E-wallets have now been officially recognized as payment instruments equivalent to cash, bank cards, and bank accounts.

On July 17, 2024, the State Bank of Vietnam issued Circular No. 40/2024/TT-NHNN regulating the provision of intermediary payment services. Although this circular took effect overall from July 17, 2024, several key provisions specifically governing e-wallet operations will officially come into force on July 1, 2025.

Clear regulations on E-wallet top-up methods

Circular 40/2024/TT-NHNN has clarified the legitimate sources of funds for topping up e-wallets, with particular emphasis on transactions connected to banking systems or other e-wallet platforms:

– Receiving funds from Vietnamese dong accounts at domestic or foreign bank branches: E-wallet holders may now receive funds from bank accounts that are not directly linked to their wallets. This measure expands top-up capabilities and offers greater flexibility to users [Article 25, Clause 1, Point c].

– Receiving funds from external e-wallets: Notably, users are permitted to receive funds from e-wallets managed by other service providers [Article 25, Clause 1, Point d]. This regulation is expected to enhance interoperability among different e-wallet platforms.

Detailed provisions on E-wallet usage (Fund withdrawal and transfers)

In addition to top-up regulations, Circular 40/2024/TT-NHNN specifies scenarios for withdrawing or transferring funds from e-wallets to external destinations:

– Transfers to Vietnamese dong accounts at banks or foreign bank branches: E-wallet holders may transfer funds from their wallets to bank accounts not directly linked to their wallets. This provision diversifies channels for fund withdrawals and transfers [Article 25, Clause 2, Point b].

– Transfers to external e-wallets: Similar to top-up functionality, the ability to transfer funds between e-wallets managed by different service providers is formally regulated [Article 25, Clause 2, Point d]. This measure promotes connectivity and convenience within the digital payments ecosystem, enabling users to move funds seamlessly across platforms.

Regulations on payment guarantee accounts for E-wallet services

To ensure the security and liquidity of e-wallet transactions, Circular 40/2024/TT-NHNN introduces specific requirements for the use of payment guarantee accounts maintained by e-wallet service providers:

– Transfers to Vietnamese dong accounts at banks or foreign bank branches: Guarantee accounts may be used to transfer funds to Vietnamese dong accounts for lawful e-wallet activities [Article 27, Clause 3, Point b].

– Transfers to guarantee accounts of other e-wallet providers: Guarantee accounts are also authorized to transfer funds to the guarantee accounts of other e-wallet service providers [Article 27, Clause 3, Point d]. This provision supports inter-wallet settlements and ensures transparent reconciliation and clearing of funds among stakeholders.

These new regulations, effective from July 1, 2025, reflect the State Bank of Vietnam’s efforts to establish a robust and transparent legal framework for intermediary payment services. By specifying channels for topping up, withdrawing, and transferring funds between wallets, and tightening the management of payment guarantee accounts, the regulations will enhance safety, security, and convenience for users while laying the groundwork for sustainable, transparent fintech development in the future.

Relevant e-wallet service providers and banks are advised to review and adjust their operational procedures to ensure full compliance with these requirements.

According to the Vietnam Banks Association

Source: Lan Anh (An ninh tiền tệ)