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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.


Oanh Nguyen is partner in Baker & McKenzie´s Ho Chi Minh City office. She has been advising on various aspects of corporate and commercial law for more than 17 years. She has been rated by Chambers Asia as a leading lawyer in Banking & Finance and Projects, Infrastructure & Energy. IFLR 1000 has listed her as a leading lawyer in the areas of Banking & Project Finance and Mergers and Acquisitions. PLC Which Lawyer? has also recommended her for Finance in Vietnam. Ms. Nguyen serves as editor of the monthly Banking and Finance Letter, and has delivered several presentations on foreign investments and M&A in Vietnam.


Linh Chi Dang is a Special Counsel in Baker McKenzie's Hanoi office.