PNJ and Vietnam Gold Payments: Decree 390/2026 E-Wallet Rules Explained

Overview

Decree 390/2026/NĐ-CP, signed on 16 October 2026 by Deputy Prime Minister Nguyễn Văn Thắng, amends Decree 24/2012 on gold trading and took effect the same day. It lowers the cashless payment threshold for gold transactions to VND 5 million per customer per day and broadens permitted methods beyond bank transfers to include cards and e-wallets. The change matters for Vàng Phú Nhuận (PNJ), listed on HOSE, which had previously asked the State Bank of Vietnam to clarify whether credit cards, e-wallets and intermediary payments were compliant.

Key Facts

• Decree 390/2026/NĐ-CP was signed on 16 October 2026 and took effect immediately, amending Decree 24/2012 on gold trading management.
• The cashless threshold falls from VND 20 million per customer per day under Decree 232/2025 (effective 10 October 2025) to VND 5 million per customer per day.
• The new wording requires payment by “non-cash payment instruments under the law on non-cash payments,” rather than only via customer and gold-business bank accounts.
• Decree 390 also removes the business-conditions requirement for jewellery and fine-art gold.
• PNJ had requested clarification on credit card, e-wallet and intermediary payments during consultation on the draft circular; the State Bank of Vietnam replied that methods not routed through payment accounts were non-compliant.
• Lương Ngọc Quang, legal lead at Bảo Tín Mạnh Hải, said e-wallet settlement leaves gold businesses unable to identify who actually paid.
• Phú Quý, Bảo Tín Mạnh Hải and Bảo Tín Minh Châu announced payment-method changes on 19 October 2026.

What Happened

The decree replaces the narrower framework of Decree 232/2025, which had effectively made bank transfer the only compliant channel for gold purchases above VND 20 million per day. Under the new text, any non-cash instrument recognised by Vietnam’s non-cash payment rules is acceptable, which on Lương Ngọc Quang’s reading includes bank transfers, debit cards, credit cards and e-wallets. The threshold is also four times lower, meaning far more routine gold purchases now fall inside the cashless requirement.

In practice, several gold businesses continue to reject e-wallet payments at or above VND 5 million. Quang’s explanation is operational rather than legal: when a buyer pays by bank transfer, the incoming instruction carries the payer’s full name, allowing the business to match the funds to the buyer. When payment arrives through an e-wallet or a card routed via a payment intermediary, the settlement to the gold business typically carries only a transaction code, so the seller cannot document that the payer is the buyer. The article does not state whether PNJ itself has changed its payment acceptance since the decree.

Market Context

PNJ closed at VND 19 on 20 October 2026, up 1.62% on volume of 4,180,800 shares, a modest positive session in the days following the decree. The stock sits in the Retail sector on HOSE, with gold-bar and jewellery retail economics sensitive to transaction friction and to the compliance cost of customer identification. The decree’s removal of business conditions for jewellery and fine-art gold widens the competitive field in the segment where PNJ generates most of its revenue, while the lower cashless threshold pushes more of its daily transaction flow into documented, traceable channels.

Strategic Significance

The strategic question for PNJ is not whether e-wallets are legal, but whether the company can build settlement and reconciliation processes that satisfy payer identification at scale. A national jewellery chain with centralised systems is better placed than independent shops to integrate wallet and card rails with know-your-customer records, which could convert a compliance burden into a share-gain opportunity as smaller rivals keep refusing wallets. The simultaneous removal of jewellery business conditions cuts the other way, lowering barriers for new entrants. For long-term holders, the decree shifts competitive advantage toward operators with the technology and audit trail to accept any non-cash method without breaching identification rules.

What to Watch

• PNJ’s next quarterly filing or annual report for disclosure on payment methods accepted and any change in transaction mix.
• State Bank of Vietnam guidance or a circular clarifying whether e-wallet and card-intermediary settlements satisfy payer identification.
• Announcements from PNJ, Phú Quý, Bảo Tín Mạnh Hải and Bảo Tín Minh Châu on revised payment policies after 19 October 2026.
• Evidence of new entrants in jewellery and fine-art gold following removal of business conditions.
• Daily trading volume and foreign-ownership filings for PNJ on HOSE as the market digests the regulatory change.