Paying factory workers by e-wallet is legal and spreading fast in industrial parks, but the model only stands when a bank stands behind the wallet: under Decree 52/2024/ND-CP an e-wallet must link to the worker’s own payment account, and wages sit in a guarantee account at a bank. An employer forcing workers onto one designated wallet, or choosing a wallet model with no account linkage, steps outside this legal frame.
Legality: wallet payroll is account payroll, and it needs agreement
Article 96 of the 2019 Labour Code requires wages to be paid directly, in full and on time; where wages are paid through a bank account, the parties agree on it and the employer bears the account-opening and transfer fees. Vietnamese e-wallets are designed to be account-linked: under Decree 52/2024/ND-CP a wallet must link to the customer’s own payment account or debit card. Paying wages ‘by wallet’ is therefore in substance payment into the worker’s own account-wallet system, and is lawful where the payment method is agreed with the worker in the labour contract or a payroll agreement.
The limit to remember is voluntariness: the employer cannot unilaterally force all workers to open wallets at one employer-designated intermediary as a condition of receiving wages. The standard operating model is a bank-fintech-employer triangle: the bank opens accounts and holds the guarantee account, the intermediary operates the wallet and interface, and the employer sends the payroll file through the bank for bulk crediting. The personal wallet limit of VND 100 million per month at one intermediary (Article 26, Circular 40/2024/TT-NHNN) is many times a worker’s monthly wage, but the employer should still model the worker’s total monthly transactions when designing the scheme.
How workers without a bank account receive wages
This is the most practical bottleneck in industrial parks, and the answer must be straight: an e-wallet cannot be opened wholly independently of an account, because the law requires the wallet to link to the holder’s own payment account or debit card. Workers without an account need supported onboarding to open a payment account at the partner bank — most banks now open accounts remotely by electronic identification (eKYC) on a phone, usually free to open and maintain — then link the wallet to that account to receive wages and cash out.
During transition, the employer should keep a parallel cash channel for workers who have not yet opened accounts and record the roadmap in its agreement with the workforce. Forcing an unbanked worker to receive wages through someone else’s wallet, a pooled company account, or an agent point not in their name are distortions that destroy the ‘paid directly to the worker’ character that Article 96 of the Labour Code protects.
Cash-out fees and how safe wages in a wallet are
On fees, the Labour Code places the cost of the account channel on the employer for account-opening and wage-transfer fees. The fee for withdrawing cash from the wallet to an account or at an agent point belongs to the intermediary’s fee schedule; an employer rolling out wallet payroll should negotiate an enterprise package under which workers’ wage cash-out costs are borne by the employer or the fintech partner by agreement, disclosed to workers in advance — making workers pay to withdraw their own wages is the single biggest cause of factory-floor backlash against the model.
On safety, all customers’ wallet money is protected by the guarantee account mechanism: the intermediary must keep the total balance of its payment guarantee accounts at banks no lower than the total balance of all wallets issued to customers (Decree 52/2024/ND-CP). In other words, wages in a wallet do not sit in the fintech company’s own assets and cannot be used for other purposes. The remaining risk is personal operational risk — a lost phone, a leaked PIN, account-takeover fraud — handled by layered identification, OTP authentication, and the provider’s wallet-locking and trace procedures.
Frequently asked questions
Is paying workers’ wages via e-wallet legal?
Legal, provided it is agreed with the worker. Article 96 of the 2019 Labour Code allows account-based wage payment by agreement, and under Decree 52/2024/ND-CP an e-wallet must link to the worker’s own payment account or debit card, so wallet payroll is in substance payment into the worker’s own account system. The employer cannot force workers to open wallets at one designated intermediary as a condition of being paid.
How do workers without a bank account receive wages?
A wallet cannot be opened with no account at all: the law requires linkage to the holder’s own payment account or debit card. Workers need supported onboarding to open an account at the partner bank (remote opening by eKYC, usually free) and then link the wallet. During transition the employer should keep a parallel cash channel for workers not yet onboarded.
Who bears the wallet withdrawal fee?
The employer bears account-opening and wage-transfer fees under Article 96 of the Labour Code. Wallet cash-out fees sit in the intermediary’s fee schedule — the standard model is an enterprise payroll package where workers’ cash-out costs are borne by the employer or the fintech partner by agreement and disclosed to workers in advance.
How is wage money in the wallet kept secure?
Wages in a wallet are held in the intermediary’s guarantee account at a bank: the guarantee balance must never fall below the total balance of all issued wallets (Decree 52/2024/ND-CP), so the money is not the fintech’s own asset. Additional protection comes from identification, PIN/OTP and the provider’s wallet-lock and trace procedures if a phone is lost or an account is compromised.