What an offshore merchant really needs to get paid in Vietnam

The methods Vietnamese buyers actually use

MoMo is the largest e-wallet and functions as a national-level app covering bill payment, transfers, QR scanning and shopping. ZaloPay is tied to the Zalo messaging ecosystem and has a sticky user base. Viettel Money extends reach through the telecom operator's physical distribution, which matters outside the big cities. Underneath the wallets sits the bank layer: NAPAS runs the national switching and clearing infrastructure, and VietQR is the unified QR standard that lets one code be paid from any participating bank app. Card penetration is limited, so cards play a smaller role than in most Western markets. Cash on delivery retains a real share of e-commerce, particularly for first-time buyers and for orders outside the major urban centres, and it brings the usual logistics and returns burden with it. Each reaches a different buyer, so breadth of coverage matters more than picking a single winner.

• Treat wallets as the primary checkout methods rather than an alternative to cards.
• Add VietQR so bank-app buyers can pay from a single interoperable code.
• Expect cash on delivery to matter more in Vietnam than in most of Southeast Asia.
• Check whether your provider covers MoMo, ZaloPay and Viettel Money, or only one.

What the regulations actually say

Vietnam replaced its non-cash payments framework with Decree 52/2024/ND-CP, issued in May 2024 and effective from July 2024, and the State Bank of Vietnam followed with Circular 40/2024/TT-NHNN regulating intermediary payment services, effective in July 2024. Intermediary payment services include e-wallet services, payment gateway services, financial switching and electronic clearing, and collection and payment support services. These are conditional business lines under direct state management by the central bank. Decree 52 also raised the bar for licensing, including higher minimum charter capital for switching and clearing activities and stricter experience requirements for legal representatives. For a foreign business the practical consequence is that providing payment services in Vietnam is a licensed activity, and you cannot simply offer wallets or a payment gateway to Vietnamese residents without addressing that. The detail shifts, so confirm the current position with local counsel rather than relying on summaries.

• Treat e-wallet and payment gateway services in Vietnam as licensed activities, not open APIs.
• Confirm which licensed Vietnamese entity stands behind any provider you are evaluating.
• Ask your provider how Decree 52 and Circular 40 affect the specific products you want.
• Take local legal advice before describing yourself as a payment provider in Vietnam.

The two routes for a foreign business

Vietnamese law recognises two ways for a foreign organisation to participate. The first is cross-border provision without a commercial presence: the foreign organisation does not provide the service directly, but works through a Vietnamese commercial bank or foreign bank branch approved by the State Bank to participate in that organisation's international payment system. Importantly, this route is scoped narrowly to non-residents and to foreign residents in Vietnam paying for lawful goods and services inside the country. It is designed for serving existing international customers, such as visitors and expatriates, rather than for reaching the domestic mass market. The second route is to establish a Vietnamese entity and apply for a licence to provide intermediary payment services, which carries minimum charter capital requirements, personnel qualifications, a resident legal representative, and a consultation process with the central bank because payment services are not covered by Vietnam's WTO services commitments.

• Check whether your target customers are residents or non-residents, because that determines the route.
• Assume the cross-border route does not give you mass-market domestic reach by itself.
• Budget realistically for the capital and personnel conditions of the local licence route.
• Take specialist Vietnamese legal advice before choosing between the two.

What an offshore merchant realistically does instead

Most foreign merchants selling into Vietnam do not become payment providers at all. They sell to Vietnamese buyers using a cross-border payment provider that holds the local relationships, and they receive settlement offshore. That keeps the merchant on the selling side of the line rather than the regulated service side. What you must still get right is the commercial plumbing: prices displayed in dong, local methods offered at checkout, a returns and refund process that works without card chargebacks, and a logistics partner able to handle cash on delivery if you offer it. Foreign exchange management rules apply to cross-border fund movements, so the repatriation path and any documentation the receiving bank requires should be confirmed before launch rather than discovered during your first payout. Ask also what happens if the provider changes its licence or local banking relationship mid-contract.

• Sell through a provider that holds the Vietnamese licence, rather than becoming a provider yourself.
• Confirm the repatriation path and documentation requirements with your own bank first.
• Display prices in dong and localise the checkout rather than converting at the payment step.
• Build a refund process that works without a card chargeback mechanism.

Costs and settlement to pin down

Wallets, bank transfers and cards are priced differently, and the visible rate is only part of the total. Ask separately about the transaction fee per method, any fixed per-transaction charge, the FX spread applied when dong are converted to your settlement currency, a settlement or payout fee, a refund fee, a chargeback fee where cards are involved, a monthly minimum, any setup fee, and whether a rolling reserve applies. Ask how cash-on-delivery orders that are refused at the door are billed, because that cost lands somewhere and it is easy to discover it on the first invoice. Public pricing is only a first filter. Actual pricing changes with country, industry, volume, settlement currency, integration method and contract terms. Confirm against the provider's official pricing page or a written quote before you go live.

• Ask for a per-method fee schedule instead of one blended percentage.
• Ask who bears the cost of a refused or returned cash-on-delivery order.
• Ask whether the quoted rate includes the FX margin or excludes it.
• Ask for the payout calendar, cut-off times and any minimum settlement amount.

A build order and the things that go wrong

Start with MoMo, since it is the largest wallet, then add ZaloPay, then VietQR for bank-app buyers, then Viettel Money if your audience sits outside the major cities. Add cards for higher ticket sizes and for buyers who expect them, and treat cash on delivery as a deliberate decision with logistics costs modelled rather than a default. The failure modes are fairly consistent: merchants discover too late that the cross-border route does not reach resident mass-market buyers; refunds on wallets turn out to need a manual process; dong payouts arrive on a cycle that was never written down; and cash-on-delivery return rates quietly erase the margin on an order. Each of those is avoidable with questions asked before integration rather than after. Write the answers down before you sign, rather than discovering them after the first payout disappoints.

• Launch MoMo first, then ZaloPay, then VietQR, in that order.
• Model cash-on-delivery return rates before enabling it as a checkout option.
• Confirm the wallet refund process end to end before you need it.
• Write down the payout cycle, cut-offs and minimums before you sign.

Questions merchants ask

Public sources

• State Bank of Vietnam - official portal
• NAPAS - national payment switching and clearing network
• MoMo - official site
• Vision and Associates - highlights of Circular 40/2024/TT-NHNN on intermediary payment services