You have a Vietnamese SIM card in your phone, you have seen the QR codes everywhere, and you have downloaded MoMo, ZaloPay, or ShopeePay. Then you hit the registration wall: a passport upload that fails, a bank linkage step that asks for a document you do not have, or a KYC tier that quietly caps your account at a level that makes the wallet barely usable.
The friction is real, and it is not your imagination. Vietnam's e-wallet system was built for a domestic market of roughly 100 million people who all hold a citizen identity card (CCCD), a local bank account, and a long-term residence status. Foreigners are allowed to use these wallets, but the registration flow assumes you live here rather than visit.
The regulatory picture also changed recently. Circular No. 41/2025/TT-NHNN, issued by the State Bank of Vietnam on 5 November 2025, amended earlier rules on intermediary payment services and introduced mandatory biometric verification for e-wallet registration, effective from 1 January 2026.This guide walks through what that means in practice for foreign nationals, using only the requirements set out in the official regulatory framework.
Critical note on accuracy: This guide summarizes the regulatory framework as published by the State Bank of Vietnam. It does not list specific fee amounts, because those are set by individual e-wallet providers and are not specified in the official circulars. Always verify current fees, limits, and document requirements directly with the e-wallet provider or a local bank branch before you begin.
What Does Vietnamese Law Say About Foreigners Opening an E-Wallet?
The legal basis for e-wallet operations in Vietnam is Circular No. 39/2014/TT-NHNN on intermediary payment services, as amended by Circular No. 40/2024/TT-NHNN and subsequently by Circular No. 41/2025/TT-NHNN.These circulars set out the licensing requirements for e-wallet providers, the documents they must collect from customers, and the identity verification standards they must meet.
Under the earlier framework, foreign nationals applying to open an e-wallet were required to provide a passport along with an immigration visa or a document proving exemption from the immigration visa requirement.That requirement remains the foundation, but Circular 41 expanded the range of acceptable identification documents.
Specifically, Circular 41 broadened the scope of acceptable identification documents for individual customers who are foreign nationals. In addition to passports, foreign individuals may now submit other valid identification documents evidencing their personal identity as issued by competent foreign authorities when applying to open an e-wallet.This is a meaningful change, because it means a foreigner is not limited to a single document type if their passport is expired, being renewed, or otherwise unavailable at the time of registration.
Circular 41 also introduced a biometric verification requirement. E-wallet service providers must meet customers in person to verify their identity documents and verify biometric data before activating an e-wallet.For foreigners who are not physically present in Vietnam, verification can be conducted through a third party or a contracted organisation.That provision matters for anyone who is opening a wallet before arriving in the country.
Pro tip: The expansion to accept foreign-issued identity documents beyond passports is one of the most practical changes in Circular 41. If your passport is being renewed, ask the e-wallet provider whether your national ID card or another government-issued identity document from your home country is accepted for the KYC process.
Required Documents Checklist for Foreign Applicants
Based on the official regulatory framework, the following documents and information are required when a foreign national applies to open an e-wallet in Vietnam. Requirements may vary slightly by provider, so confirm with the specific wallet before you begin.
- A valid passport or another valid identification document evidencing your personal identity issued by a competent foreign authority.
- An immigration visa or a document proving exemption from the immigration visa requirement, applicable to foreign nationals under the Circular 39 framework as amended.
- A Vietnamese phone number registered in your own name for SIM verification and OTP delivery.
- A linked Vietnamese bank account in your name, which serves as the funding source for the wallet.
- Biometric data (facial verification) captured during the registration process, mandatory for e-wallet activation from 1 January 2026.
- The phone number registered on the e-wallet service application, which the provider is required to retain and verify.
- Transaction device information, including the unique identification of the device used for registration.
One point worth emphasizing: under the State Bank of Vietnam's foreign exchange rules, e-wallets in Vietnam operate in Vietnamese dong only. There is no path from a foreign-currency card or account directly into the wallet balance. You are funding a dong wallet from a dong bank account.
Official Registration Steps and Biometric Verification
The registration process follows a consistent sequence across the major e-wallet providers. Each step must be completed in order, and the biometric verification step is now mandatory before the wallet can be activated.
- Step one: Install the app and register with a Vietnamese phone number. The number must be registered in your own name and capable of receiving an OTP for verification.
- Step two: Submit your identification documents. Upload a clear image of your passport or another valid foreign-issued identity document accepted by the provider.The document must be valid and legible.
- Step three: Complete biometric verification. A facial verification is captured through the app. Under Circular 41, providers must verify biometric data before activating the wallet.For foreigners not physically present in Vietnam, verification can be conducted through a third party or contracted organisation.
- Step four: Link a Vietnamese bank account. The account must be in your name, and the name on the bank account must match the name on your identity document exactly. This is the step where most foreign applicants encounter difficulty, because opening a Vietnamese bank account typically requires a longer-term visa or residence status.
- Step five: Wait for verification. Verification usually takes one to three business days, and may extend to one or two weeks if document images are unclear or the bank account name does not match exactly.
The provider is required to retain your identification documents, biometric data, audio and video recordings, the registered phone number, device information, transaction logs, and the results of biometric matching. All of this must be stored securely and confidentially, and retained in accordance with anti-money laundering and electronic transaction laws.
Warning: The bank account linkage is the single largest barrier for foreign applicants. If you are on a short-term tourist visa, you will likely be unable to open the Vietnamese bank account required to fund the wallet. Plan accordingly before you begin the registration process.
Understanding KYC Tiers and Transaction Limits
Vietnam's e-wallet framework uses tiered KYC levels. The basic tier can be completed with a passport and allows limited functionality. The higher tier generally requires a CCCD, the Vietnamese citizen identity card, which foreign nationals do not hold.
This tier structure has a direct practical consequence. A foreigner who registers with a passport can open and use a wallet at the basic level, but will typically be capped below the transaction limits available to Vietnamese citizens who complete the higher tier.
On transaction limits, Circular 41 maintains the overall monthly limit of VND 100 million per customer per service provider for ordinary e-wallet transactions, while raising the limit to VND 300 million per month for payments related to essential services such as electricity supply.These limits apply to the wallet itself and are separate from any limits imposed by the tier system.
Under Circular 41, e-wallet providers are also prohibited from accepting cash deposits or allowing cash withdrawals at their locations. All transactions must go through linked bank accounts. The provision of credit for e-wallet users and the payment of interest on wallet balances are also banned.
This means your e-wallet is strictly a payment instrument connected to a bank account, not a standalone stored-value account. You cannot top it up with cash, and you cannot earn interest on the balance.
Which E-Wallet Should Foreigners Choose?
All three major wallets accept passports at the basic KYC level. The differences appear in the registration flow and the practical requirements for full functionality.
- MoMo: Accepts a passport at the basic level. Requires a Vietnamese SIM, facial verification, and a linked Vietnamese bank account for proper use. The higher KYC tier generally expects a CCCD, which foreigners do not have.
- ZaloPay: Requires a Zalo account, which is typically tied to a Vietnamese phone number, plus a Vietnamese SIM and a linked Vietnamese bank account. The passport option at signup is available at the basic level. The higher tier generally expects a CCCD.
- ShopeePay: Passport holders may register for a ShopeePay account according to the provider's official help documentation. However, in practice the activation process requires a Vietnamese bank account and the higher verification tier typically expects a CCCD linked to a 12-digit citizen identity number.
In practice, the choice between the three matters less than whether you can clear the two structural barriers: the Vietnamese SIM and the Vietnamese bank account. If you can obtain both, any of the three will work. If you cannot, none of them will function at full capacity.
Pro tip: The QR code system in Vietnam, known as VietQR, is interoperable across wallets and banks. If you can clear the KYC barriers on one wallet, you can typically pay any VietQR code, which means you do not need to register with multiple providers.
Common Rejection Reasons and How to Avoid Them
Most registration failures happen at the same three points. These are the issues that cause the highest volume of rejections for foreign applicants.
- Bank account name does not match the identity document. The name on your Vietnamese bank account must match the name on your passport or foreign-issued identity document exactly. Even a small difference in spelling, middle name order, or diacritics can cause a rejection.
- Blurry or incomplete document images. The uploaded images of your identity documents must be clear, fully visible, and free of glare. Verification times extend to one or two weeks when document images are unclear.
- Using a tourist visa to open a bank account. Opening a Vietnamese bank account typically requires a longer-term visa and residence status. A short-term tourist entry usually does not meet the requirements for account opening.
- Phone number not registered in your own name. The Vietnamese SIM used for registration must be registered in your own name with the carrier, matching the identity document you submit to the wallet provider.
- Attempting higher-tier KYC without a CCCD. The higher tier generally expects a CCCD, which foreign nationals do not hold. Do not expect to reach the top tier unless the provider offers a specific pathway for foreign residents.
Frequently Asked Questions
Q: Can foreigners legally open an e-wallet in Vietnam?
A: Yes. Circular 39/2014/TT-NHNN and its amendments, including Circular 41/2025/TT-NHNN, permit foreign nationals to open e-wallets using a valid passport or another valid identification document issued by a competent foreign authority. The wallet must be linked to a Vietnamese bank account, and biometric verification is now mandatory for activation.
Q: What documents do I need to register for MoMo, ZaloPay, or ShopeePay as a foreigner?
A: You need a valid passport or another valid foreign-issued identity document, an immigration visa or proof of visa exemption, a Vietnamese phone number registered in your own name, a linked Vietnamese bank account, and biometric data for facial verification. The bank account requirement is typically the hardest barrier for short-term visitors to clear.
Q: Can I use an e-wallet in Vietnam if I am only visiting on a tourist visa?
A: Technically the wallet can be registered at the basic KYC tier with a passport, but the practical barriers are significant. You need a Vietnamese bank account to fund the wallet, and opening one generally requires a longer-term visa or residence status. Most tourists will be unable to complete the full registration process.
Q: What is the transaction limit for a foreigner's e-wallet in Vietnam?
A: Circular 41/2025 maintains the overall monthly limit of VND 100 million per customer per service provider for ordinary e-wallet transactions, with an increased limit of VND 300 million per month for payments related to essential services such as electricity. Your actual limit may be lower depending on your KYC tier, and the basic tier available to passport holders is typically capped below the maximum.
Q: Why was my e-wallet registration rejected even though I uploaded my passport?
A: The most common reasons are a mismatch between the name on your bank account and the name on your passport, blurry or incomplete document images, or attempting to link a bank account that was opened with a visa type that does not meet the provider's requirements. Ensure that all names match exactly and that document images are clear and fully visible before resubmitting.
Disclaimer: Administrative regulations are subject to official policy updates. Always cross-check with the official immigration/government authority before final submission.