A fintech licence has no regional passport: an e-wallet successful in Vietnam expanding to Thailand or Indonesia must apply again from scratch in each country, and the biggest legal risk of Southeast Asian expansion is assuming the domestic compliance model can be copied abroad wholesale.
Legal basis to know
Unlike some market blocs with licence recognition mechanisms, ASEAN has no passporting for payment and e-money licences, so a Vietnamese fintech must incorporate or acquire a local entity and obtain a licence under each host country’s law — for example a payment service licence in Thailand under that country’s payment systems law, or a payment service provider licence in Indonesia under Bank Indonesia regulations. On the Vietnamese side, outward investment must comply with the Investment Law 143/2025/QH15, which replaced Investment Law 61/2020/QH14 from 1 March 2026, together with foreign exchange rules on outward investment capital accounts. Transferring customer data to the foreign entity must simultaneously satisfy the transfer impact assessment dossier under the Personal Data Protection Law 91/2025/QH15 and the receiving country’s data law.
How this applies in practice
Three legal risks recur in most expansions: underestimating host-country foreign ownership conditions and capital requirements, forcing deal structures to be redone after announcement; Vietnamese customer data being moved into regional systems before the cross-border transfer dossier is complete; and tax and foreign exchange duties on moving capital out and profits back not being designed from the start. The safe roadmap is a licence map for each country before choosing the first one, because expansion order decides compliance cost for the whole region.
What to do now
- Build a licence, ownership condition and capital map for each target country before deciding expansion order.
- Design the regional data architecture to segregate Vietnamese customer data and complete the cross-border transfer dossier before integrating systems.
- Prepare the outward investment file and capital account under Vietnamese investment and foreign exchange law in parallel with host-country procedures.
Frequently Asked Questions
What licences does a Vietnamese fintech need to operate in Thailand or Indonesia?
In each country the fintech needs a local entity and a payment or e-money licence under that country’s law — for example a licence under Thailand’s payment systems law issued by its central bank, or a payment service provider licence in Indonesia under Bank Indonesia regulations — plus each country’s capital and foreign ownership conditions.
Can the Vietnamese e-wallet model be applied abroad?
The product model can travel, but the legal model cannot: a Vietnamese licence has no validity in another country, and wallet limits, identification requirements and customer fund protection rules are all re-prescribed by host law, so each market is an independent licensing and compliance project.
What is needed to transfer customer data when expanding abroad?
The company must complete the cross-border personal data transfer impact assessment dossier under the Personal Data Protection Law 91/2025/QH15 for Vietnamese customer data, simultaneously satisfy the receiving country’s data protection law, and design minimal data flows with customer consent where the law requires it.
This article has been quality-reviewed by the FLAW AI Legal Council