Transaction limits for payment agents from July 1, 2024 in Vietnam

Recently, the State Bank issued Circular 07/2024/TT-NHNN on June 21, 2024, regulating payment agent activities, effective from July 1, 2024.

1. Transaction limits for payment agents from July 1, 2024 in Vietnam

According to Clause 1, Article 3 of Circular 07/2024/TT-NHNN, payment agent activities are defined as the principal payment agency authorizing the payment agent to perform part of the process of opening payment accounts, issuing bank cards, and providing payment services to customers.

In particular:

- The principal payment agent includes commercial banks, cooperative banks, and branches of foreign banks (hereinafter referred to as the principal).

- The payment agents include commercial banks, cooperative banks, branches of foreign banks, people’s credit funds, microfinance institutions, and other organizations (hereinafter referred to as agents).

According to Article 5 of Circular 07/2024/TT-NHNN, the transaction limits for payment agents are as follows:

- The principal must manage the balance and transaction limits of the agent, which are other organizations, including:

+ Transaction limits (including deposit and withdrawal transactions) for individual customers, a maximum of 20 million VND/customer/day;

+ The agent is only allowed to conduct transactions for customers within the account balance to perform agency tasks assigned by the principal at the agent’s account accordance with Clause 4, Article 7 of Circular 07/2024/TT-NHNN, and each payment agent can transact no more than 200 million VND/day and a maximum of 5 billion VND/month.

- Transaction limits for agents which are commercial banks, cooperative banks, branches of foreign banks, people’s credit funds, and microfinance institutions are based on agreements between the principal and the agent.

Thus, in Vietnam, the transaction limit for individual customers is a maximum of 20 million VND/customer/day, and each payment agent can transact no more than 200 million VND/day and a maximum of 5 billion VND/month.

2. Principles for conducting payment agent activities in Vietnam

According to Article 7 of Circular 07/2024/TT-NHNN, the principles for conducting payment agent activities in Vietnam include:

(1) Payment agent activities must be established through a written contract between the principal and the agent as stipulated in Circular 07/2024/TT-NHNN and other relevant regulations.

(2) The principal is permitted to delegate the agent to perform the tasks specified in Article 4 of Circular 07/2024/TT-NHNN and aligned with the content stated in the Establishment and Operation License or Establishment License or Decision on Organization and Operation issued by competent authorities, as well as any amended or supplemented licenses or decisions (if any) of the principal, for agents who are credit institutions or branches of foreign banks.

(3) Agents are not allowed to sub-delegate payment agency tasks to third parties.

(4) When conducting the tasks specified in Clause 3, Article 4 of Circular 07/2024/TT-NHNN, agents that are other organizations must open and maintain a payment account at the principal to perform the assigned tasks within the agreed balance between the principal and the agent; this payment account must be separated from other payment accounts for different activities and purposes of the agent opened at the principal.

(5) The principal collects fees from customers through the agent according to the fee schedule set by the principal in each period. The principal and the agent are not allowed to collect additional fees outside the fee schedule stipulated and published by the principal. The service fee schedule of the principal must clearly state the types of fees, the fee levels applied to each type of service, in accordance with legal regulations, and must be publicly listed at payment agent points and on the agent's website (if available).

(6) The principal and the agent must commit to protecting customer information in accordance with the Law on Credit Institutions, implementing guidelines, and other relevant legal provisions.

(7) The principal is allowed to sign payment agency contracts with other organizations nationwide. The number of payment agent points by other organizations must ensure that the number of payment agent points in district-level areas (excluding districts, district-level towns, provincial-level cities, and cities under central government) in the provinces and centrally-run cities account for over 70% of the total number of principal’s payment agent points.

(8) The number of payment agents who are credit institutions or branches of foreign banks is determined by the principal according to its management capacity; the number of payment agent points of credit institutions or branches of foreign banks is determined by the credit institutions or branches of foreign banks based on their operational network.

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