The Role of Foreign Investors in Vietnam’s Growing E-Wallet Industry 

3 minutes
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Premia TNC Vietnam Team

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Vietnam is one of the fastest-growing digital payment markets in Southeast Asia, with demand for e-wallets and fintech services steadily increasing. However, e-payments and fintech services are financially related industries and face strict regulations on foreign investment (FDI), making it difficult for foreign companies to enter the market independently. 

In this article, we will take a closer look at foreign investment restrictions, required licensing and operating requirements, key market players, and realistic entry strategies for Vietnam’s e-wallet business

FDI Regulations Shaping Vietnam’s E-Wallet Market

Operating an e-wallet or fintech business in Vietnam requires obtaining a “Payment Intermediary Services” license, which is strictly regulated by the State Bank of Vietnam (SBV).  

Currently, the Vietnamese government does not allow 100% foreign direct investment (FDI) in the e-wallet business, and entry is only possible through joint ventures with local companies.  

Key Operating Restrictions Related to Foreign Investment

Restrictions Related to Foreign Ownership 
  • This business line has not been committed by Vietnam in the WTO schedule of commitments, so there are no regulations on the maximum foreign ownership ratio. However, it is impossible for a 100% foreign investment (FDI) corporation to operate an e-wallet business solely on its own. In practice, the approved foreign ownership ratio is typically below 49%, depending on each case and the review and approval of the state authority. 
  • A corporation can only be established in the form of a joint venture with a local Vietnamese company. 
  • To operate an e-wallet business, Vietnamese law requires a minimum paid-up capital of VND 50 billion (approximately USD 2 million). 
  • Considering the initial operating costs, substantially higher capital may be required.  
Payment Intermediary Service License Requirement 
  • To operate an e-wallet business, you must obtain a Payment Intermediary Service License from the State Bank of Vietnam (SBV). 
  • To obtain the license, you must meet capital requirements, technology infrastructure, security regulations, and internal audit systems. 
  • The approval process can take at least 6 months to a year or more. 
Mandatory Partnership with a Local Bank 
  • To operate an e-wallet business, you must enter into a merchant agreement with a bank licensed in Vietnam. 
  • This process involves the bank’s internal screening process, so thorough preparation is required before entering the market. 

 

Major Players Driving Vietnam’s E-Wallet Market

E-Wallet 

Primary Information 

Market Share 

Momo 

Vietnam’s largest e-wallet partners with banks, telecom companies, and large corporations. 

60% or higher 

ZaloPay 

Payment service linked with Zalo, Vietnam’s largest messenger 

15% 

VNPay 

An electronic wallet linked to a bank payment system. This payment service is highly reliable, as it is linked to Vietnam’s state-owned banks. 

10% 

ShopeePay (formerly AirPay) 

Payment service linked with Shopee and SEA Group, Southeast Asia’s largest e-commerce platform. 

8% 

SmartPay 

Fintech startup-based services targeting small and medium-sized businesses 

5% or lower 

 

Crafting a Viable Market Entry Strategy in Vietnam

When establishing a fully foreign-owned entity in Vietnam is challenging, businesses can consider alternative entry strategies: 

Strategy 1: Joint Venture with a Local Vietnamese Company 

  • Limit foreign ownership to 49% or less by forming partnerships with local firms. 
  • Collaborate with established Vietnamese fintech companies to simplify licensing and accelerate market entry. 

 Strategy 2: Provide Fintech Solutions Through Partnerships 

  • Instead of operating a standalone e-wallet, partner with major players such as VNPay, MoMo, and ZaloPay. 
  • Focus on niche opportunities like cross-border remittance services (e.g., Korea–Vietnam) and e-commerce payment solutions. 

 Strategy 3: Utilize Hong Kong or Singapore Holding Companies 

  • Establish an intermediate holding structure in Hong Kong or Singapore to invest in Vietnam. 
  • Design a structure that enhances scalability and tax efficiency across Southeast Asia. 

Opportunities Exist in Vietnam’s E-Wallet Market

Operating an e-wallet business in Vietnam as a 100% foreign-owned entity is not permitted. A joint venture with a local company is required, with foreign ownership capped at 49% (depending on each case). Additionally, businesses must secure a license from the State Bank of Vietnam (SBV) and meet minimum capital requirements. 

The market is highly competitive, dominated by established players such as MoMo, ZaloPay, and VNPay, making differentiation essential for new entrants. Alternative entry strategies include partnering with existing fintech firms or leveraging holding structures in Hong Kong or Singapore to facilitate operations and compliance. 

Premia TNC’s Assistance for Market Entry

The process of establishing a business in Vietnam can be challenging for businesses due to the various administrative procedures and stringent requirements. In particular, incorporation and tax reporting processes require expert understanding of Vietnam’s laws and accounting systems. 

Premia TNC streamlines these complex processes and helps businesses navigate the entire process smoothly through expert advice and customized services. We will be a reliable partner from start to finish, ensuring your company’s successful entry into Vietnam. 

Picture of Premia TNC Vietnam Team
Premia TNC Vietnam Team

Author

Premia TNC Vietnam is a dynamic team of experts dedicated to supporting businesses and entrepreneurs as they establish, manage, and grow their presence in Vietnam and across the region. Premia TNC Vietnam specializes in providing tailored corporate services, from company incorporation and compliance to tax planning and accounting. With our extensive experience and deep understanding of the local regulatory environment, we are here to make business operations smoother and more efficient.