In the age of comprehensive digital transformation, cashless payments have become a widespread method, driving the growth of fintech platforms.
Intermediary Payment Service Providers (IPS Providers) play a central role in connecting users to the broader banking and financial ecosystem.
The license for providing intermediary payment services is a mandatory legal requirement for organizations to operate the following services: financial switching services, international financial switching services, electronic clearing services, e-wallet services, collection and payment support services, and electronic payment gateway services.
Organizations are required to carry out the license reissuance procedure when:
If the reissuance procedure is not performed promptly or is carried out incorrectly, the organization may face operational disruptions, penalties, or even loss of the right to provide services, as regulated by the State Bank of Vietnam.
So, what does an organization need to prepare in order to be reissued a license for providing intermediary payment services? CDR Counsels will walk you through each step and requirement, based on the latest legal foundations from Decree No. 52/2024/NĐ-CP dated May 15, 2024, on non-cash payment regulations (“Decree 52”), Circular No. 40/2024/TT-NHNN dated July 17, 2024, on regulations for intermediary payment service provision (“Circular 40”), and administrative procedure code 1.002031, officially published on the National Public Service Portal.
According to Clause 2 Article 28 of Decree No. 52/2024/NĐ-CP, licensed organizations must submit a reissuance application at least 60 days before the expiration date stated on the license. This ensures service continuity and minimizes legal disruption risks..
If the license becomes unusable due to physical damage or other objective circumstances, the organization may apply for reissuance. As per guidance from the State Bank of Vietnam and Decree 52, the reason must be clearly stated in the application and the correct form must be used.
Important Note: An IPS license is not issued to regular enterprises or cooperatives, but only to organizations legally established and operating under Vietnamese law with clearly defined financial, technological, and risk management capabilities.
Depending on the reason for reissuance, the legal dossier must include the following:
As outlined by the National Public Service Portal, the dossier includes:
Application for license reissuance in accordance with Form No. 11 issued with Decree 52/2024/NĐ-CP.
Report on the implementation of Licensed activities from the date of issuance to the date of the application.
A copy of the currently valid license.
Other supporting documents demonstrating that the enterprise meets the licensing conditions for providing intermediary payment services, as required by the State Bank of Vietnam. These include, but are not limited to, compliance with the provisions of Decree 52, Circular 40, the 2022 Anti-Money Laundering Law, and regulations related to ensuring safety and information security in the financial and banking sector.
Number of sets: 3 original sets.
The organization only needs to submit:
Number of sets: 3 original sets.
Procedure and Methods of Submission
Step 1: Submit the Application
The organization may choose one of the following four methods::
Step 2: Government Review and Evaluation
The State Bank of Vietnam is the authority responsible for reviewing and assessing the validity of submitted dossiers. If the application is incomplete or invalid, the organization will receive formal written notice stating the reason for rejection or a request for clarification.
| Reissuance Scenario | Processing Time (Working Days) |
| License expiration | 30 days from the date of receiving a complete dossier |
| Lost, torn, burned, or destroyed license | 10 days from the date of receiving a complete dossier |
Review, assess, and update internal regulations and procedures to ensure compliance with relevant legal provisions before applying for license reissuance - especially for organizations undergoing expansion or changes in technology or personnel.
Avoid submitting the application too close to the deadline. If the submission is made less than 60 days before the license expiration date, the State Bank of Vietnam may reject the application or require a complete resubmission.
Ensure the application dossier is complete and accurate, including proper signatures, seals, and the required number of original documents, in accordance with regulations
Most importantly, choose a consulting firm with a team of experts specializing in the enterprise’s field of operation and with proven experience in preparing reissuance applications for intermediary payment service providers.
The reissuance of License for Provision of Payment Intermediary Services is a crucial legal procedure – not merely an extension of operations, but a formal reaffirmation of the organization’s ability to comply with regulations in the financial – technology sector.
CDR Counsels has successfully assisted numerous Fintech organizations in preparing and submitting license reissuance applications to the State Bank of Vietnam. We offer:
Contact CDR Counsels today for expert guidance and support.
