Any enterprise wishing to provide payment intermediary services in Vietnam (e-wallets, payment gateways, collection and disbursement support, and similar services) must obtain a License for payment intermediary service provision. The state fee is only a small part of the total licensing cost; the bulk of the real cost lies in meeting the licensing conditions on capital, personnel, technology systems, and security safeguards. This article summarizes the costs to budget for under the regulations in force (as of 14 October 2026).
1. State fee: VND 10 million for a new license, VND 5 million for re-issuance or amendment
Under Circular 150/2016/TT-BTC (still in force), the fee for the License for payment intermediary service provision is:
- VND 10,000,000 — new issuance;
- VND 5,000,000 — re-issuance or amendment.
This is the only state fee payable when applying for the license, regardless of enterprise size.
2. Important: this fee is not reduced by 50% under Circular 64/2025
Circular 64/2025 introduced a 50% fee reduction for certain fees, but it does not apply to the License for payment intermediary service provision. Budget the full VND 10 million / VND 5 million amounts; do not assume a 50% discount that does not exist.
3. Licensing conditions under Article 22 of Decree 52/2024/ND-CP
Decree 52/2024/ND-CP (effective 1 July 2024, still in force) governs payment intermediary services. Article 22 sets out the conditions for granting the License for payment intermediary service provision. Enterprises must satisfy all condition groups on capital, personnel, information technology systems, and safety and confidentiality safeguards before filing.
In practice, the cost of meeting these conditions is the largest expense in the whole licensing process:
- Capital: the enterprise must maintain the prescribed capital level — usually the biggest financial barrier for new entrants;
- Personnel: the enterprise must have personnel meeting the prescribed qualification and experience standards — recruitment, training, and retention costs are the second-largest barrier;
- Technology systems: investment in technical infrastructure, payment systems, and security solutions meeting the regulator requirements;
- Safeguard plans: building processes and plans for customer protection, incident handling, and risk prevention.
When budgeting for a payment intermediary license, do not look only at the VND 10 million fee — the total cost of meeting the conditions is typically many times higher.
4. Advisory and dossier preparation costs
The licensing dossier requires extensive legal, technical, and financial documentation prepared in compliance with the regulations. Many enterprises engage advisors to draft the dossier, review the conditions, and accompany them through the appraisal process. This cost is agreed with the advisor and should be included in the budget from the outset.
5. Law 88/2025 does not affect payment intermediary conditions
Law 88/2025 (effective 15 October 2025) only amends the Law on Credit Institutions in relation to bad debt resolution — it does not regulate payment intermediary service provision. The controlling texts for this license remain Decree 52/2024/ND-CP and Circular 150/2016/TT-BTC.
Frequently asked questions
What is the fee for a new payment intermediary license?
VND 10,000,000 under Circular 150/2016/TT-BTC.
What is the fee for re-issuance or amendment?
VND 5,000,000 under Circular 150/2016/TT-BTC.
Is the fee reduced by 50% under Circular 64/2025?
No. The 50% reduction under Circular 64/2025 does not apply to the License for payment intermediary service provision.
What is the largest cost item in the licensing process?
Not the state fee, but the cost of meeting the licensing conditions (capital, personnel, technology systems, safeguards) under Article 22 of Decree 52/2024/ND-CP — with capital and personnel as the two main barriers.
Sources
- Decree 52/2024/ND-CP (effective 1 July 2024, in force) — Article 22: conditions for the License for payment intermediary service provision.
- Circular 150/2016/TT-BTC (in force) — VND 10,000,000 for new issuance; VND 5,000,000 for re-issuance/amendment.
- Law 88/2025 (effective 15 October 2025) — amends the Law on Credit Institutions on bad debt resolution only; no effect on payment intermediary conditions.
For reference only; not legal advice. This content was prepared by AI and will undergo quality review by the AI Legal Council of FLAT Law Firm before any publication consideration; it is not the legal opinion of a licensed human lawyer. Laws and regulations may change; verify the current legal texts before applying them.
Is your enterprise preparing a payment intermediary license application? Contact FLAT Law Firm for advice.