E-wallets and electronic payment gateways both belong to the payment intermediary service group and share a single licence issued by the State Bank of Vietnam under Decree 52/2024/ND-CP. The core difference lies in the money flow: an e-wallet holds clients’ prepaid funds, whereas a payment gateway only provides the technical infrastructure to connect and process transactions and never holds the money. This article compares the two models in terms of licensing, conditions and compliance costs so that a business – including a foreign-invested enterprise – can choose the right service to license for its business model.
Legal basis
- Decree 52/2024/ND-CP dated 15 May 2024 of the Government on cashless payment, effective from 1 July 2024, replacing Decree 101/2012/ND-CP and Decree 80/2016/ND-CP: clauses 12, 16 and 18 of Article 3 (e-money, the e-wallet service, the electronic payment gateway service); clause 3 of Article 6 (payment guarantee accounts for the e-wallet service); Article 22 (list of services and supply conditions); Article 24 (licence issuance).
- Circular 40/2024/TT-NHNN of the State Bank of Vietnam: Article 26 (transaction limits for individual clients’ e-wallets).
A distinction to note: Decree 52/2024/ND-CP governs cashless payment and is different from Decree 52/2013/ND-CP on e-commerce (which ceased to be effective on 1 July 2026 under the Law on E-commerce 122/2025/QH15).
What the two models share: one licence, one floor of conditions
Under clause 1 of Article 22 of Decree 52/2024/ND-CP, payment intermediary services comprise six services: financial switching, international financial switching, electronic clearing, e-wallets, collection and payment support, and electronic payment gateways. Any organisation that is not a bank or a foreign bank branch wishing to provide any of these services must obtain a Licence for payment intermediary service provision from the State Bank of Vietnam, and the conditions in clause 2 of Article 22 must be maintained throughout the provision of the service – not only at the time of application.
For both the e-wallet service and the payment gateway service, the floor of conditions is identical: minimum actually-contributed charter capital of VND 50 billion (point b, clause 2, Article 22 – the VND 300 billion level applies only to financial switching, international financial switching and electronic clearing); a service provision Plan approved by the competent level under the organisation’s Charter in Form No. 08 (point c); personnel conditions – the legal representative and the General Director (Director) must hold a university degree or higher in economics, business administration, law or information technology and have at least 05 years of experience as a manager or executive in the finance and banking sector, and at least one legal representative must reside in Vietnam at all times (point d); and a Technical solution description meeting level-3 information system security requirements (point dd).
The licensing procedure is also shared under Article 24 of Decree 52/2024/ND-CP: the State Bank confirms receipt of a complete and valid dossier within 05 working days; appraisal takes 90 working days from receipt of the complete valid dossier; the Licence has a 10-year term (clause 5, Article 24); and under clause 3 of Article 22 the licensed organisation must bring the service to market within a maximum of 06 months from licensing, after completing the technical system and technical acceptance testing with the partner bank. One point foreign-invested businesses should note: a single Licence may register several payment intermediary services, so a business with an expansion roadmap can apply for both the e-wallet and the payment gateway in one dossier instead of filing twice. Conversely, banks and foreign bank branches provide e-wallets under their banking licences and are not subject to this intermediary Licence.
The core difference: wallets hold client money, gateways only connect
Under clause 16 of Article 3 of Decree 52/2024/ND-CP, the e-wallet service is a service provided to clients to top up money into an e-wallet, withdraw money from an e-wallet and make payment transactions – in other words the client pays in advance, and the value stored on the wallet is e-money under clause 12 of Article 3. Under clause 18 of Article 3, the electronic payment gateway service is the provision of technical infrastructure to connect, transmit and process electronic data of payment transactions between clients, payment acceptors and banks, foreign bank branches, finance companies permitted to issue credit cards, and payment intermediary organisations. Put simply: the wallet is “where the end user’s money sits”; the gateway is the “technical pipe” that lets a seller accept payment from the buyer’s bank cards and accounts.
That difference generates three layers of obligations that only the e-wallet model bears. First, the switching connection condition: under point e, clause 2, Article 22, an e-wallet provider (and a collection/payment support provider serving clients holding accounts at multiple banks) must have its financial transactions switched and its arising obligations cleared by a licensed financial switching and electronic clearing organisation. Second, the client-money safeguard obligation: clause 3 of Article 6 of Decree 52/2024/ND-CP requires the e-wallet provider to maintain the total balance on all payment guarantee accounts opened at banks at no less than the total balance of all e-wallets issued to clients, and permits use of the service only for e-wallets linked to the client’s own payment account or debit card. Third, the transaction cap: Article 26 of Circular 40/2024/TT-NHNN limits the total transaction limit through all e-wallets of an individual client at one e-wallet provider to a maximum of VND 100 million per month, except for certain separately listed transaction groups. A payment gateway bears none of these three layers, because money never stops at the gateway: transaction data is transmitted to the issuing bank and funds settle into the payment acceptor’s account.
Which model is easier to license?
Procedurally, the two models are on a par: the same licensing authority, the same 90-working-day appraisal under Article 24, the same VND 50 billion capital floor and the same level-3 information system security requirement. In substance, the payment gateway is lighter: the dossier does not have to prove a client-money safeguard mechanism, no switching and clearing arrangement under point e, clause 2, Article 22 is needed, and no guarantee account must be operated after licensing. The e-wallet is heavier at both ends: at the application stage it must persuade the State Bank of its client balance governance mechanism in the service provision Plan, and in operation it must maintain the safeguard obligation matching the entire wallet float under clause 3 of Article 6. Therefore, a business that only needs to accept payments for its own sales or for a network of payment acceptors should start with a payment gateway; a business that wants to build a user base holding balances, wallet-to-wallet transfers and in-app payments needs the e-wallet model – or can license both services in a single Licence if its product roadmap includes both.
How do compliance costs differ?
The shared cost items of both models include: charter capital of VND 50 billion that must be actually contributed and maintained throughout operation; the cost of building and operating a technical system meeting level-3 information security; management personnel meeting the degree and experience standards; and reporting and change-notification obligations towards the State Bank during service provision. The e-wallet’s own cost items include: capital kept at the guarantee accounts – the larger the clients’ wallet float, the larger the balance that must be maintained in the guarantee accounts; daily balance reconciliation, client authentication and account linking, and transaction-limit monitoring; and switching and clearing connection fees. The payment gateway’s own costs concentrate on technical integration with banks and payment acceptors, transaction data security and transaction reconciliation – but there is no client-money safeguard cost. Accordingly, under the same statutory capital floor, the total operating compliance cost of the e-wallet model is markedly higher than that of the payment gateway, and the gap widens with the size of the wallet float.
Frequently asked questions
Should I build an e-wallet or a payment gateway: which licence fits my model?
It depends on your business model. If the business needs clients to top up money in advance, hold a balance and pay from that balance, you need the e-wallet service. If the business only needs to help sellers accept payment from buyers’ bank cards and accounts – the money runs through the bank and never stops at your business – you need the electronic payment gateway service. Both use the same Licence for payment intermediary service provision issued by the State Bank of Vietnam under Article 22 of Decree 52/2024/ND-CP, and one Licence may record several services.
How do the two models differ in licensing?
The two models share one licence type and one floor of conditions in clause 2 of Article 22 of Decree 52/2024/ND-CP: minimum actually-contributed charter capital of VND 50 billion, a service provision Plan in Form No. 08, qualified management personnel, and a technical solution meeting level-3 information system security. The difference lies in the e-wallet’s own layer of obligations: transactions must be switched and cleared by a licensed switching and clearing organisation (point e, clause 2, Article 22); payment guarantee accounts must be maintained at no less than the total balance of all issued e-wallets and each wallet must be linked to the client’s own payment account or debit card (clause 3, Article 6); and individual clients’ e-wallet transactions are capped at VND 100 million per month (Article 26 of Circular 40/2024/TT-NHNN). A payment gateway only provides the connection infrastructure and does not hold client money, so it bears none of these layers.
Which one is easier to license?
Procedurally and in timing the two models are the same: one procedure under Article 24 of Decree 52/2024/ND-CP (90 working days of appraisal, a 10-year Licence). In substance the payment gateway is easier because it never touches client money: the dossier does not have to prove a balance safeguard mechanism, no switching and clearing arrangement for the wallet service is needed, and no guarantee account must be operated after licensing. The e-wallet is heavier both at the licensing stage and in operation, so businesses that only need to accept payments usually choose the gateway first.
How do compliance costs differ?
The shared items are the cost of maintaining VND 50 billion of charter capital, a technical system meeting level-3 information security, qualified management personnel, and reporting obligations towards the State Bank. The e-wallet adds: funds that must be maintained in guarantee accounts matching the entire client wallet float (the larger the float, the larger the tied-up capital cost), daily balance reconciliation, client authentication, transaction-limit monitoring, and switching and clearing fees. The payment gateway spends mainly on technical integration with banks and payment acceptors and on transaction data security, with no client-money safeguard cost.
This article has been quality-reviewed by the FLAW AI Legal Council