Vietnam’s fintech sector continues to attract significant foreign capital, driven by the rapid expansion of digital payments and supportive government policies. Despite this growth, the sector presents significant regulatory challenges, particularly regarding strict licensing requirements.

In this legal update, Hung Phi Law Firm provides a guide on Foreign investment in Vietnam’s fintech and intermediary payment services (IPS) to clarify market access conditions and assist clients in navigating the complex statutory procedures.

1. Overview of foreign investment in Vietnam’s fintech & IPS sector

 Vietnam’s fintech & IPS: Investment overview

1.1. Legal framework for Vietnam’s fintech and intermediary payment services (IPS) sector

The foreign investment activities in Vietnam’s fintech and payment intermediary sector are governed by a comprehensive regulatory framework, including international treaties and domestic legislation as follows:

– WTO Schedule of Specific Commitments;

– The Vietnamese Law on Investment 2025;

– The Vietnamese Law on Enterprises 2020;

– The Vietnamese Law on Credit Institutions 2024; 

– The Vietnamese Law on Cybersecurity 2018;

– The Vietnam Commercial Law 2005;

– Decree No. 96/2026/ND-CP detailing and guiding the implementation of the Law on Investment;

– Decree No. 52/2024/ND-CP on Non-Cash Payments;

– Decree No. 53/2022/ND-CP guiding the Law on Cybersecurity;

– Decree 356/2025/ND-CP detailing a number of articles and measures for the implementation of the Law on Personal Data Protection;

– Circular No. 40/2024/TT-NHNN on the provision of intermediary payment services;

– Circular No. 41/2025/TT-NHNN amending and supplementing a number of articles of Circular No. 40/2024/TT-NHNN on the provision of intermediary payment services;

– Ordinance No. 28/2005/PL-UBTVQH11 on Foreign Exchange;

– Ordinance No. 06/2013/UBTVQH13 amending and supplementing a number of articles of the Ordinance on Foreign Exchange;

1.2. Fintech & IPS in Vietnam: Latest developments in foreign investment

Vietnam’s fintech and IPS sector remains a top destination for foreign capital, consistently ranking among the top three in Southeast Asia. Despite global economic shifts, investment in Vietnamese fintech is stabilizing, with total deal value showing a steady upward trend.

Payment services still lead the market, accounting for over 60% of total funding. However, there is a clear shift toward diversification, as digital lending and investment platforms see a 20-25% year-on-year increase in funding. Key investors from Singapore, Japan, and Korea remain the predominant contributors, focusing on established startups that demonstrate sustainable profitability and full compliance with local regulations.

1.3. Trends and outlook for Vietnam’s Fintech and IPS sector

(i) Current trends in foreign investment within Vietnam’s fintech and IPS landscape

– Expansion of cross-border payment connectivity

The enhancement of cross-border payment networks is a key trend. Through the infrastructure provided by the National Payment Corporation of Vietnam (NAPAS), official partnerships with regional markets – including Thailand, Cambodia, and China – have been established. Foreign investors are now focusing on providing the technical systems and settlement mechanisms required to support these real-time, cross-border retail transactions.

– Formalization of the regulatory testing mechanism

The implementation of Decree 94/2025/NĐ-CP has established a structured framework to address existing legal gaps in the fintech market. This formal testing mechanism for emerging sectors – specifically P2P Lending, Open API, and Credit Scoring – provides a clearer and more transparent pathway for foreign-invested enterprises to implement innovative financial solutions under state supervision.

– Strategic focus on RegTech and cybersecurity compliance

In response to stricter requirements for data localization and anti-money laundering (AML) oversight, foreign investment is increasingly shifting toward Regulatory Technology (RegTech). Significant capital is being directed into advanced e-KYC solutions, biometric authentication, and AI-driven fraud detection systems. These investments are vital for ensuring compliance with the security standards mandated by the State Bank of Vietnam.

– Focus on financial accessibility and ESG criteria

International investors are increasingly adding Environmental, Social, and Governance (ESG) standards to their fintech portfolios. There is a clear interest in platforms that improve financial access by providing digital credit and payment services to those without bank accounts and Small and Medium Enterprises (SMEs). This approach aligns commercial goals with national digital economy objectives.

(ii) Future outlook for foreign investment in Vietnam’s fintech sector

The outlook for foreign investment in Vietnam’s fintech and payment sectors remains positive, supported by the government’s digital economy strategy and evolving legal frameworks. Investment is expected to focus on digital lending and investment platforms as regulatory testing mechanisms become more established. Additionally, the adoption of AI and blockchain will create new opportunities for high-tech financial solutions. By aligning local regulations with international standards, Vietnam remains a preferred destination for fintech capital in the region.

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2. Foreign investment in Vietnam’s fintech and intermediary payment services

Fintech & payment intermediaries: A guide for foreign investors in Vietnam

Foreign investors must navigate strict regulations on market access and licensing, with key requirements detailed below:

(i). Market access conditions

Payment intermediary services are classified as a conditional sector for foreign investors.

– Foreign ownership limit (FOL): Current regulations do not impose a specific cap on foreign ownership. However, as this sector is not fully committed under WTO or FTAs, approvals are granted on a case-by-case basis by the State Bank of Vietnam (SBV) and the Ministry of Finance (MOF).

– Forms of investment: Investors may establish a new entity or acquire stakes in existing licensed Vietnamese enterprises.

– M&A approval: Foreign investors must obtain prior approval for capital contributions or share purchases before finalizing transactions in this conditional sector.

(ii). Licensing requirements

According to Clause 2, Article 22 of Decree no. 52/2024/ND-CP, to obtain a payment intermediary service license, an enterprise must meet the following criteria:

– Minimum charter capital:  the required equity is determined by the service scope as follows:

– Personnel qualifications: The Legal Representative and CEO (Director) must hold at least a Bachelor’s degree in Economics, Business Administration, Law, or Information Technology, and possess a minimum of 05 years of management or executive experience in the banking or finance sectors. Candidates must also comply with all statutory eligibility requirements (no prior legal prohibitions).

– Technical infrastructure: The entity must demonstrate robust IT systems, security solutions (e.g., ISO 27001 or PCI DSS), and comprehensive disaster recovery plans.

– Regulatory compliance: A detailed business plan is required, covering operational processes, risk management frameworks, and Anti-Money Laundering (AML) measures. 

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3. Critical considerations for foreign investors in Vietnam’s fintech & IPS

Key strategic considerations for fintech & IPS investors in Vietnam

While Vietnam’s fintech and IPS sectors present compelling opportunities, foreign investors must navigate a complex regulatory landscape. To ensure sustainable operations and mitigate risks, the following critical considerations should be prioritized:

– Regulatory constraints on E-money and cross-border payments:

Vietnamese law requires e-wallets to be linked to local bank accounts, obliging foreign fintech firms to form domestic partnerships and limiting their operational autonomy. Furthermore, cross-border payments are subject to strict foreign exchange controls to ensure compliance with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) standards.

– Data management and cybersecurity:

Under the Law on Cybersecurity and its guiding decrees, personal data of Vietnamese users must be stored within the country. Furthermore, fintech companies are required to maintain strict business continuity standards; any service disruptions exceeding four business hours may result in heavy administrative sanctions.

– Foreign exchange controls and capital transfer:

This is often a major challenge for FDI investors. Profit transfer is permitted only after all tax obligations are fulfilled and audited financial statements are provided. Additionally, as of May 2026, transactions exceeding VND 500 million must be processed through standard banking channels and are subject to strict supervision by Anti-Money Laundering (AML) authorities. Banks are no longer permitted to automatically split large transfers for immediate processing.

– Regulatory Developments and Policy Changes:

Vietnam’s fintech regulatory framework continues to evolve rapidly as authorities seek to balance innovation with financial security. New regulations, pilot programs, and policy initiatives may significantly impact market participants.

While Vietnam’s Fintech and IPS sectors offer significant potential, investors face complex hurdles in regulatory compliance, data localization, and capital management. Professional legal counsel is therefore essential to navigate these challenges, mitigate risks, and ensure sustainable operations.

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4. Fintech & payment intermediaries: FDI legal services by Hung Phi Law Firm

Hung Phi Law Firm – Strategic legal solutions for fintech & IPS investments

Hung Phi Law Firm is a reputable Vietnamese practice specializing in high-quality legal solutions for foreign investors across multiple industries. Our attorneys are highly regarded for their dedication, professionalism, and deep expertise in Vietnam’s legal and business environment.

As a strategic partner, we deliver tailored insights and optimized solutions to address our clients’ most complex challenges. By proactively mitigating legal risks – particularly in Fintech and intermediary payment services – we enable our clients to safeguard their operations and drive commercial success.

We regularly provide the following legal services for foreign investment in Vietnam’s Fintech and Payment Intermediary sectors:

(i). Market entry & licensing

– Investment advisory: Advising on market entry conditions, ownership limits, and optimal investment structures.

– Licensing: Assisting with the application for Payment Intermediary Licenses and other necessary regulatory approvals.

(ii). Compliance & corporate governance

– Regulatory compliance: Ensuring adherence to regulations on electronic payments, foreign exchange, and Anti-Money Laundering (AML).

– Internal governance: Drafting internal policies and ensuring compliance with operational standards and reporting requirements.

(iii). Operational & commercial support

– Contracts: Drafting and reviewing commercial agreements, partnership contracts, and technology transfer documents.

– Data & cybersecurity: Advising on data privacy compliance and cybersecurity requirements under Vietnamese law. 

– Risk management: Identifying and mitigating legal risks to safeguard business operations and enhance efficiency. 

(iv). Dispute resolution

– Negotiation & mediation: Representing clients in settlements and mediation to resolve commercial disputes efficiently.

– Arbitration & litigation: Acting as legal counsel in arbitration and court proceedings in Vietnam.

– Strategic advisory: Developing effective strategies to resolve disputes arising from investment projects, shareholder agreements, or commercial contracts.

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5. Frequently asked questions

5.1. How long does it take to establish a foreign-invested fintech company in Vietnam?

The timeline depends on the investment structure, business model, and whether the project requires an Intermediary Payment Service License. While establishing a foreign-invested company may take only several weeks, obtaining specialized licenses and satisfying regulatory requirements generally requires additional time. Working with experienced legal advisors can help foreign investors prepare compliant documentation, avoid common procedural delays, and significantly shorten the overall investment and licensing process.

5.2. How much does it cost to hire an FDI lawyer from Hung Phi Law Firm?

Our legal fees depend on the complexity of the matter, the scope of work, and the documents involved in each specific case. Please contact Hung Phi Law Firm directly for a tailored quotation and legal assessment.

5.3. Does Hung Phi Law Firm provide online legal consultancy services?

Yes. Hung Phi Law Firm offers online legal consultancy services tailored to foreign investors in Vietnam. We provide legal consultation through various online platforms, including Zalo, Google Meet, Zoom, WhatsApp, and other communication channels, ensuring that investors can promptly connect with experienced lawyers and receive timely, practical, and professional legal support regardless of their location.

5.4. Can foreign investors fully own a FinTech company in Vietnam, and is it easy to expand the business there?

Yes, foreign investors may establish a 100% foreign-owned FinTech company in Vietnam for most technology-based activities, such as software development, AI, and SaaS solutions. However, expansion into regulated financial services, including intermediary payment services, requires additional licenses and compliance with Vietnamese laws. With a fast-growing digital economy and strong government support for innovation, Vietnam offers significant long-term growth opportunities for FinTech businesses.

The above information provides key insights into Navigating foreign investment in Vietnam’s fintech and payment intermediaries, as provided by Hung Phi Law Firm to our clients. 

Should you have any questions regarding this matter or require legal advice tailored to your specific case, please do not hesitate to contact the lawyers of Hung Phi Law Firm for timely support and professional consultation.

Contact Information:

Hung Phi Law Firm

Phone: (+84) 962 75 28 38

Email: luathungphi@gmail.com

Website: hungphi.vn

Sincerely,