Two markets on two different paths
Vietnam and the Philippines are two Southeast Asian retail payment markets built on different foundations. Vietnam built its system on the bank account. Its instant rail, NAPAS 247, and its VietQR standard encode an account number, not a wallet ID. The Philippines built its system on e-money, with GCash and Maya. These two wallets have signed up tens of millions of people the banks had never served. The two foundations differ in legal nature. One is a deposit on a bank's balance sheet. The other is an e-money balance issued by a company that is not a bank.
What the two markets do share is the staying power of cash in retail. Cash on delivery remains the fallback payment method for e-commerce. A merchant setting up in either country therefore has to run three channels at once, and each one reconciles differently. The first is the domestic instant rail. The second is the dominant wallet. The third is cash collected at the buyer's door.
| Vietnam | Philippines | |
|---|---|---|
| Authority | State Bank of Vietnam (SBV) | Bangko Sentral ng Pilipinas (BSP) |
| Legal basis | Decree 52/2024/NĐ-CP, effective July 1, 2024 | National Payment Systems Act (Republic Act No. 11127), 2018 |
| Retail instant rail | NAPAS 247 (2016) | InstaPay (2018) |
| Batch rail | IBPS, operated by the SBV | PESONet (2017) |
| Final settlement | IBPS (SBV) | PhilPaSS / PhilPaSS+ (BSP, 2002) |
| National QR standard | VietQR (2021), running on NAPAS 247 | QR Ph (2019), running on InstaPay |
| Domestic card scheme | NAPAS chip card, VCCS standard, BIN 9704 (2018) | No domestic card scheme |
| Operational governance | NAPAS, a joint-stock company 49% owned by the SBV | PPMI writes the rules; BancNet and PCHC run the systems |
| What drove adoption | The bank account and its QR code | The e-money wallet |
Vietnam: NAPAS, the unavoidable switch
NAPAS, the National Payment Corporation of Vietnam, handles switching and clearing for Vietnamese retail payments. Every local integration runs through its systems. The State Bank of Vietnam owns 49% of its share capital, and the country's large commercial banks hold the rest. That ownership puts the operator and the regulator in the same boardroom. It explains why infrastructure decisions are carried out so quickly, and why no private company has built a competing rail.
- NAPAS 247 (2016): 24/7 instant interbank transfers, with 68 member institutions and more than 80 million connected customers. It processed 8.9 billion transactions in 2024, up 33.8% year over year (NAPAS).
- VietQR (2021): the national QR standard, running on NAPAS 247. It accounts for about a third of the rail's volume. Nearly 90 million accounts were paying by scan in October 2025, with volume up 52% and value up 85% year over year (NAPAS).
- NAPAS domestic chip card (2018): the national VCCS chip standard and BIN 9704, mandated by the SBV to move off the magnetic stripe and keep routing in the country. More than 20,600 ATMs and 741,000 POS and mPOS terminals are connected (NAPAS). The card works with Apple Pay and Tap to Phone.
- VIETQRGlobal: cross-border QR acceptance, launched with Thailand, Laos, and Cambodia, then extended to China on December 2, 2025, together with UnionPay International, ICBC, and Vietcombank (NAPAS).
A first-generation VietQR code encodes the bank ID, the payee's account number, sometimes the amount, and a free-text memo. It carries no merchant ID. The payment therefore reaches the merchant's account as an ordinary incoming transfer. Matching it to the order depends on the memo, which the payer types in. If the payer deletes or edits the memo, the merchant is left with a transfer it can no longer match to an order automatically.
Vietnam: wallets, aggregators, and licenses
E-wallets play a smaller role in Vietnam than in Indonesia or the Philippines. Small in-person payments go through VietQR, whose underlying instant transfer is free for the payer. Wallets have therefore moved into services the bank rail does not provide: loyalty, short-term credit, ticketing, mobile top-ups, and recurring bills. Whatever the use case, they are licensed under the regime for intermediary payment services.
Vietnam overhauled its legal framework for cashless payments in 2024. Decree 52/2024/NĐ-CP of May 15, 2024, effective July 1, 2024, replaces Decree 101/2012/NĐ-CP. It introduces a definition of e-money that covers both wallets and prepaid cards. Circular 40/2024/TT-NHNN of July 17, 2024, sets out the operating details: licensing conditions, know-your-customer obligations, and limits. It lists four intermediary payment services. A foreign company can offer them only through a local holder of the relevant license.
| Service | What it allows | Typical license holders |
|---|---|---|
| Electronic clearing | Financial switching and interbank clearing | NAPAS, the only license holder |
| E-payment gateway | Routing a transaction to the payer's bank or wallet | VNPAY, OnePay, Payoo, MoMo, ZaloPay |
| Collection and disbursement support | Collecting on a merchant's behalf, then paying the funds out to it | Aggregators and wallets |
| E-wallet | Issuing and holding a prepaid balance in the customer's name | MoMo, ZaloPay, Viettel Money, VNPAY |
Philippines: InstaPay, PESONet, and three-tier governance
Philippine payment governance is split across three tiers: supervision, rulemaking, and operations. That separation sets it apart from most Asian rails. The Bangko Sentral ng Pilipinas sits at the top and sets the framework. The National Payment Systems Act, Republic Act No. 11127, signed into law on October 30, 2018, requires every payment system operator to register with it. Rulemaking is delegated to an industry association, Philippine Payments Management, Inc. (PPMI), designated as the Payment System Management Body. Private operators run the systems.
| Criterion | InstaPay | PESONet |
|---|---|---|
| Launched | 2018 | 2017 |
| Mode | Instant credit transfer, 24/7 | Batch credit transfer, in settlement windows |
| Cap per transaction | PHP 50,000 for an individual; PHP 500,000 for a registered business since July 29, 2026 | No scheme limit |
| Funds availability | A few seconds | Same banking day or next business day, depending on the window |
| Typical use | Merchant payments, P2P transfers, wallet top-ups | Payroll, supplier payments, high-value collections |
| Clearing | Switch operated by BancNet | Philippine Clearing House Corporation |
| Challenge | No chargebacks: the credit is irrevocable | No chargebacks |
The transaction amount decides which rail a merchant can use. An order above PHP 50,000 paid by an individual cannot go through InstaPay. It moves to PESONet, which takes anywhere from a few hours to one business day, or to a card. The July 2026 limit increase applies only to registered businesses. The constraint on payments by individuals is unchanged.
Philippines: QR Ph, GCash, and Maya
QR Ph is the national QR standard. It is EMVCo-compliant, runs on InstaPay, and was launched in 2019 under the authority of the BSP, together with PPMI. A regulatory mandate made it replace proprietary codes, as Indonesia did with QRIS and Malaysia with DuitNow QR. The Paleng-QR Ph program extended acceptance to public markets and local transport. In mid-2022, the BSP counted 473,000 merchant locations and 17 institutions participating on the merchant side.
Since 2024, the scheme has been split in two. QR Ph now means person-to-merchant payments, where the merchant pays the fees, not the payer. InstaPay QR means person-to-person transfers, which may still carry a fee depending on the institution and the account type. The number of accepting merchants grew 148.7% in 2024 (BSP). The two names thus cover two pricing regimes on the same instant rail: one paid by the merchant, the other by the payer, on their institution's terms.
- Payment system operator registration with the BSP under Republic Act No. 11127 (2018): required for anyone who operates a system, not just for those who participate in one.
- Non-bank e-money issuer license (EMI-NBFI): the three-year moratorium was lifted on December 16, 2024, under Monetary Board Resolution No. 1400 of December 5, 2024. BSP Circular 1166 (2023) sets minimum capital at PHP 200 million for a large-scale issuer and PHP 100 million for a small-scale one.
- Digital bank license: moratorium lifted as of January 1, 2025, with a cap of ten banks in the market.
- Virtual asset service provider: a separate regime, used among others by the Coins.ph entities that issue PHPC.
- Project Agila, a wholesale central bank digital currency proof of concept launched in 2022, ended without going into production. Cite it as a closed pilot, not a live system.
The real cost of cash on delivery
Cash on delivery means the carrier collects the price in cash when it hands the parcel to the buyer. In both markets, it is a payment method in its own right, with its own chain of players, cash cycle, and losses. The carrier collects the cash at the door and takes it back to its depot. It pays the merchant after a contractual delay of several days, during which the logistics provider holds the sales proceeds.
Published market shares for cash on delivery vary so widely that they are useless as they stand, because they do not measure the same thing. A self-reported survey asks consumers what they prefer or have ever used, while a flow measure counts transactions actually recorded. For Vietnam, the 2025 TGM Research survey found that 35% of consumers prefer cash on delivery for online purchases. For the Philippines, the only measure with a published methodology is still the BSP's. It puts the digital share of retail payment volume at 57.4% in 2024, up from 52.8% in 2023. The rest of that volume is not broken down by instrument, so the share of cash on delivery cannot be derived from it.
- Refusal at the door: the order comes back, shipping both ways is lost, and the product may no longer be sellable.
- The cash flow gap: several days between delivery and payout, on all the revenue involved.
- Counterparty risk: a third-party logistics provider holds the cash and is rarely regulated as a payment institution.
- Cash handling: cash shortages, counterfeit notes, theft, and internal controls the carrier has to build.
- No data: no payment method on file, so no recurring billing and no usable fraud signal.
Remittances are an inbound rail first and a payment method second
Remittances are the funds that Filipino workers based abroad send to recipients living in the Philippines. The country receives one of the largest remittance flows in the world, and these transfers shape its retail payments. They are not a side income. For many households, receiving these funds is the main reason to have an e-wallet, and paying merchants comes second. A payment product that ignores inbound funds therefore covers only half the market.
| Request | Share | What it means for operators |
|---|---|---|
| United States | 39,7 % | Corridor dominated by digital players; Remitly, founded in Seattle in 2011, is especially strong here |
| Singapore | 7,3 % | Intra-ASEAN corridor, exposed to competition from instant payment links |
| Saudi Arabia | 6,6 % | Gulf corridor, served by long-established exchange houses |
| Japan | 5,0 % | Growing corridor with a large share of contract workers |
| United Kingdom | 4,6 % | Banked corridor with low transfer costs |
| United Arab Emirates | 4,6 % | LuLu Exchange operates at both ends of the corridor, with six reported branches in the Philippines |
| Canada, Qatar, Taiwan, Hong Kong | 3,5 %, 2,9 %, 2,8 %, 2,5 % | A long tail of corridors, each with its own leading players |
The Bangko Sentral ng Pilipinas breaks these flows down by the sender's type of work. In 2025, land-based workers sent $28.49 billion, up 3.4%. Sea-based workers sent $7.14 billion, up 2.9% (BSP). The two groups send on different cycles and through different channels, and seafarers send less often but in larger amounts.
Regional links: cross-border QR, Nexus, and Alipay+
Between 2020 and 2025, Southeast Asia built a web of bilateral QR links under the Regional Payment Connectivity initiative, signed by five central banks in November 2022 and since expanded to nine. These links let a banking app from one member country pay a national QR code from another. A traveler scans the local merchant's code with their home bank's app. Settlement takes place in local currencies through designated settlement banks, which reduces reliance on the dollar. Vietnam is connected to this web. The Philippines, although one of the founding signatories, is not linked to it by any bilateral QR connection.
| Country | Instant rail | QR standard | Measured size |
|---|---|---|---|
| Vietnam | NAPAS 247 (2016) | VietQR (2021) | 8.9B transactions in 2024, +33.8% (NAPAS) |
| Philippines | InstaPay (2018) | QR Ph (2019) | 4.8B InstaPay and PESONet transactions in 2025 (BSP) |
| Thailand | PromptPay (2017) | Thai QR Payment (2018) | 27.4B transactions worth ~$1.6T in 2025, +12.8% (Bank of Thailand) |
| Indonesia | BI-FAST (2021) | QRIS (2019) | 50.50M users and 32.71M QRIS merchants enrolled (Bank Indonesia, 2024) |
| Malaysia | DuitNow / RPP (2018) | DuitNow QR (2019) | 4.5B transactions worth $330B in 2025, +28.6% (PayNet) |
| Singapore | PayNow (2017) on FAST | SGQR (2018) | More than 45% of the account-to-account transfer market in 2025 |
| Cambodia | Bakong (2020) | KHQR (2020) | 1.325B transactions in 2025, 1.2× the 2024 volume (National Bank of Cambodia) |
Without a public link, a Philippine merchant cannot accept a regional visitor's domestic QR payment. A Thai or Malaysian tourist in Manila cannot pay by scanning with their home bank's app. Reaching those customers requires a private network. Alipay+, operated by Ant International, connects GCash, TrueMoney, Touch 'n Go, Kakao Pay, and about fifty other wallets to a shared acceptance network that it says spans more than 220 markets. Since September 2026, Alipay+ partner wallets can pay existing QR Ph codes directly. A Philippine merchant targeting regional customers therefore goes through that network, not through an agreement between central banks.
Accepting payments locally: a scoping checklist
In both Vietnam and the Philippines, local acceptance requires a partner established in the country. A card gateway run from abroad is not enough for either market. Cards are a minority payment method there, and the rails that carry the volume are domestic. Scoping therefore starts with the regulatory status under which the funds are collected. Choosing a provider comes after that.
- Vietnam: choose the intermediary service. Electronic payment gateway, or collection and disbursement support? Circular 40/2024/TT-NHNN treats them as two separate licenses, and a provider can offer only the services its own license lists.
- Vietnam: confirm which VietQR standard is implemented. First generation, reconciled on the transfer memo, or the merchant standard, with dedicated identifiers and refund handling.
- Vietnam: connect the domestic card. An international acquirer cannot reach BIN 9704 and the VCCS standard without going through NAPAS.
- Vietnam: plan for the thresholds. Biometrics above VND 10 million per transfer, and a monthly cap of VND 100 million on an individual wallet.
- Vietnam: treat cash on delivery as a financial channel. Payout contract, contractual payout delay, and controls on cash discrepancies.
- Philippines: determine your status. Participant in a system, or operator of one? Operators must register with the BSP under Republic Act No. 11127.
- Philippines: decide whether you will hold customer funds. Holding balances requires an e-money issuer license, whose moratorium was lifted on December 16, 2024.
- Philippines: accept QR Ph for merchant payments, knowing that the merchant pays the fees and the payer pays nothing.
- Philippines: route by amount. InstaPay below PHP 50,000 for individuals, PESONet above that, with a delay of a few hours to one business day.
- Philippines: evaluate Direct Debit PH for recurring payments, live since July 29, 2026, rather than building direct debit on top of push transfers.
Both markets share the same public-rail economics: using the rails is free or nearly free for the payer. The resulting acceptance cost for the merchant is far lower than for a card payment. Retail payment companies there make their money from credit, deposits, merchant data, and adjacent services rather than from acceptance fees. A business model imported from a card-dominated market and built on those fees does not work here.