Creating space for e-wallets to develop safely and healthily

E-wallets are increasingly becoming a familiar payment tool, making an important contribution to promoting cashless payments. On that basis, the State Bank has continued to improve the legal framework to manage and develop this service. To clarify the impact of this change, Banking Times reporter spoke with Associate Professor, Dr. Tran Viet Dung - Director of the Institute of Banking Science Research, Banking Academy.

Thời báo Ngân hàng•02/12/2025

Tạo dư địa cho ví điện tử phát triển an toàn, lành mạnh

How do the legal changes from Decree 94/2025/ND-CP on Controlled Testing Mechanism in the Banking Sector and Circular 41/2025/TT-NHNN amending Circular 40/2024/TT-NHNN regulating the provision of intermediary payment services impact e-wallet operations, sir?

The controlled testing mechanism under Decree 94 creates a “temporary legal safety zone” to test new products, technologies and business models before mass deployment. For e-wallets, the sandbox allows testing of features such as advanced electronic onboarding, biometric KYC or digital linking of financial products within a limited customer scope, thereby perfecting the technology and process without having to comply with all requirements immediately. This mechanism also reduces temporary legal risks, facilitates coordination between businesses and management agencies in building control measures, and provides empirical data for the SBV to assess the impact on financial safety, AML/CFT and security.

Meanwhile, Circular 41 has amended Circular 40 to improve payment capabilities, withdrawal/transfer operations and identification. Highlights include: increasing transaction limits, adding payment guarantee accounts and tightening KYC processes, including biometric verification meetings or accepting legal electronic identification. These adjustments increase security and user protection, but may increase compliance costs and require small organizations to upgrade their capacity to meet new requirements.

In your opinion, is the current legal framework for e-wallets sufficient to both promote innovation and control risks?

The current legal framework has made important progress, but is not completely “sufficient”, but is being improved to achieve a balance between development and risk control. Specifically, the combination of Circular 40, Circular 41 and Decree 94 creates a multi-layered legal toolkit: standardizing operations, tightening payment security and encouraging technology testing. This is the necessary foundation to both promote innovation and manage risks.

However, in the coming time, in my opinion, the legal framework should continue to be supplemented on technology risk management (cybersecurity, data, AI), helping businesses minimize systemic risks. At the same time, accelerate the completion of the interconnected electronic identification infrastructure to facilitate the implementation of digital KYC on a large scale. In addition, the sandbox testing monitoring mechanism and the process of converting testing results into official regulations should continue to be clarified, creating transparency, consistency and encouraging business innovation.

It can be seen that the current legal framework has created an important foundation and further completion of technical components will help the e-wallet ecosystem develop more sustainably and safely.

Decree 94 encourages innovation and experimentation, while new regulations on limits and KYC are tighter. In your view, what will be the next development trend of the e-wallet market?

From increasing transaction limits, tightening identification/authentication, and opening up technology testing that Decree 94 opens, new trends in the e-wallet market will emerge.

First, larger limits allow wallets to serve higher-value transactions, creating opportunities to provide complementary financial services such as micro-credit, savings, and micro-insurance. Next, solvency and KYC requirements force providers to invest in risk management and security technology; wallets with good technology platforms and banking partnerships will have a better competitive advantage. In addition, the sandbox mechanism will promote new cooperation models between wallets, banks, and fintech. For example, consumer credit products based on wallet data and non-traditional credit scores.

The new regulations will also create risk management pressures and compliance costs for small suppliers if these organizations do not upgrade their compliance capabilities and meet capital requirements.

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