Applying for an Intermediate Payment Licence in 2025 (P2)

Continuing from part 1: https://hmlf.vn/invesment/guide-to-payment-intermediary-license-application-process-2025/

1. Required documents for payment intermediary license application
To apply for a payment intermediary license, businesses need to prepare a complete and detailed application according to Clause 2, Article 24 of Decree 52/2024/ND-CP, including the following documents:

• License application form: According to the template prescribed by the State Bank of Vietnam (SBV), including basic information about the business, type of payment intermediary service being registered, and commitment to comply with legal regulations.
• Legal business documents: Including Business Registration Certificate, Company Charter, Resolutions, decisions appointing legal representatives and senior management. According to regulations, businesses must register with appropriate business lines and have been operating for at least 2 years before applying.
• Business plan: A detailed business plan for at least the first 3 years of operation, including market analysis, business model, development strategy, revenue and profit forecasts. The plan should clearly demonstrate the value provided to users and the payment ecosystem.
• Technical and security solutions: A technical solution document detailing the technology infrastructure, security solutions, transaction processing procedures, contingency and incident recovery plans. In 2025, compliance with security standards such as PCI DSS, ISO 27001 and specific SBV standards is required.
• Operational procedures: Documents describing in detail the operational procedures, risk management procedures, customer dispute and complaint resolution processes. The internal control mechanism and risk governance should be clearly explained.
• Financial reports and proof of financial capacity: Audited financial statements for the 2 most recent years and documents proving compliance with statutory capital requirements (50-100 billion VND depending on the type of service).
• Key personnel files: Criminal records, qualifications, certificates, and work experience of management and key personnel. According to Decree 52/2024/ND-CP and detailed guidance in Circular 40/2024/TT-NHNN, senior managers must have at least 3 years of experience in finance-banking or information technology.
• Other required documents: Including cooperation agreements with partners, banks, relevant certificates and licenses, commitments to comply with anti-money laundering regulations and personal data protection.
  Source: https://chinhphu.vn/?pageid=27160&docid=210262

2. SBV regulations on payment intermediary activities
The SBV has issued many legal documents regulating payment intermediary activities, which businesses need to understand clearly to ensure compliance:

• Current legal documents: Decree 52/2024/ND-CP: The core legal document stipulating conditions, documentation, procedures, licensing process and management of payment intermediary service provision. Includes services such as: e-wallets, payment gateways, financial switching, electronic clearing, payment collection and disbursement support, electronic money transfer support.

Decree 181/2025/ND-CP: Guidance on implementing certain articles of the 2024 Value Added Tax Law, especially regulations on cashless payments to qualify for tax deductions and reasonable expense calculations. Clearly defines cashless payment methods and corresponding documentation requirements

Circular 23/2019/TT-NHNN: Amending and supplementing several articles of Circular 39/2014/TT-NHNN, focusing on: E-wallet management: transaction limits, user authentication. Information security: technical requirements and data protection procedures. Responsibilities of service providers: in anti-money laundering, consumer protection.

Circular 40/2024/TT-NHNN: Detailed guidance on implementing Decree 52/2024/ND-CP. Regulations on: License application documentation. Requirements for personnel, capital, technical infrastructure. Appraisal and licensing procedures. Risk management, information security, periodic reporting. And SBV Decisions on conditions, documentation, procedures for approving service provision. In 2025, regulations have been updated to align with technological development trends and security.

• Reporting and compliance obligations: Payment intermediary businesses must periodically report their operations to the SBV, including financial reports, operational reports, system security reports. Reporting frequency is typically quarterly and annually, with some special cases requiring ad-hoc reports.
• Information security and system safety regulations: Businesses must ensure information security, protect customer data, and have backup and system recovery plans in case of incidents. In 2025, the SBV requires multi-factor authentication solutions and data encryption according to international standards.
• Anti-money laundering regulations: Compliance with Know Your Customer (KYC) regulations, monitoring suspicious transactions, reporting high-value transactions, and other anti-money laundering measures. According to new regulations, businesses must have automated systems to detect suspicious transactions.
• Consumer protection regulations: Disclosure of service fees, complaint resolution procedures, customer compensation mechanisms. In 2025, the SBV requires businesses to have 24/7 customer support hotlines and resolve complaints within the prescribed timeframe.

3. Common challenges and solutions
The process of applying for a payment intermediary license often faces many challenges; below are common difficulties and solutions:

• Difficulties in meeting capital requirements: High statutory capital requirements (50-300 billion VND) can be a barrier for many startups. Solutions include finding strategic investors, raising capital from venture funds, or partnering with large financial institutions.
• Technology and security challenges: Building systems that meet high security standards requires significant investment. Businesses may consider hiring consultants, using certified technology solutions, or partnering with experienced technology partners.
• Specialized personnel issues: Lack of personnel with experience in fintech and payments. Solutions include investing in personnel training, attracting talent from banks or financial technology companies, or hiring consultants.
• Extended application processing times: Although regulations state a 60-day processing time, in practice it can be longer. Businesses should thoroughly prepare applications before submission, maintain regular contact with the SBV to update progress, and be ready to provide additional information when requested.
• Additional requirements arising during the process: During evaluation, the SBV may request additional information or documents. Businesses should be flexible and respond quickly, while maintaining transparency in communications with regulators.

4. Expert advice
Based on the experience of businesses that have successfully obtained licenses, here are valuable recommendations:

• Consultation from specialized lawyers: Hire lawyers with expertise in fintech and banking regulations to advise throughout the process. They can help review applications, ensure regulatory compliance, and assist in resolving legal issues that arise.
• Experience from previously licensed businesses: Consult the experience of predecessors, learn from their successes and failures. If possible, join fintech associations to connect with the business community in the same industry.
• Effective application preparation strategy: Invest time and resources to prepare high-quality applications. All documents should be clear, consistent, and fully meet requirements. Use templates and checklists to ensure no important information is omitted.
• Methods for tracking application processing progress: Maintain regular contact with the SBV to update application processing progress. Be prepared to respond quickly to requests for additional information. Use internal management systems to track progress and ensure deadlines are met.

5. Conclusion
Summary of key points: Applying for a payment intermediary license is a complex process, requiring thorough preparation of legal documents, business plans, technical solutions, and financial capacity. Businesses need to strictly comply with SBV regulations and be ready to face challenges during the licensing process.

• Vision for Vietnam’s payment intermediary market: Vietnam’s payment intermediary market is developing strongly with increasing trends in digitalization and cashless payments. By 2030, transaction values through payment intermediary platforms are forecast to increase many times over, opening up significant opportunities for licensed businesses.

Legal Consulting Services for Payment Intermediary Licenses – Harley Miller Law Firm

With over 10 years of experience in the field of financial technology (FinTech) law in Vietnam, Harley Miller Law Firm provides comprehensive consulting services for businesses seeking payment intermediary licenses:

• Legal strategy consulting: Assessing business models, identifying specific legal requirements, and developing a tailored compliance roadmap for each business.
• Application preparation and submission support: Drafting all necessary legal documents, ensuring compliance with SBV requirements, and reviewing the completeness and accuracy of the application before submission.
• Representing the business: Working directly with the SBV and relevant regulatory authorities, monitoring the progress of the application process, and promptly responding to any additional requests.
• Ongoing legal compliance consulting: Keeping you updated on regulatory changes, assessing their impact, and proposing adjustment plans, as well as assisting in maintaining compliance after obtaining the license.

Why choose Harley Miller Law Firm?

• Expert team: FinTech-specialized lawyers with direct experience working with the SBV.
  Comprehensive approach: Combining legal advice with deep understanding of technology and business.
• Network of partners: Collaborations with financial, technology, and security experts to provide comprehensive support.

Contact us for consultation: info@luatminhnguyen.com | Hotline: +84 937215585