The question ‘payment intermediary license or digital bank license’ contains a misconception to fix before comparing: Vietnam currently has no standalone license category called a digital bank license. A digital bank is a digitally operated model inside a full commercial bank license under the Law on Credit Institutions 32/2024/QH15. The real choice is between holding customer money in custody in a guarantee account, or being a true bank with the right to take deposits and lend.
The essential difference: custody money versus deposits
A payment intermediary licensed under Decree 52/2024/ND-CP supplies services such as e-wallets, payment gateways and collection/disbursement. Customer money in a wallet is not a deposit: it sits in the organisation’s guarantee account at a bank, the organisation may not use it, may not pay deposit-style interest on it, and absolutely may not lend from it. The intermediary earns from payment service fees, not from interest margins.
A bank — even one operated fully digitally — is a credit institution: it may take customer deposits into accounts owned by customers at the bank, may use mobilised funds to extend credit as regulated, and bears the State Bank’s full safety supervision such as reserve requirements, capital safety limits and deposit insurance for depositors. This boundary is the deepest dividing line between the two licenses: one side is a payment pipeline, the other a true financial intermediary. The intermediary license dossier and procedure are analysed in FDI-LC-0900; this article only compares to choose the model.
Capital and licensing time compared
On capital, the payment intermediary conditions in Article 22 of Decree 52/2024/ND-CP set paid-in charter capital at VND 50 billion for the e-wallet and payment gateway group, and VND 300 billion for the financial switching and electronic clearing group. On the bank side, the minimum statutory capital of a commercial bank is VND 3,000 billion — sixty times the wallet license level — before counting shareholder, governance, control-system and facilities requirements attached to founding a credit institution. The capital gap mirrors the rights gap exactly: taking the public’s deposits and lending them is the most expensive privilege in the financial system.
On time, the intermediary license procedure has a clear written timeline in Article 24 of Decree 52/2024/ND-CP: the State Bank confirms the dossier within 05 working days, organises appraisal within 90 working days, and the license is valid for 10 years — although in practice the scheme-preparation and technical-readiness stage before filing usually runs far longer than the official appraisal figure. Founding a new bank has no comparable shortcut: it is a licensing decision at the system’s highest level, demanding preparation and appraisal over years, and foreign investors in practice usually choose buying shares in an existing bank or other permitted presence forms under credit institution law instead of founding a new bank.
Which model to choose
Choose the payment intermediary license when the business problem is payments: e-wallets, gateways for e-commerce, collection networks, merchant services — where revenue comes from transaction fees and value lies in a frequently transacting user base. Choose the bank path when the ambition is full financial products: deposit accounts, credit cards, lending, and margin from credit activity; the price is capital in the thousands of billions, credit risk governance and the full compliance burden of a credit institution.
The practical route for many FDI groups is a ladder: start with the intermediary license to build the customer base and payment infrastructure, while partnering with a bank for deposit and credit products standing in the bank’s name. The single taboo in every structure is blurring the boundary: an intermediary advertising wallet balances as ‘interest-bearing deposits’, or suggesting its wallet is ‘like a bank’ — that breaches the license’s very nature and is the conduct regulators punish most heavily among intermediary behaviours.
Frequently asked questions
How does running an e-wallet differ from opening a digital bank?
They differ in nature: a payment intermediary (Decree 52/2024/ND-CP) only supplies payment services — customer money sits in a guarantee account, is not a deposit, cannot be lent and earns no deposit interest. A digital bank has no license of its own: it is a commercially licensed bank operated digitally under the Law on Credit Institutions 32/2024/QH15, entitled to take deposits and extend credit like any bank.
How much charter capital does each model need?
Intermediary: VND 50 billion for the e-wallet/gateway group and VND 300 billion for switching and clearing under Article 22 of Decree 52/2024/ND-CP. Commercial bank: minimum statutory capital of VND 3,000 billion — sixty times the wallet license level — plus shareholder, governance and control conditions for founding a credit institution.
Which model may take deposits?
Only a bank may take deposits. A payment intermediary absolutely may not take deposits — wallet money is customer funds held in a guarantee account, not at the organisation’s disposal, and not covered by deposit insurance like bank deposits.
How long does licensing take for each type?
The intermediary has a clear written timeline: dossier confirmation in 05 working days, appraisal in 90 working days, license valid 10 years (Article 24, Decree 52/2024/ND-CP), though scheme preparation in practice takes longer. Founding a new bank has no shortcut: preparation and licensing appraisal run over years, so foreign investors usually buy into an existing bank or use other presence forms under credit institution law.
This article has been quality-reviewed by the FLAW AI Legal Council