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Vietnam’s New Mobile Money Framework: Key Regulatory Developments under Decree 368
With Decree No. 368/2025/ND-CP taking effect on 1 January 2026, Vietnam has moved from a pilot model to a permanent legal framework for Mobile Money. The new regime defines how licensed telecommunications operators may offer mobile-based payment services and sets the regulatory parameters for a market that is becoming increasingly relevant for digital commerce.
The decree allows telecommunications operators holding the appropriate licences to offer Mobile Money services - that is, payment accounts linked to a mobile phone number, allowing users to make payments, send money, and top up or withdraw cash without a bank account.
As a result, technology providers, compliance consultants, and other service partners supporting Mobile Money providers will need to understand the technical and regulatory standards introduced under the new regime.
Although foreign investors remain restricted from directly operating Mobile Money services, the framework is still commercially significant for international stakeholders. Merchants, technology providers, and other business partners should consider how the new rules may affect service design, partnerships, and compliance expectations in the Vietnamese payments ecosystem.
Contributed by Luther Vietnam
Vietnam’s New Investment Rulebook: What Decree 96 Means for Foreign Investors
Decree 96/2026/ND-CP provides the detailed implementation framework for Vietnam’s Law on Investment 2025 and reshapes several aspects of the foreign investment process. The new rules affect how projects may be structured and licensed, including more flexible timing for company establishment and a registration-based route for certain projects in designated zones.
Key changes include greater flexibility to set up a company before obtaining an Investment Registration Certificate (IRC) – the core approval a foreign investor needs for a project – and a new registration-based licensing route for eligible projects in designated zones (such as industrial parks, high-tech parks, and free trade zones), which may speed up implementation.
At the same time, foreign investors in intermediary e-commerce platforms may face additional market-access restrictions, and businesses will need to comply with new quarterly reporting requirements.
For foreign investors, the main implication lies in reassessing investment planning from the outset - not only in terms of market entry and licensing, but also with regard to market-access conditions and ongoing reporting duties. Early structuring decisions will be important in making full use of the new options while staying compliant.
Contributed by Luther Vietnam
