A virtual account looks like a dedicated bank account for each seller, but legally it is only an identification number layer issued by a bank on top of a real payment account. Because only credit institutions may open and maintain payment accounts, an e-commerce platform cannot issue virtual accounts itself — it must go through a partner bank, and sellers need to understand where their money actually sits inside that structure.
Can an e-commerce platform issue virtual accounts itself
No. Opening and maintaining payment accounts is an activity of credit institutions under the Law on Credit Institutions 32/2024/QH15 and the State Bank’s rules on opening and using payment accounts. A virtual account is a bank-provided service: the bank issues the customer (the platform, or an enterprise collecting money) sub-account identification numbers, each mapped to a specific payer or seller, while all money actually posts to a real payment account held by the account holder at that bank. An e-commerce platform is not a credit institution, so it cannot create ‘accounts’ for sellers under any name — including ‘internal wallet’ or ‘platform balance’ — if that structure lets it hold and move money like an account.
The lawful routes for a platform are two: contract with a bank for the bank to issue virtual accounts per seller, identifying money flows into the platform’s or the seller’s payment account; or route the money leg through a payment intermediary licensed under Decree 52/2024/ND-CP (e-wallet, collection and disbursement), where sellers’ money is held in the intermediary’s guarantee account. The platform’s own operation is governed by the E-commerce Law 122/2025/QH15 and Decree 248/2026/ND-CP — the current framework replacing the expired old one — but that framework does not turn a platform into an entity allowed to hold money in a bank’s place.
How a virtual account differs from a regular bank account
The core difference has three points. First, the legal holder: a regular account stands in the customer’s own name with a direct account relationship with the bank, while a virtual account is an identification number riding on a master account — in the common platform model the real account is held by the platform or its payment partner, and the seller is merely an identifier on that account. Second, function: a virtual account mainly serves the collection side — letting the system automatically recognise who paid how much — and does not by itself let the seller withdraw, transfer out or use banking services like a full account; payouts run from the real account on the platform’s settlement cycle.
Third, experience and risk: because money awaiting settlement sits in the platform’s or partner’s account, the seller carries the platform’s credit risk during the unsettled window — the single biggest difference from sales proceeds landing directly in a bank account in the seller’s own name. Larger sellers should negotiate short settlement cycles and, where possible, a virtual account model mapped directly onto their own payment account at the bank instead of the platform’s master account.
Is money in a virtual account deposit-insured
Not in the way sellers usually imagine. Deposit insurance in Vietnam protects depositors’ deposits at participating institutions, and the insured person is the holder of the deposit. In the master-account virtual account model, the account holder at the bank is the platform or its payment partner, not each seller, so the seller is not the directly insured person for the balance awaiting settlement; the seller’s right to that money is a receivable against the platform under the platform participation contract and the transaction reconciliation data.
The practical conclusion is not alarming but must be clear: money in a virtual account is protected by three other layers — it sits at a bank in the account of an entity supervised by the State Bank, transaction identification data makes every sum traceable, and if routed through a payment intermediary there is the guarantee-account layer under Decree 52/2024/ND-CP. But ‘the bank holds the money’ does not mean ‘deposit-insured’, and a platform must not market virtual accounts to sellers with messaging that confuses the two.
Frequently asked questions
Can an e-commerce platform issue virtual accounts to sellers itself?
No. Only credit institutions may open and maintain payment accounts; a virtual account is a bank service — an identification sub-number mapped onto a real payment account. A platform must partner with a bank to issue virtual accounts to sellers, or route the money leg through an intermediary licensed under Decree 52/2024/ND-CP. The platform framework is the E-commerce Law 122/2025/QH15 and Decree 248/2026/ND-CP, which do not make the platform a money-holding entity.
How does a virtual account differ from a regular bank account?
Three differences: (i) a regular account is in the customer’s own name with a direct bank relationship, while a virtual account is an identifier on a master account usually held by the platform or partner; (ii) a virtual account mainly serves collection and payer identification and does not itself allow withdrawal or transfer like a full account — payouts run from the real account on a settlement cycle; (iii) the seller carries the platform’s credit risk while money awaits settlement.
Is money in a virtual account insured?
Not directly. Deposit insurance protects the person holding the deposit at a participating institution; in the master-account model the bank account holder is the platform or payment partner, not each seller, so the seller is not the insured person for the unsettled balance. The money is still protected by sitting at a bank, by traceable identification data and — if routed through an intermediary — by the guarantee account under Decree 52/2024/ND-CP.
This article has been quality-reviewed by the FLAW AI Legal Council