Five-Minute Data, Planned Inspections: How the State Bank Will Watch Payment Rails and E-Wallets from July 2027

Every bank transfer between two Vietnamese banks, every card swipe routed through a domestic switch and every top-up of an e-wallet passes through infrastructure that the State Bank of Vietnam (SBV) treats as systemically important. Thông tư 47/2026/TT-NHNN rewrites how the SBV watches that infrastructure. The circular is short (10 articles), but it replaces five appendices of reporting indicators. It also gives fintech companies a long runway: the main rules start on 1 July 2027, and the near-real-time monitoring indicators on 1 October 2027. The SBV published the consolidated text on 6 October 2026, so the full post-amendment rulebook is now available to read.

The document

Number and title: Thông tư 47/2026/TT-NHNN “Sửa đổi, bổ sung một số điều của Thông tư số 41/2024/TT-NHNN quy định về giám sát và thực hiện giám sát các hệ thống thanh toán quan trọng, hoạt động cung ứng dịch vụ trung gian thanh toán” (amending Circular 41/2024 on supervising important payment systems and payment intermediary services).
Issuer: the Governor of the State Bank of Vietnam, on the proposal of the Payments Department (Vụ Thanh toán).
Date: 24 September 2026.
Effective: 1 July 2027 (Điều 9 khoản 1). Two monitoring sections, mục 3 of Phụ lục III and mục 3.3 of Phụ lục IV, apply from 1 October 2027 (Điều 9 khoản 2).
Parent rule: Thông tư 41/2024/TT-NHNN of 17 July 2024. It is now consolidated as Văn bản hợp nhất 111/2026/VBHN-TT-NHNN (6 October 2026).
Who must comply (Điều 10): SBV units, operators of important payment systems, payment intermediaries (e-wallets, payment gateways, collection and disbursement support), and the banks and foreign bank branches that work with them.

What changes

1. The supervised list now covers every licensed switch

Phụ lục II lists the “important payment systems”. Under the 2024 version, the clearing and switching entry named a single operator: Công ty cổ phần Thanh toán Quốc gia Việt Nam (NAPAS). The replacement appendix names a category instead: “các tổ chức được Ngân hàng Nhà nước cấp phép cung ứng dịch vụ chuyển mạch tài chính, dịch vụ bù trừ điện tử”, meaning any organisation the SBV licenses for financial switching and electronic clearing. The other three entries are unchanged: the national interbank system (Hệ thống TTLNH Quốc gia), Vietcombank for foreign-currency payments, and BIDV for securities-trade cash settlement. Reporting on the draft, Doanh nghiệp Hội nhập noted that the SBV had already licensed MobiFone Digital Payment (Công ty Cổ phần Thanh toán số MobiFone) for switching and clearing. A second switch therefore no longer escapes oversight just because the appendix lists NAPAS by name.

2. On-site inspections no longer need a red flag

Under the old Điều 7, the supervisor could inspect an operator on site only after finding missing, wrong or unremedied data, or a risk that needed more information. The circular itself then spelled out the procedure: a Governor’s decision, five working days’ notice, signed minutes, and a report within 30 working days. The new Điều 7 lets the SBV inspect according to its inspection plan, as well as ad hoc on the Governor’s instruction or when the old triggers occur. Procedures now follow the Governor’s rules and the law on specialised inspection rather than the circular. Operators must also provide staff and equipment so inspectors can check data on their IT systems. Điều 12 khoản 2 applies the same procedural change to inspections of payment intermediaries.

3. Supervisory data gets storage and secrecy rules

A new Điều 4a requires the SBV to keep collected supervisory documents and data under the archives law. Their confidentiality follows banking-secrecy rules.

4. The SBV’s internal map is redrawn

The circular follows the SBV’s 2025 reorganisation. The old “Cơ quan Thanh tra, giám sát ngân hàng” becomes the SBV Inspectorate (Điều 21). The duty to flag banks under early intervention or special control moves to the new Cục Quản lý, giám sát tổ chức tín dụng (Điều 21a). Provincial branches become regional branches (Điều 22). A new Điều 21b requires the Anti-Money Laundering Department to pass on the results of its AML checks on payment intermediaries.

5. New indicators, some of them near real time

The replaced appendices are where the engineering work lies.

Interbank system (Phụ lục III, mục 3, from 1 October 2027): indicators R-28 to R-40. They cover the share of volume and value sent by the five largest members, average processing time per transaction in milliseconds, throughput in transactions per minute, queue times, the share of payments queued, liquidity pressure, overdraft-limit usage and settlement processing times. Most raise alerts when a threshold set by the supervisor is crossed.
Switching and clearing (Phụ lục IV, mục 3.3, from 1 October 2027): indicators R-6 to R-14. They track each member’s clearing limits and usage, and flag any member that has sent no outgoing Internet or mobile transfers for more than 30 minutes or has suspended service for over 30 minutes. They also measure timeout rates every 15 minutes, error-response rates every 30 minutes, hourly average processing time and capacity. Indicators reported “thường xuyên” (continuously) must reach the SBV with a data delay of no more than five minutes.
Partner banks (Phụ lục V): monthly figures by partner intermediary. These include intermediaries the bank works with to let customers pay for foreign goods and services, VND accounts and debit cards linked to e-wallets, flows through the e-wallet guarantee account, and any payment-assurance measures other than the guarantee account agreed for collection and disbursement services.
Intermediaries themselves (Phụ lục VI): quarterly and annual templates for gateways, e-wallets and collection/disbursement support. Each provider reports its apps and websites, partner banks, merchant counts split into individuals, organisations and household businesses, and QR-code acceptance. A new item, G-7, requires a list of foreign partners the provider works with to serve customers paying for foreign goods and services. E-wallet providers report wallets issued, activated, active (at least one monetary transaction in the past 12 months) and closed. They also report outage hours, and the number and value of transactions linked to fraud and scams.

Who is affected and what to do

NAPAS, MobiFone Digital Payment and future switch licensees: budget for a monitoring feed to the SBV with alerting-grade indicators and at most five minutes of delay by 1 October 2027.
E-wallet, gateway and collection/disbursement companies: map your data warehouse to the new Phụ lục VI codes before July 2027. The foreign-partner list and the merchant split by type and QR acceptance need clean master data. Expect planned, not just triggered, inspections, and be ready to give inspectors staff and access to systems.
Banks partnering with fintechs: Phụ lục V reporting is monthly and broken down by partner, including foreign-payment arrangements and non-account payment-assurance measures.
Consumers: nothing changes directly. Faster detection of outages, timeouts and liquidity strain should reduce the “transfer pending” incidents users notice.

Open questions

The alert thresholds are set by the supervisor “phù hợp với yêu cầu giám sát trong từng thời kỳ”, that is, as supervision needs dictate at the time. They are not published in the circular, so operators cannot yet size their tolerances.
The detailed inspection procedure now sits in a separate Governor’s regulation and the specialised-inspection law. Firms should watch for that instrument.
The VNBA summary refers to the switching category being moved into Phụ lục I. The signed text and the consolidated version put the list in Phụ lục II. This post follows the legal text.

Sources

This post is general information, not legal advice.