A payment intermediary license in Vietnam is not one sheet of paper that ‘does all payment services’. Decree 52/2024/ND-CP licenses service by service — payment gateway, e-wallet, and collection/disbursement are distinct services recorded separately in the license. Collecting electricity bills therefore needs no wholly new license, but the collection and disbursement service must already be inside the organisation’s license.
Electricity bill collection: the collection/disbursement service must be licensed
Collection and disbursement is defined in Decree 52/2024/ND-CP as a payment intermediary service in which the provider collects money from payers and pays beneficiaries under authorization and contracts with the relevant parties — collecting electricity, water, tuition and insurance payments is the typical application. An organisation wanting to collect electricity bills must hold a State Bank payment intermediary license recording the collection and payment-support service; a technology company holding only a contract with the power company, without this service in its license, may not collect the public’s money in its own name.
On conditions, Article 22 of Decree 52/2024/ND-CP sets them by service group: paid-in charter capital tied to the registered services (for example VND 50 billion for the e-wallet and payment gateway group, VND 300 billion for financial switching and electronic clearing), a service provision scheme in the prescribed form, and technical systems meeting level-3 information security. The license is valid for 10 years under Article 24, and the organisation must maintain these conditions throughout operation — losing a condition without remedy is a ground for license revocation.
How many services can one license cover
One license can record several services, if the organisation registers and meets the conditions for each at the time of licensing. In practice, large intermediaries commonly hold licenses combining payment gateway, e-wallet and collection/disbursement — but their lawful scope stops exactly at the recorded services. Supplying a service outside the license, for example using a gateway-only license to run an e-wallet holding customer money, is unlicensed provision of a payment intermediary service in that scope and is handled accordingly.
The practical distinction is between ‘a new feature inside an already licensed group’ and ‘an unlicensed service group’. Launching collection for a new bill category — from electricity to water or tuition — stays within the licensed collection/disbursement service and needs only partner contracts and reconciliation engineering. By contrast, adding an e-wallet or payment gateway to a license that lacks them crosses into another service group and requires the license-amendment procedure before supply.
Adding a new service: amend the license first
To supply a service not yet in its license, the organisation must ask the State Bank to amend and supplement the payment intermediary license, evidencing the conditions for the added service under Article 22 — especially capital if the new service sits in a higher-capital group, the service provision scheme and system capability. Only once the amended license records the new service may the organisation supply it to the market.
The sequence matters for risk: launching first and amending later leaves every transaction in the unlicensed period inside the violation zone, and customer money in that period is not wrapped by the guarantee-account mechanism attached to the license. For an FDI investor acquiring or investing in a payment intermediary, reconciling each operating service against the current license content is one of the first due-diligence items — because the deal’s value lies in the actual licensed scope, not in the service catalogue the company advertises.
Frequently asked questions
Does providing electricity bill collection services require a separate license?
No separate license just for electricity bills is needed, but the collection and disbursement service must be inside the State Bank payment intermediary license under Decree 52/2024/ND-CP. Electricity, water and tuition collection are the same collection/disbursement service; an organisation without it in its license may not collect money in its own name, even with a contract with the power company.
How many services can one payment intermediary license cover?
There is no one-service-per-license limit: one license can record several services at once (gateway, e-wallet, collection/disbursement) if the organisation registers and meets each service’s conditions under Article 22 of Decree 52/2024/ND-CP. The lawful scope stops at the recorded services; supplying an unrecorded service is unlicensed provision in that scope.
Must a supplementary license be obtained to add a new service?
Yes. To add a service not in the license, the organisation must obtain a State Bank amendment of the license, evidencing the new service’s conditions (capital, scheme, systems), and may supply it only after the license is supplemented. Launching first and amending later leaves the interim transactions in the violation zone.
This article has been quality-reviewed by the FLAW AI Legal Council