Circular 41/2025/TT-NHNN amend Circular 40/2024/TT-NHNN on provision of payment intermediary services

CIRCULAR

Amending and supplementing a number of articles of Circular No. 40/2024/TT-NHNN on provision of payment intermediary services

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

Pursuant to the Law on Credit Institutions No. 32/2024/QH15;

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

Pursuant to the Government's Decree No. 52/2024/ND-CP on cashless payment;

Pursuant to the Government’s Decree No. 19/2023/ND-CP detailing a number of articles of the Anti-Money Laundering Law;

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

At the proposal of the Director of the Payment Department;

The Governor of the State Bank of Vietnam hereby promulgates the Circular amending and supplementing a number of articles of Circular No. 40/2024/TT-NHNN on provision of payment intermediary services.

Article 1. Amending, supplementing, and annulling a number of points of Article 8

1. To amend and supplement Point a, Clause 5 as follows:

“a) Regulations on measures to ensure solvency in providing collection and payment support services, such as opening payment guarantee accounts or adopting other measures to secure the performance of obligations in accordance with law;”

2. To annul Point c, Clause 7.

Article 2. Amending and supplementing a number of clauses of Article 9

1. To amend and supplement Clause 4 as follows:

“4. Prior to providing services to customers, an organization licensed by the State Bank shall publicly disclose, and update upon any change, the following information on its official website: payment intermediary services licensed by the State Bank; forms of provision of payment intermediary services by the organization; trade name or brand name of the organization’s payment intermediary services.

In the event of termination of provision of one or more payment intermediary services after being licensed by the State Bank, the payment intermediary service provider shall carry out procedures for modification of the License as prescribed in Clause 1, Article 26 of Decree No. 52/2024/ND-CP; and publicly disclose such termination on its official website no later than 03 months prior to the date of termination of provision of one or more payment intermediary services.”

2. To add Clause 5a as follows:

“The payment intermediary service provider shall regularly review and ensure that customers may only use funds from payment accounts, bank cards, or e-wallets to perform payment transactions on browsers or applications providing payment intermediary services in accordance with law.”

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

“(ii) In case at least one settlement member fails to maintain a sufficient balance for the settlement of electronic clearing results, the organization in charge of electronic clearing shall only update the portion of the electronic clearing limit value previously reduced for those settlement members that have sufficient settlement balances for the payment of electronic clearing results, calculated up to the time of completion of the low-value clearing settlement through the interbank electronic payment system and upon receipt of information from the State Bank confirming the completion of low-value clearing settlement through the interbank electronic payment system.”

Article 4. Amending and supplementing Point c, Clause 2, Article 15

“c) To coordinate with the partner bank in establishing a solvency assurance mechanism, which shall, at a minimum, include the following contents:

(i) The mechanism for opening and maintaining payment guarantee accounts and the purpose of using such payment guarantee accounts for collection and payment support services, ensuring that such accounts are not shared with payment guarantee accounts for other services or with other payment accounts opened at the partner bank; or

(ii) Regulations on the value of other measures to secure the performance of obligations;”

Article 5. Amending and supplementing a number of points and clauses of Article 18

1. To amend and supplement Point a, Clause 2 as follows:

“a) In the case of an individual customer who is a Vietnamese citizen: Citizen identity card, identity card, or electronic identity card; or birth certificate for persons under 14 years of age who do not possess an identity card;”

2. To amend and supplement Point c(i), Clause 2 as follows:

“(i) Passport or other identity document issued by a competent foreign authority; in case of a foreign national residing in Vietnam, an entry visa, a valid document in lieu of a visa, or a document evidencing visa exemption shall be required; or”

3. To amend and supplement Clause 3 as follows:

“3. For institutional customers: Documents, information, and data for verification of customer identification in accordance with the Anti-Money Laundering Law, together with documents, information, and data of the lawful representative, chief accountant, or person in charge of accounting (if any), as prescribed in Clause 2 of this Article. Where the institution uses an electronic identification account, the e-wallet service provider shall not require the submission of documents, information, and data already contained in such electronic identification account.”

Article 6. Amending and supplementing a number of clauses of Article 21

1. To amend and supplement Clause 2 as follows:

“2. E-wallet service providers shall inspect the legality and validity of, and verify the accuracy and consistency among, the documents, information, and data provided by customers; and shall verify customer identification information in accordance with the law on anti-money laundering and the following provisions:

a) For e-wallets of individual customers:

(i) Where the e-wallet holder or his/her representative uses an identity card, electronic identity card, or citizen identity card (with information storage component) or electronic identity, the e-wallet service provider shall meet the e-wallet holder or his/her representative in person, inspect and compare the identity document, and verify the biometric information of the e-wallet holder or his/her representative in conformity with the provisions of Point b, Clause 1, Article 22 of this Circular;

(ii) Where the e-wallet holder or his/her representative is an individual using a citizen identity card without information storage component, or a birth certificate, for persons under 14 years of age without an identity card or passport, the e-wallet service provider must meet the e-wallet holder or his/her representative in person, check and compare the identity document, and verify that the biometric information of the e-wallet holder or his/her representative matches the biometric information displayed on his/her identity document;

(iii) Where the e-wallet holder is a foreign individual not present in Vietnam, the e-wallet service provider may verify the customer identification information through a third party or by hiring another organization;

(iv) Where the representative is an organization, the provisions of Point b of this Clause shall apply;

b) For e-wallets of institutional customers:

(i) Where the e-wallet holder is an organization established and operating in Vietnam (except cases specified at Point c of this Clause), the e-wallet service provider shall meet in person the lawful representative of the e-wallet holder and verify the information of such lawful representative in accordance with the provisions of Points a(i), a(ii), and a(iii) of this Clause;

(ii) Where the e-wallet holder is a foreign legal entity (except cases specified at Point c of this Clause), the e-wallet service provider may verify information of the lawful representative’s e-wallet holder through a third party or by hiring another organization, provided that such third party or organization meets the lawful representative of the e-wallet holder in person and inspects and compares the identity document, verifying that the biometric information of the lawful representative matches the biometric information displayed on his/her identity document;

c) E-wallet service providers shall not be required to comply with Point b of this Clause with respect to the following organizations:

(i) State agencies and public non-business units;

(ii) Organizations listed in accordance with the Law on Securities;

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

E-wallet service providers must ensure accurate verification of customers opening e-wallets and bear full responsibility for identification of customers opening e-wallets at their entities.

d) Where a customer registers to conduct transactions via the e-wallet application software, the e-wallet service provider shall verify the phone number information of the e-wallet holder or his/her representative (for individual customers), or the lawful representative of the e-wallet holder (for institutional customers), ensuring that the subscriber’s user information matches the information on the person’s identity document.”

2. To add Clause 6 as follows:

“6. The provisions of Clause 2 of this Article shall not apply to the opening of e-wallets as prescribed in Article 22 of this Circular.”

Article 7. Amending and supplementing a number of points and clauses of Article 22

1. To amend and supplement Point c, Clause 2 as follows:

“c) Storing and preserving complete and detailed customer identification documents, information, and data during the opening and use of e-wallets by electronic means, including customer identification information; biometric factors of individual e-wallet holders and lawful representatives of institutional e-wallet holders; audio, images, video and voice recordings; registered phone numbers on the e-wallet service application software; unique identification information of the transaction device; transaction logs; and results of biometric information verification as prescribed at Point b, Clause 1 of this Article. Information and data shall be securely and confidentially stored, backed up, and preserved to ensure data sufficiency and integrity for the purposes of inspection, verification, and authentication of e-wallet holders during the process of e-wallet use; handling of tracing, complaints, and disputes; and provision of information upon request by competent authorities. The storage period shall comply with the law on anti-money laundering and the law on e-transactions.”

2. To amend and supplement Clause 3 as follows:

“3. The opening of e-wallets by electronic means shall not apply to individual customers as prescribed in Clause 4, Article 18 of this Circular.”

Article 8. Annulling Clause 4, Article 24.

Article 9. Amending, supplementing and annulling a number of points and clauses of Article 25

1. To annul Clause 1.

2. To amend and supplement Points a and b, Clause 2 as follows:

“a) Withdrawing funds from the e-wallet to the e-wallet holder’s VND account or debit card linked to the VND account at the affiliated bank;

b) Transferring funds to a VND account or a debit card linked to a VND account opened at a bank or a foreign bank branch, except as provided at Point a of this Clause;”

3. To amend and supplement Clause 5 as follows:

“5. E-wallet service providers shall not receive cash from customers for loading funds into e-wallets; shall not permit customers to withdraw cash from e-wallets at e-wallet service providers; and shall not grant credit to e-wallet users or pay interest on e-wallet balances.”

4. To amend and supplement Point d, Clause 6 as follows:

“d) Applying forms of electronic transaction authentication for each type of electronic payment transaction in accordance with the State Bank's regulations on safety and security for the provision of online banking services.”

Article 10. Amending, supplementing, and annulling a number of clauses of Article 26

1. To amend and supplement Clause 1 as follows:

“1. The total transaction limit through all personal e-wallets of one customer at one e-wallet service provider (including money transfer and payment transactions as prescribed at Points b, c, d, and dd, Clause 2, Article 25 of this Circular) shall not exceed VND 100,000,000 (one hundred million Vietnamese dong) per month.

This provision shall not apply to personal e-wallets of individuals who have entered into a contract or agreement with the e-wallet service provider to act as payment-accepting units.”

2. To annul Clause 2.

3. To amend and supplement Clause 3 as follows:

“3. For personal e-wallets of one customer at one e-wallet service provider, in addition to the limit prescribed in Clause 1 of this Article, the e-wallet service provider may establish additional limits for payment transactions, including: online payments via the National Public Service Portal; payments for electricity, water, and telecommunications services; fees, charges, and service payments related to road motor vehicle transportation; tuition fees; hospital fees; payments of social insurance and health insurance; payment of insurance premiums in accordance with the Law on Insurance Business; and repayment of due or overdue debts, interest, and other costs payable to credit institutions and foreign bank branches as prescribed by law; provided that the total limit for these payment transactions shall not exceed VND 300,000,000 (three hundred million Vietnamese dong) per month.”

Article 11. Amending, supplementing, and annulling a number of points of Article 27

1. To annul Point b, Clause 2.

2. To amend and supplement Points a and b, Clause 3 as follows:

“a) Transferring funds to the VND account or debit card linked to the VND account of the e-wallet holder at the affiliated bank (for the use of e-wallets as prescribed at Point a, Clause 2, Article 25 of this Circular);

b) Transferring funds to the VND account or debit card linked to the VND account at a bank or foreign bank branch (for the use of e-wallets as prescribed at Point b, Clause 2, Article 25 of this Circular);”

3. To amend and supplement Point dd, Clause 3 as follows:

“dd) Making payments through banks to payment-accepting units or public service providers corresponding to transactions made via e-wallets for payment purposes as prescribed at Point dd, Clause 2, Article 25 of this Circular;”

Article 12. Amending and supplementing a number of points of Article 28

1. To amend and supplement Point a(i), Clause 1 as follows:

“(i) Measures to inspect the legality and validity, and to verify the consistency and accuracy, of documents, information, and data in customers’ e-wallet opening dossiers; and measures for periodic inspection, comparison and re-verification of customer identification information during the process of e-wallet use;”

2. To amend and supplement Point c(iii), Clause 1 as follows:

“(iii) Cases in which refusal or suspension of electronic transactions prescribed in Clause 2, Article 25 of this Circular shall be applied, including cases where e-wallets have payment transactions but the customer cannot be contacted through the contact information provided by such customer;”

Article 13. Amending and supplementing a number of clauses of Article 30

1. To amend and supplement Clause 2 as follows:

“2. No later than the 10^th day of each month, e-wallet service providers shall, at the request of the State Bank, provide information on e-wallets suspected of involvement in fraud, scams, or other violations of law in accordance with Appendix No. 01 and Appendix No. 02 to this Circular. The provision of information shall be carried out by electronic means in accordance with the technical connection guidance provided by the State Bank.

In case of any changes to the information in Appendix No. 01 and Appendix No. 02, e-wallet service providers shall promptly update and send such changes to the State Bank; and shall take responsibility for the truthfulness and accuracy of the information and data provided to the State Bank.”

2. To add Clause 3 as follows:

“3. When conducting fund transfers between e-wallets or between e-wallets and VND accounts or debit cards linked to VND accounts opened at banks or foreign bank branches, the service provider serving the originator shall, upon request, provide to the service provider serving the beneficiary the minimum information related to the transaction originator, including: name of the originator; e-wallet number or account number of the originator; permanent registered address or identification number of the originator, or transaction reference number (if no account is available).”

Article 14. Adding Clause 3 to Article 32

“3. A payment intermediary service provider shall send a written notification to the State Bank (through the Payment Department) no later than 01 month prior to the commencement of service provision.”

Article 15. Amending and supplementing a number of points and clauses of Article 37

1. To amend and supplement Point dd, Clause 1 as follows:

“dd) To periodically update customer information, or upon the customer’s notification of any change in the information stated in the e-wallet opening dossier, or when there is doubt regarding the accuracy or completeness of the previously collected customer identification information, ensuring that updated information is fully verified in accordance with regulations; and to promptly update and verify customer identification information upon determining that the customer is of high risk according to criteria established by the e-wallet service provider. To preserve and store e-wallet dossiers and all transaction documents via e-wallets in accordance with the law;”

2. To amend and supplement Point i, Clause 1 as follows:

“i) To promulgate and implement internal regulations on the opening and use of e-wallets at the e-wallet service provider. Internal regulations must include, at a minimum, the following contents:

(i) Regulations on dossiers, order, and procedures for e-wallet opening, including cases of e-wallet opening by electronic means and cases of e-wallet opening for customers who are persons with disabilities, persons lacking civil act capacity, or persons with lost or restricted civil act capacity;

(ii) Regulations on reaching an agreement on opening and use of e-wallets;

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

(iv) Regulations on handling inquiries, complaints, and request form for inquiry and complaint;

(v) Regulations on risk management in the opening and use of e-wallets in conformity with Clause 1, Article 28 of this Circular;

(vi) Requirements that customers must have VND accounts opened at banks or foreign bank branches before using the service; and requirements that customers must complete the linkage of their e-wallets with their own VND accounts and/or debit cards linked to such VND accounts in accordance with Article 24 of this Circular;”

3. To add Point k to Clause 1 as follows:

“k) To provide guidance and publicly disclose regulations on dossiers, order, and procedures for the opening and use of e-wallets, as well as regulations on tracing and complaint settlement and the form of request for tracing and complaint settlement, for customers’ awareness and compliance.”

4. To add Clause 8 as follows:

“8. An e-wallet service provider shall use only one trade name or brand name for its e-wallet service after being granted a License by the State Bank.”

5. To add Clause 9 as follows:

“9. In the event of a change in the trade name or brand name of the e-wallet service after being granted a License by the State Bank, the payment intermediary service provider shall send a written notification to the State Bank (through the Payment Department) and publicly disclose such change on its official website no later than 01 month before the change of trade name or brand name of the e-wallet.”

Article 16. Amending and supplementing Article 41

“Article 41. Responsibilities for coordination in the licensing process

1. Upon receipt of a complete and valid dossier as prescribed in Clause 2, Article 24 of Decree No. 52/2024/ND-CP, the Payment Department shall issue a written request for opinions from relevant Departments, Authorities, or units under the State Bank (if deemed necessary) in accordance with Clause 2 of this Article.

2. From the date of receipt of the written request from the Payment Department:

a) Within 30 working days, the Information Technology Department shall provide its written opinion to the Payment Department, assessing and appraising the dossier and the technical conditions of the organization applying for the License, including: the dossiers specified at Points c, d, and dd (personnel dossiers of technical officers implementing the scheme on provision of payment intermediary services),
Point h (for financial switching and electronic clearing services), Point i (for international financial switching services), and Clause 2, Article 24 of Decree No. 52/2024/ND-CP;

b) Within 15 working days, the Anti-Money Laundering Department shall provide its written opinion to the Payment Department, assessing and appraising the compliance of the applicant’s dossier with the law on anti-money laundering as prescribed at Point c, Clause 2, Article 24 of Decree No. 52/2024/ND-CP, including general principles and internal regulations on anti-money laundering, counter-terrorism financing, and financing of proliferation of weapons of mass destruction;

c) Within 15 working days, other relevant Departments, Authorities, or units under the State Bank (if any) shall provide their written opinions to the Payment Department on matters related to their respective functions and duties.

3. After receiving opinions from the relevant Departments, Authorities, or units under the State Bank in accordance with Clause 2 of this Article, the Payment Department shall consolidate and process as follows:

a) Issue a written request for the organization to provide explanations or to complete the dossier in case the dossier lacks sufficient information to assess compliance with the provisions of Clause 2, Article 22 of Decree No. 52/2024/ND-CP and needs supplementation or completion; or

b) Submit to the Governor of the State Bank a report on the appraisal results of the applicant’s dossier and issue a written request for opinions from the Ministry of Public Security and other relevant agencies (in cases where the application dossier is assessed as meeting the requirements under Clause 2, Article 22 of Decree No. 52/2024/ND-CP). After obtaining opinions from the Ministry of Public Security and other relevant agencies, the Payment Department shall consolidate the results and submit them to the Governor of the State Bank for a decision on licensing or for issuance of a written reply to the applicant refusing the License, clearly stating the reasons therefor.

4. Within 60 days from the date on which the State Bank issues a written request for explanation or completion of the dossier as prescribed at Point a, Clause 3 of this Article:

a) In case the organization fails to provide a written explanation or to complete the dossier, the Payment Department shall submit to the Governor of the State Bank for issuance of a written notice returning the dossier to the organization;

b) In case the organization provides a written explanation and completes the dossier, the Payment Department shall act as the focal point to conduct the appraisal, solicit opinions from relevant units under the State Bank (if necessary) in accordance with the process prescribed in Clause 2 of this Article, and handle as follows:

(i) Submit to the Governor of the State Bank a report on the appraisal results of the applicant’s dossier and issue a written request for opinions from the Ministry of Public Security and other relevant agencies (in cases where the application dossier is assessed as meeting the requirements under Clause 2, Article 22 of Decree No. 52/2024/ND-CP). After obtaining opinions from the Ministry of Public Security and other relevant agencies, the Payment Department shall consolidate the results and submit them to the Governor of the State Bank for a decision on licensing or for issuance of a written reply to the applicant refusing the License, clearly stating the reasons therefor;

(ii) In cases where the application dossier is assessed as not meeting the requirements under Clause 2, Article 22 of Decree No. 52/2024/ND-CP, the Payment Department shall submit to the Governor of the State Bank a report on the appraisal results of the applicant’s dossier and issue a written reply to the organization refusing the License, clearly stating the reasons therefor.”

Article 17. Amending and supplementing Clause 1, Article 42

“1. In case of expiration of the License:

a) Upon receipt of a complete and valid dossier as prescribed in Clause 1, Article 25 of Decree No. 52/2024/ND-CP, the Payment Department shall issue a written request for opinions from relevant Departments, Authorities, or units under the State Bank (if deemed necessary), the Ministry of Public Security, and other relevant agencies;

b) Within 07 working days from the date of receipt of the written request from the Payment Department, the Information Technology Department, the Anti-Money Laundering Department, and other relevant Departments, Authorities, or units under the State Bank (if any) shall provide their written opinions to the Payment Department;

c) After receiving opinions from the relevant Departments, Authorities, or Units under the State Bank, the Ministry of Public Security, and other relevant agencies, the Payment Department shall consolidate the results and submit them to the Governor of the State Bank for a decision on re-issuance of the License as prescribed, or issue a written reply to the organization refusing the re-issuance of the License, clearly stating the reasons therefor.”

Article 18. Amending and supplementing Article 43

“Article 43. Responsibilities for coordination in the process of modification of the License

1. Upon receipt of a complete and valid dossier as prescribed in Clause 1, Article 26 of Decree No. 52/2024/ND-CP, the Payment Department shall issue a written request for opinions from relevant Departments, Authorities, or units under the State Bank (if deemed necessary), the Ministry of Public Security, and other relevant agencies.

2. Within 07 working days from the date of receipt of the written request from the Payment Department, the relevant Departments, Authorities, or units under the State Bank (if any) shall provide their written opinions to the Payment Department.

3. After receiving opinions from the relevant Departments, Authorities, or units under the State Bank, the Ministry of Public Security, and other relevant agencies, the Payment Department shall consolidate the opinions and submit to the Governor of the State Bank a report on the dossier of the organization requesting modification of the License, and issue a written reply to the organization refusing the modification of the License, clearly stating the reasons therefor.

Article 19. Amending and supplementing a number of clauses of Article 46

1. To amend and supplement Clause 1 as follows:

“1. To provide information to the State Bank Inspectorate and the SBV Regional branches upon detection of signs of violation or acts in breach of the law on provision of payment intermediary services; to make records of administrative violations in accordance with law and transfer such records to the competent units for handling.”

2. To amend and supplement Clause 3 as follows:

“3. To coordinate with the State Bank Inspectorate and the SBV Regional branches in the inspection of payment intermediary service providers in accordance with law.”

Article 20. Amending and supplementing Clause 2, Article 47

“2. To coordinate with the State Bank Inspectorate and the SBV Regional branches in the inspection of payment intermediary service providers in accordance with law.”

Article 21. Amending and supplementing Article 48

“Article 48. The State Bank Inspectorate

1. To receive information provided by the Payment Department in accordance with Clause 1, Article 46 of this Circular, and to review and handle such information in accordance with law.

2. To act as the focal point for the inspection of payment intermediary service activities of the National Payment Corporation of Vietnam in accordance with law.”

Article 22. Amending and supplementing Article 49

“Article 49. The Anti-Money Laundering Department

To perform the advisory function and assist the Governor of the State Bank in exercising state management over anti-money laundering activities related to the provision of payment intermediary services.”

Article 23. Amending and supplementing Clause 2, Article 50

“2. To monitor and process electronic clearing results in accordance with regulations on management, operation, and use of the interbank electronic payment system.”

Article 24. Amending and supplementing Article 51

“Article 51. The SBV Regional branches

1. To act as the focal point for the inspection of payment intermediary service activities conducted by payment intermediary service providers that are not banks or foreign bank branches and have their head offices located within the jurisdiction of the SBV Regional branches, in accordance with law, except for the entity specified in Clause 2, Article 48 of this Circular.

2. To receive information provided by the Payment Department in accordance with Clause 1, Article 46 of this Circular, and to review and handle such information in accordance with law.

3. To coordinate with the Payment Department in inspecting compliance with regulations on payment intermediary service provision activities.”

Article 25. Replacing Appendices to Circular No. 40/2024/TT-NHNN

To replace Appendix No. 01 and Appendix No. 02 to Circular No. 40/2024/TT-NHNN with Appendix No. 01 and Appendix No. 02 promulgated together with this Circular.

Article 26. Implementation responsibility

Heads of units under the State Bank, credit institutions, foreign bank branches, and payment intermediary service providers shall organize the implementation of this Circular.

Article 27. Implementation provisions

1. This Circular takes effect from November 05, 2025, except for the cases specified in Clause 2 of this Article.

2. Provisions of Article 6, Article 12, and Clauses 2, 3, and 4, Article 15 of this Circular shall take effect on January 01, 2026./.