Mobile Money is a service that allows users to perform money transfer transactions, bill payments, and shopping via mobile phones using only a telecommunications subscription, without the necessity of having a bank account. Following the pilot period, regulations on Mobile Money under Decree 368/2025/ND-CP have been officially issued by the Government and will take effect from January 1, 2026. The Decree also sets stricter conditions for Mobile Money Licensing in Vietnam: New Conditions under Decree 368/2025, aiming to promote non-cash payments and expand access to financial services for the public, marking a key update in Fintech regulations Vietnam 2026.
Table of contents
According to Article 20 of Decree 368/2025/ND-CP, to be permitted to conduct Mobile Money business, organizations that are not banks or foreign bank branches must simultaneously satisfy multiple groups of conditions and maintain them throughout the operation process.
In case of not directly owning the license, the enterprise may still participate if it is a subsidiary authorized by the parent company to use the telecommunications infrastructure, network, and data to deploy Mobile Money services in accordance with the law.
Enterprises must develop a comprehensive and detailed Mobile Money service provision plan, clearly demonstrating the implementation model, cash flow management, risk management, information security, and client rights protection.
This plan serves as an important basis for the state management agency to consider the safe and stable operational capability of the service.
The information technology system serving Mobile Money must meet high-level information security standards, ensuring continuous, stable, and safe operation throughout the service provision process.
Specifically, enterprises need to have:
Besides requirements on transaction data, enterprises must also perform the storage of records and accounting vouchers related to Mobile Money activities in accordance with accounting laws, ensuring transparency and financial control capabilities.
Based on Clause 1, Article 25 of Decree 368/2025/ND-CP, the Mobile Money service provider is responsible for ensuring the safety, transparency, and legal rights of clients throughout the process of opening and using the Mobile Money account.
Specifically, the core obligations include:
Enterprises may only execute payment orders of the Mobile Money account holder after having fully checked and verified the legality and validity of the order, to prevent fraud risks and errors in transactions.
The service provider must store and update identification information and authentication data of registered clients to serve checking and reconciliation during the use of the Mobile Money account.
Enterprises are responsible for timely recording incoming transfers, deposits, or receipts into the client’s Mobile Money account.
In case errors arise, the service provider must refund amounts recorded inaccurately and coordinate to process mistaken transfer transactions upon the request of related parties.
Clients must be notified in a timely manner regarding account balances, arising transactions, and related vouchers.
The Mobile Money service provider is liable for the accuracy of all information it provides to clients.
Enterprises must perform client information updates periodically or immediately upon changes, and simultaneously enhance verification for cases assessed as having high-risk levels.
Mobile Money account opening files and transaction vouchers must be stored and preserved according to legal regulations.
All information related to personal data, Mobile Money accounts, and transaction history of clients must be strictly secured, consistent with laws on personal data protection and related regulations.
The service provider is responsible for guiding clients to use Mobile Money accounts safely, clearly informing about prohibited acts, and simultaneously receiving and timely processing inquiries and complaints arising during service usage.
Enterprises must develop internal regulations regarding the opening and use of Mobile Money accounts, and publicly disclose and guide clearly so clients know and comply when participating in the service.
According to Article 6 of Decree 368/2025/ND-CP regulating Mobile Money, organizations providing mobile money services are not allowed to perform or permit the performance of the following acts:
A Mobile Money account is a specialized account attached to a telecommunications subscription number used for ground mobile telecommunication services performing person-to-person communication methods, provided by the Mobile Money service provider to the client to use Mobile Money services.
A client is only allowed to open one Mobile Money account at one Mobile Money service provider.
Example: A client can only open a single Mobile Money account at Viettel or Vinaphone….
The total transaction limit for money transfers and payments via the Mobile Money account of 01 client at 01 Mobile Money service provider is a maximum of 100 million Vietnamese Dong in one month.
Procedures for opening a Mobile Money account require the service provider to meet the account holder/representative directly to cross-check identification documents and match biometric information for cases:
Besides the direct opening form, users can completely open Mobile Money accounts online.
In this case, the service provider must match biometric information stored in the QR code of the authenticated Citizen ID card/ID card or via VNeID or biometric data that has been collected and checked.
The above is an update on regulations regarding Mobile Money Licensing in Vietnam: New Conditions under Decree 368/2025. Enterprises with a need to conduct Mobile Money business need to proactively review conditions, complete documentation, and build suitable compliance mechanisms to fully meet legal requirements.
