Vietnam: Pilot program for mobile money ̶ a government initiative toward a cashless society and financial inclusion

In brief

On 9 March 2021, the Prime Minister issued Decision No. 316/QD-TTg, which takes immediate effect, to allow a pilot program for mobile money service (MMS), under which telecommunication accounts can be used to make payment for small value transactions. The pilot program will run for two years from the first enterprise being approved to pilot the MMS, and the result of the pilot program will be used by regulators to design concrete legislation.

The MMS pilot program is designed to encourage financial inclusion and promote a cashless society, and rural, mountainous and remote areas will be prioritized for implementation. MMS can only be provided for payment of legal domestic transactions in Vietnamese dong, and payment for goods and services provided on a cross-border basis is not allowed.


In more detail

Enterprises eligible to apply for the pilot program must be either a qualified enterprise that has a license to provide e-wallet intermediary payment service and a license to establish a ground public telecommunication network using radio frequency bands, or a subsidiary that is allowed to use telecommunications infrastructure, network and data by its parent company who has a license to establish a ground public telecommunication network using radio frequency bands.

An individual customer can register to use MMS by providing their ID or passport number that matches the information registered for the mobile number that has been used continuously for at least three consecutive months before the registration of the MMS. Basically, mobile money account is used as follows:

  • The MMS enterprise must open payment guarantee account at banks and ensure that the balance in the payment guarantee accounts is not less than the total balance of all the mobile money accounts at the same time.
  • For account collection/withdrawal: via cash at trading locations, via bank account of the mobile money accountholder, and via e-wallet account of the mobile money accountholder opened at the MMS enterprise
  • For money transfer: between mobile money accounts of different customers of the same MMS enterprise, between mobile money account of the customer and bank account of the customer, and between mobile money account of the customer and e-wallet account of the customer opened at the MMS enterprise
  • For payment: payment of goods and services to payment acceptance units using mobile money account
  • Total transaction value limit for withdrawals, transfers and payments: VND 10 million per month per mobile money account

In order to apply for the pilot program, applicants must submit a dossier to the State Bank of Vietnam (SBV). A key highlight of the application dossier is that the applicant must provide an MMS plan that details the processes regarding business operation, payment guarantee mechanism, know-your-customer, anti-money laundering, selecting and managing trading locations, managing payment acceptance units, information technology system, responsibility towards customers, internal check and control, and risk assessment and handling. That said, the requirements to join the pilot program are extensive and subject to the SBV's approval on a case-by-case basis.

Contact Information

© 2021 Baker & McKenzie. Ownership: This site (Site) is a proprietary resource owned exclusively by Baker McKenzie (meaning Baker & McKenzie International and its member firms, including Baker & McKenzie LLP). Use of this site does not of itself create a contractual relationship, nor any attorney/client relationship, between Baker McKenzie and any person. Non-reliance and exclusion: All information on this Site is of general comment and for informational purposes only and may not reflect the most current legal and regulatory developments. All summaries of the laws, regulation and practice are subject to change. The information on this Site is not offered as legal or any other advice on any particular matter, whether it be legal, procedural or otherwise. It is not intended to be a substitute for reference to (and compliance with) the detailed provisions of applicable laws, rules, regulations or forms. Legal advice should always be sought before taking any action or refraining from taking any action based on any information provided in this Site. Baker McKenzie, the editors and the contributing authors do not guarantee the accuracy of the contents and expressly disclaim any and all liability to any person in respect of the consequences of anything done or permitted to be done or omitted to be done wholly or partly in reliance upon the whole or any part of the contents of this Site. Attorney Advertising: This Site may qualify as “Attorney Advertising” requiring notice in some jurisdictions. To the extent that this Site may qualify as Attorney Advertising, PRIOR RESULTS DO NOT GUARANTEE A SIMILAR OUTCOME. All rights reserved. The content of the this Site is protected under international copyright conventions. Reproduction of the content of this Site without express written authorization is strictly prohibited.