necessary), the Ministry of Public Security, and relevant agencies.

2. Within seven working days from the date of receipt of the request document from the Payment Department, relevant Departments, Bureaus, and units under the State Bank (if applicable) will provide their opinions in writing to the Payment Department.

3. After receiving the opinions of relevant Departments, Bureaus, and units under the State Bank, the Ministry of Public Security, and relevant agencies, the Payment Department will compile the opinions and submit to the Governor of the State Bank for a report on the application file of the organization requesting amendments and supplements to the License, and send a document refusing to amend or supplement the License (specifying the reasons).

Article 19. Amending and supplementing some clauses of Article 46

2. Amending and supplementing Clause 5 as follows:

"1. Provide information to the Banking Inspection Agency, Regional Branches of the State Bank when signs of violations or acts violating laws on providing payment intermediary services are discovered; establish administrative violation records according to the law and transfer to competent units for handling."

2. Amend and supplement Clause 3 as follows:

"3. Cooperate with the Banking Inspection Agency, Regional Branches of the State Bank in inspecting organizations providing payment intermediary services according to the law."

Article 20. Amend and supplement Clause 2 of Article 47

"2. Coordinate with the State Bank of Vietnam Inspectorate and the State Bank of Vietnam Branch in the Region in inspecting organizations providing payment intermediary services in accordance with the provisions of the law."

Article 21. Amend and supplement Article 48

"Article 48. State Bank of Vietnam Inspectorate

1. Receive information provided by the Payment Department in accordance with Clause 1 of Article 46 of this Circular and handle it in accordance with the provisions of the law.

2. The focal point for inspecting the provision of payment intermediary services by the National Payment Corporation in accordance with the provisions of the law."

Article 22. Amend and supplement Article 49

"Article 49. Anti-Money Laundering Department

Perform advisory functions and assist the Governor of the State Bank of Vietnam in state management of anti-money laundering activities related to the provision of payment intermediary services."

Article 23. Amend and supplement Clause 2 of Article 50

"2. Monitor and process the results of electronic settlement in accordance with the regulations on management, operation, and use of the Interbank Electronic Payment System."

Article 24. Amend and supplement Article 51

"Article 51. State Bank of Vietnam Branch in the Region

1. The focal point for inspecting the provision of payment intermediary services by non-bank organizations providing payment intermediary services and foreign bank branches whose main office is located within the region of the State Bank of Vietnam Branch in the Region, in accordance with the provisions of the law, except for the subjects specified in Clause 2 of Article 48 of this Circular.

2. Receive information provided by the Payment Department in accordance with Clause 1 of Article 46 of this Circular and handle it in accordance with the provisions of the law.

3. Coordinate with the Payment Department in supervising compliance with regulations on the provision of payment intermediary services."

Article 25. Replace the Appendix attached to Circular 40/2024/TT-NHNN

Replace Appendix No. 01 and Appendix No. 02 issued together with Circular 40/2024/TT-NHNN with Appendix No. 01 and Appendix No. 02 issued together with this Circular.

Article 26. Responsibility for Implementation

Heads of units under the State Bank of Vietnam, credit institutions, foreign bank branches, and organizations providing payment intermediary services are responsible for implementing this Circular.

Article 27. Implementation Provisions

1. This Circular takes effect from November 5, 2025, except as provided in Clause 2 of this Article.

2. Articles 6, 12, Clause 2, Clause 3, and Clause 4 of Article 15 of this Circular take effect from January 1, 2026./.