Buy-now-pay-later looks like a payment feature, but in substance it is consumer credit granted at the point of sale. Vietnamese law has no licence called BNPL, yet it draws a bright line: lending is a banking activity that only licensed credit institutions may perform. Whether a BNPL model is lawful therefore depends entirely on who actually grants the credit inside the transaction structure.
The legal boundary: credit is a licensed activity
Under Law on Credit Institutions 32/2024/QH15, lending is a form of credit extension within banking activity, which only licensed banks, finance companies and other credit institutions may perform as a regular business. Licensed finance companies may conduct consumer lending, instalment lending and credit card issuance, and they are the entities standing behind most BNPL products operating lawfully in Vietnam.
A technology platform that uses its own funds to pay the merchant upfront and collects from the buyer over time, with fees or interest, is in substance lending whatever the BNPL label says. If that entity is not a credit institution, the activity faces the risk of being treated as unlicensed banking business, while its interest and fee terms are tested against the civil loan interest ceiling in Article 468 of Civil Code 91/2015/QH13.
Three BNPL structures used lawfully
The first structure is partnership with a finance company or a bank: the platform acts as distribution and technology channel, while the credit institution appraises, disburses and collects. The second structure is pure commercial deferred payment, where the seller itself lets the customer pay for the goods over time as a payment term of the sales contract, without a stand-alone credit product and usually without loan-style interest.
The third structure is credit cards and instalment conversion through the card-issuing bank, where the pay-later period is granted by the bank through the card limit. All three structures share one feature: the credit grantor, where one exists, is an entity allowed to grant credit. The structure must be settled in a legal document before launch, because changing it after a customer portfolio exists usually means migrating the entire loan book.
Interest caps, fees and consumer transparency duties
In a civil loan outside credit institutions, agreed interest may not exceed 20 percent per year of the loan amount under Article 468 of Civil Code 91/2015/QH13, and the excess is ineffective. For credit granted by a credit institution, interest and fees follow credit institution law and the customer agreement, but remain subject to transparency about the total cost the customer must pay, including interest, late fees and penalty fees.
The BNPL practice drawing the most regulatory and public scrutiny is high late fees and presentation that makes users believe the service is absolutely free. Operators should publish the total amount payable for each tenor right at the point of sale, run reminder and overdue handling that respects debt collection rules, and ensure customers’ credit data is processed under personal data protection law when shared with the funding partner.
Frequently Asked Questions
Does buy-now-pay-later in Vietnam require a licence?
There is no licence specifically named BNPL, but where the model contains credit extension, that activity must be performed by a licensed credit institution under Law on Credit Institutions 32/2024/QH15. An unlicensed technology platform may only act as distribution and technology partner to a bank or finance company, or use a pure commercial deferred payment structure of the seller itself.
Is BNPL treated as credit activity?
BNPL is treated as credit activity when an entity pays the merchant on the buyer’s behalf at the point of sale and then collects that sum over time, with interest or fees that are in substance credit costs. The transaction is then credit extension whatever the marketing label. If instead the seller itself lets the customer pay later under the sales contract with no third-party funder, the relation is commercial deferred payment, not banking activity.
Is there a cap on BNPL interest and fees?
For civil loans outside credit institutions the interest ceiling is 20 percent per year under Article 468 of Civil Code 91/2015/QH13, and the excess is ineffective. For loans through a finance company or bank, interest and fees follow the credit institution mechanism but total customer cost must be transparent. BNPL late and penalty fees should be aggregated when assessing reasonableness and compliance, to avoid fee stacking far above the stated credit cost.
Would a foreign investor’s BNPL be treated as licensed credit activity?
There is a risk of being treated as credit activity requiring permission if the platform funds purchases with its own money for buyers in Vietnam. The safe route for a foreign investor is structuring through a licensed Vietnamese credit institution partner, with the platform keeping the technology and distribution role, or investing in an already licensed financial entity under market access conditions. A self-funded model needs dedicated legal advice before launch.
Bottom line for BNPL operators
BNPL in Vietnam needs no licence of its own, but it needs a lawful credit grantor behind it. Identifying clearly who lends inside the structure, respecting the civil interest ceiling where it applies and making total customer cost transparent are the three conditions for the model to stand.