Vietnam

Overview

Vietnam's digital payment landscape features a critical distinction between two categories: e-wallets (operating since the early 2010s under SBV licensing) and telco-based mobile money (authorized on a pilot basis only in 2021 under Decision 316). E-wallets like MoMo, ZaloPay, and VNPay dominate non-cash retail payments, while telco mobile money pilots by Viettel Money, VNPT Money, and MobiFone Money remain early-stage. Vietnam has ~100 million people, a young smartphone-connected population, and a government "cashless society" objective -- yet cash remains dominant for most retail. As of 2023, there were an estimated 40-50 million active e-wallet accounts (unverified), with MoMo, ZaloPay, and VNPay holding the largest shares.

Regulatory Environment

The State Bank of Vietnam (SBV) is the primary regulator of payment services. Vietnam regulates digital payments under Decree 101/2012/ND-CP (amended by Decree 80/2016/ND-CP) governing non-cash payments and intermediary payment services, Circular 39/2014/TT-NHNN providing detailed licensing guidance, and Decision 316/QD-TTg (2021) authorizing a two-year pilot for telco mobile money, allowing licensed operators to offer small-value payment services linked to mobile accounts without requiring a bank account.

E-wallet providers must obtain an Intermediary Payment Service License from the SBV. Telco mobile money operators are approved under Decision 316 with oversight from the SBV and the Ministry of Information and Communications.

KYC: e-wallet users must link to a bank account or provide national ID verification; mobile money pilot users verify against national ID databases with lower transaction and balance limits. Maximum e-wallet balance is VND 100 million (~USD 4,000, unverified).

Recent: the mobile money pilot was extended in 2023 (unverified); the SBV has been drafting revisions to the non-cash payment decree framework to modernize regulations for e-wallets, QR payments, and open banking.

Payments Infrastructure

NAPAS (National Payment Corporation of Vietnam), owned by the SBV and commercial banks, operates interbank transfer switching, the Napas domestic debit card network, and VietQR -- the national standardized QR code system enabling interbank and e-wallet QR payments. VietQR adoption has grown rapidly at merchants and for P2P transfers, with QR codes widely displayed at small businesses and restaurants in urban areas.

E-wallet interoperability remains limited. MoMo users cannot directly transfer to ZaloPay accounts and vice versa. However, wallets connect to bank accounts through NAPAS, enabling indirect fund flows. The SBV has signaled intent to improve interoperability.

E-Wallets vs. Telco Mobile Money

E-Wallets

MoMo (M_Service) -- Founded 2007; app-based since 2014. Services: P2P, bills, QR merchant, online payments, financial product distribution (insurance, investment), ride-hailing/food delivery integration. Claimed over 31 million users (unverified, 2023). Widely cited as Vietnam's largest e-wallet by active users and transaction frequency.

ZaloPay (VNG Corporation) -- Launched 2017. P2P, bills, QR, online payments, integration with Zalo messenger (Vietnam's dominant messaging platform with 70M+ users). Among top 3 e-wallets.

VNPay / VNPAY-QR -- Operating since ~2015 primarily as a B2B payment technology provider; VNPAY-QR codes are widely displayed at merchants but transactions typically process through partner bank apps. Largest QR acceptance network by merchant count (unverified).

ShopeePay (SeaMoney / Sea Group) -- Launched ~2019 as embedded payment within Shopee Vietnam. Significant within the Shopee ecosystem.

Telco Mobile Money (2021 Pilot)

Decision 316, signed March 2021, authorized a pilot program allowing licensed telcos to provide mobile money services, designed to extend financial services to the unbanked in rural areas.

• Viettel Money (Viettel Group, state-owned, Vietnam's largest telco) -- Launched 2021, leverages Viettel's nationwide network and agent distribution.
• VNPT Money (VNPT Group, state-owned) -- Launched 2021, limited adoption.
• MobiFone Money (MobiFone, state-owned) -- Launched 2021, limited adoption.

Mobile money accounts under Decision 316 have a maximum balance of VND 10 million (~USD 400) and monthly limits of VND 100 million. Accounts do not require a bank account, distinguishing them from e-wallets. Adoption has been slower than projected, as e-wallets and bank apps already serve most digitally active users; the pilot's primary impact has been in rural and underserved areas where e-wallet penetration is low.

Market Summary

Financial Inclusion & Impact

According to World Bank Global Findex (2021), approximately 31% of Vietnamese adults had a financial institution account (unverified). The government's National Financial Inclusion Strategy targets 80% of adults. Despite rapid e-wallet growth, cash remains dominant in traditional markets (cho), rural commerce, and small-value daily transactions.

The Vietnamese government has promoted non-cash payments through the 2016 national plan (Decision 2545/QD-TTg), the 2021 mobile money pilot for financial inclusion, salary payment via bank transfer, and COVID-19's accelerating effect on e-commerce and food delivery.

Challenges: e-wallets require smartphones and bank accounts (telco mobile money addresses this partially); fragmented ecosystem with limited interoperability creates friction; deep cash culture persists among older demographics and in traditional commerce; and the evolving regulatory framework creates compliance complexity.

Timeline

• 2012 -- Decree 101/2012/ND-CP establishes legal framework for non-cash payments
• 2014 -- MoMo launches app-based e-wallet
• 2015 -- VNPay begins expanding QR acceptance
• 2016 -- Government publishes cashless payment promotion plan
• 2017 -- ZaloPay launches
• 2019 -- ShopeePay enters Vietnam; QR adoption accelerates
• 2021 -- Decision 316 authorizes telco mobile money pilot; Viettel Money, VNPT Money, and MobiFone Money launch
• 2022 -- VietQR adoption expands rapidly
• 2023 -- Mobile money pilot extended; SBV continues payment regulation modernization