On July 16, 2025, the State Bank of Vietnam (NHNN) unveiled a draft circular proposing significant amendments to Circular No. 15, which governs non-cash payment services across the country. Central to this draft is the introduction of strict regulations on the maximum allowable downtime for online payment and intermediary payment services, aiming to enhance service reliability and protect consumer rights in Vietnam's rapidly evolving digital financial landscape.
The NHNN's draft stipulates that the total annual interruption time for all online payment and intermediary payment services must not exceed four hours. Furthermore, any single interruption should last no longer than 30 minutes, except in cases of force majeure or scheduled system maintenance, which must be announced at least three days in advance. Should an interruption extend beyond 30 minutes, service providers are required to report the incident to the NHNN within four hours and submit a detailed report within three working days after the issue is resolved.
This regulation applies broadly to all commercial banks, credit institutions, and intermediary payment entities, including e-wallets, payment gateways, and digital financial platforms—key players in Vietnam's payment infrastructure. The move comes in response to numerous complaints received by NHNN's Payment Department regarding frequent service disruptions, especially during peak periods such as holidays and the Tet festival. Users have reported issues like inability to log into banking apps, failure to scan QR codes for payments, and 'stuck' transactions where funds are deducted from accounts but not received by the payees, causing significant frustration and inconvenience.
Many consumers have also voiced concerns over the lack of official notifications from banks when such disruptions occur, delayed resolution times, and unannounced maintenance activities. The NHNN emphasized that these new regulations are intended to hold service providers accountable, increase transparency, and ultimately ensure that customers are not left in the dark when issues arise.
To further enhance transparency, the draft mandates that service providers publicly disclose their maintenance schedules and service interruption times. Additionally, if an unplanned shutdown is necessary, providers must inform customers at least 24 hours in advance. This requirement is designed to empower users to plan accordingly and reduce the impact of unexpected service outages.
The NHNN is not only looking inward but also aligning Vietnam's regulatory framework with international best practices. Globally, most countries impose a maximum annual downtime of around four hours for financial services. In Asia, countries like Singapore and China maintain similar standards, requiring periodic system checks, contingency planning, and comprehensive reporting to ensure service continuity.
European Union nations often enforce even stricter rules, limiting downtime to just 15 minutes per incident. Banks there are mandated to have robust backup systems and contingency plans to minimize service interruptions. Violations of these regulations can lead to severe penalties, including hefty fines and license revocations, underscoring the importance of uninterrupted service in the financial sector.
Beyond downtime regulations, the draft also introduces new measures to combat payment fraud. It requires payment service providers to verify the legality and validity of payment orders, ensuring that account numbers and names match customer agreements and are fully displayed on payment documents. This addition addresses a growing concern where fraudsters exploit the use of aliases or nicknames instead of official account identifiers to impersonate reputable brands and deceive customers. Such practices can also lead to accidental money transfers due to incomplete information during payment processing.
Moreover, the draft tightens oversight on collection and payment services conducted through public postal enterprises like VNPost and Viettel Post. These entities must now enter into clear contracts with customers outlining transaction processing times, compensation responsibilities, transaction locations, and service fees. Postal employees are required to verify legal documents and customer identities before executing transactions, with a mandated processing time of one working day. This move aims to increase transparency and protect customer rights in non-bank financial services.
Industry experts have welcomed the NHNN's proactive approach. Pham Tien Dung, Deputy Governor of the State Bank of Vietnam, noted that many banks have established dedicated data units akin to traditional credit departments, with several elevating IT risk to the same level as credit risk. This evolution reflects the growing recognition of technology's critical role in banking operations and the necessity of stringent service quality standards.
Vietnam's banking sector has also seen notable achievements recently. For instance, BIDV was honored as the "Best Forex Bank Vietnam 2025" by Global Banking & Finance Review, affirming its leadership in the foreign exchange market. Meanwhile, several banks are exploring new ventures, including establishing insurance companies, signaling a dynamic and expanding financial ecosystem.
However, as credit growth accelerates, concerns about risk management persist. Experts emphasize the need for robust safeguards, particularly in capital adequacy, to ensure sustainable economic growth. The NHNN's proposed regulations on payment service interruptions fit into this broader strategy of strengthening financial system resilience.
For consumers, these regulatory changes promise a future with fewer service disruptions and greater clarity when issues arise. The days of unexplained "stuck" transactions and silent outages may soon be behind them, replaced by a more accountable and transparent digital payment environment.
As the NHNN continues to solicit feedback on the draft circular, the banking and fintech sectors, alongside consumers, await the final regulations that could reshape Vietnam's non-cash payment landscape for years to come.
