SBV Moves Payment Licence Admin to Regional Branches

Vietnam's central bank has reduced the administrative distance between payment operators and their regulator. Circular 22/2026/TT-NHNN, signed by SBV Governor Phạm Tiến Dũng on 19 May 2026 and effective the same day, moves a set of routine payment licensing procedures from SBV's Hanoi head office to regional branches. For the cluster of e-wallet and payment gateway operators headquartered in Ho Chi Minh City, the change means less Hanoi filing for paperwork that should never have required it.

What the Circular Actually Changes#

Circular 22/2026/TT-NHNN has six articles and targets four procedural areas within the Circular 40/2024 framework.

Article 41 — Dossier rejection and consultation timelines. Under the previous rules, an incomplete resubmission could sit unresolved: the Payment Department lacked a clean mechanism to formally reject a dossier where the supplementary filing was deficient but the applicant had not technically missed a deadline. The Circular 22 amendment gives the Director General of the Payment Department authority to return a dossier when the applicant fails to resubmit within the specified timeframe, or when the supplementary dossier does not meet the component requirements listed in the SBV's Official Document. The amendment also reduces consultation timeframes between SBV departments when processing new licence applications — though the specific day-count savings are not available from the published summary.

Article 42 — Lost and destroyed licence reissuance. Reissuance of a lost or destroyed licence is now handled by the SBV regional branch with jurisdiction over the operator's headquarters. Previously, this required filing to Hanoi regardless of where the operator was based. The article also reduces internal consultation time for expired-licence reissuance procedures.

Article 43 — Licence amendment and supplementation. Applications to amend or supplement a licence — including changes to a head-office address — can now be submitted to and processed by the relevant SBV regional branch. This is the most operationally meaningful change for HCMC-headquartered operators, who previously had to route even routine address updates to the Payment Department in Hanoi.

Article 51 — Regional branch mandate formalised. New provisions give SBV regional branches a clear legal mandate to receive and resolve these administrative procedures. The decentralisation is not simply a delegated convenience — it is now a statutory function of the regional branch.

Why This Matters for HCMC-Based Operators#

Ho Chi Minh City is the operational centre of Vietnam's intermediary payment market. MoMo, ZaloPay, VNPay, and Antom are all headquartered there, as are most of the other licensed non-bank payment service providers in the market. Under the previous framework, routine licence maintenance required maintaining a relationship with the Payment Department in Hanoi — a friction that added cost and delay to procedures that carry no substantive regulatory complexity.

The Article 43 change on address amendments is the one practitioners will notice first. Corporate restructuring, office relocations, and legal entity updates all trigger licence amendment filings. For an HCMC-based operator, handling that filing through the HCMC SBV branch rather than dispatching documentation to Hanoi reduces both turnaround time and administrative overhead.

The Article 41 dossier-rejection mechanism matters differently. It protects operators from the opposite problem: a deficient resubmission that the Payment Department could not formally close, leaving the application in an indeterminate state. Formalising the rejection trigger gives applicants a definitive outcome they can act on rather than waiting for informal guidance on whether to refile.

What This Is Not#

Circular 22/2026 does not alter any substantive aspect of the intermediary payment licensing regime. Capital requirements, technology and cybersecurity standards, data-localisation obligations under the applicable cybersecurity decree, and AML compliance obligations are all unchanged. Operators who anticipated relief from the capital bar for new entrants, or faster initial-approval windows, or any form of sandbox pathway, will not find it here.

This is a point worth stating plainly for international firms evaluating market entry. Administrative decentralisation reduces friction for operators already in the licensing pipeline or holding existing licences. It does not lower the bar for entry or change the substantive criteria the SBV applies when reviewing a first-time application.

The Broader SBV Pattern#

Circular 22/2026 is the second amendment to the Circular 40/2024 framework in roughly 18 months — a cadence that suggests active iterative adjustment rather than a settled regime. The SBV has demonstrated the same pattern elsewhere in the payments framework: Circular 45/2025 on biometric verification for bank card issuance is a recent example of procedural amendment reshaping operational requirements without altering substantive licensing criteria. That matters for compliance teams: the procedural rules governing payment licensing have moved twice since the master framework was published, and teams should treat their licensing checklists as living documents rather than fixed references.

The decentralisation trajectory in this Circular also aligns with a broader SBV direction. Decree 198/2026 on SBV organisational restructuring provides the structural context: the shift of routine administrative decisions to regional branches — visible here for payment licensing — builds regulatory capacity in HCMC and reduces the need for HCMC-based operators to file through Hanoi for administrative decisions. For the VIFC-HCMC digital finance hub, which relies on HCMC-based intermediary payment operators as the plumbing for transactions inside the zone, a more capable and authoritative HCMC SBV branch is a direct operational benefit.

Practical Implications#

For licensed intermediary payment service providers headquartered in HCMC:

• Licence amendment filings (including address changes) now go to the HCMC SBV branch, not to Hanoi. Update internal procedures and contact lists accordingly.
• Lost or destroyed licence reissuance follows the same local route. Operators that have deferred this filing because of the Hanoi overhead can now resolve it locally.
• Incomplete resubmissions carry a new formal rejection risk under Article 41. If your application is in the supplementary filing stage, ensure the dossier meets every component requirement listed in the SBV's Official Document before resubmitting — the Payment Department now has clean authority to close the file if it does not.
• New applicants face no change in substantive criteria. The Article 41 consultation-timeline reduction may modestly accelerate the internal review process, but the primary bottlenecks for first-time applicants remain capital adequacy and technology compliance, not interdepartmental consultation.

What to Watch#

The specific day-count reductions in consultation timelines under Articles 41 and 42 are not available from the published sources. Operators should obtain the full Vietnamese-language circular text to confirm the revised day counts before updating internal processing timelines. Operators managing active applications should also request the updated processing schedule from their SBV contact to understand the revised timeline.

The SBV has now amended Circular 40/2024 twice. A third amendment addressing substantive licensing criteria — capital thresholds for new entrants, tiered licensing for smaller operators, or sandbox pathways aligned with the VIFC's digital finance mandate — would represent a more fundamental shift. There is no public indication that such an amendment is in preparation, but the pace of procedural adjustment suggests the SBV's Payment Department is actively reviewing the framework's operational performance.

This article was last updated on 12 June 2026. We will update it as further amendments to Circular 40/2024/TT-NHNN are issued.