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From January 5, 2026, the use of credit cards to transfer funds, credit accounts, or top up e-wallets or payment accounts will be completely prohibited under Circular No. 45/2025/TT-NHNN.
This regulation marks a significant change in Vietnam’s cashless payment system and directly affects credit card users and e-wallet service providers.
On November 19, 2025, the State Bank of Vietnam issued Circular No. 45/2025/TT-NHNN, amending Circular No. 18/2024/TT-NHNN on bank card operations.
Article 8 of Circular No. 45/2025/TT-NHNN stipulates that:
Credit cards may only be used to pay for lawful goods and services or to withdraw cash in accordance with agreements, and may not be used to transfer funds or credit amounts into:
E-wallets
Payment accounts
Debit cards
Prepaid cards
Accordingly, from January 5, 2026, credit cards may no longer be used to top up e-wallets.
Under Clause 3, Article 3 of Circular No. 18/2024/TT-NHNN, a credit card is a spending instrument based on a credit limit granted by a bank, operating under a “spend first – pay later” mechanism.
A credit card is not a payment account and is not a money-storage wallet.
Main functions of a credit card include:
Paying for goods and services
Online shopping
Installment payments
Cash withdrawals (as agreed with the issuing bank)
International payments
The new regulation is not intended to restrict users, but rather to protect the financial and payment system, enhancing transparency and safety.
Credit cards represent borrowed funds (credit limits provided by banks).
E-wallets store the user’s actual money.
Allowing credit card funds to be transferred into e-wallets would blur the boundary between borrowed money and owned funds, creating significant systemic risks.
If not strictly controlled, the following fraudulent practices may occur:
Borrowing via credit cards → transferring to e-wallets → withdrawing cash.
Using e-wallets to conceal money flows.
Creating fake transactions or circular fund flows to exploit promotions.
The prohibition strengthens transparency and ensures compliance with anti-money laundering regulations.
If credit cards could be used to top up e-wallets:
Users may overestimate their actual financial capacity.
Overspending beyond repayment ability could occur.
Accumulation of debt, high interest, and penalty fees would increase.
The ban promotes healthy credit usage and better consumer protection.
As e-wallets grow rapidly, allowing direct credit-based funding into wallets would:
Make it harder for banks to control money flows;
Increase systemic risks;
Complicate regulatory supervision.
The new rule helps ensure stability, safety, and transparency in Vietnam’s digital payment market.
Allowed:
Payment for goods and services
Online payments
International payments
Installment payments
Cash withdrawals as agreed with the bank
Not allowed:
Transferring money into e-wallets
Transferring funds to payment accounts
Topping up other cards
Credit cards can no longer be used to top up e-wallets.
Bank accounts or debit cards must be used instead.
Spending becomes easier to control, reducing credit risks.
Top-up methods must be adjusted.
Transaction verification processes must be strengthened.
Better control over credit risks.
Reduced fraud and loss of fee revenue related to cash withdrawals.
