Inside Vietnam's Passkeys: SBV mandates biometric authentication after $744M in fraud losses. Bank rollout status and enterprise lessons.

Vincent
Created: January 8, 2026
Updated: January 9, 2026

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Vietnam's banking and payments industry is undergoing a rapid transformation. In 2024 the State Bank of Vietnam (SBV) introduced Decision No. 2345/QD‑NHNN, a regulation that requires biometric authentication for high‑risk transactions starting July 1 2024. The mandate is a response to soaring online fraud: victims lost roughly $744 million in 2024. Multi‑factor authentication via SMS one‑time passwords (OTP) remains prevalent, but regulators determined that knowledge‑based codes were too easy to phish. The SBV is therefore pushing banks and e‑wallet providers toward passwordless, biometric‑backed authentication. Early signs suggest that the shift is already paying off: by mid‑2024 tens of millions of Vietnamese banking accounts were enrolled in biometric systems.
User sentiment is also evolving. A VinCSS report on Vietnamese banking apps found that biometrics are now the most commonly used authentication method for high‑risk transactions and that a majority of respondents rate them the most convenient. Despite this, roughly one in three respondents worry about their biometric data being stolen or faked. The report argues that these fears often confuse “biometrics as a password” with biometrics as a local unlock for a FIDO passkey. In the FIDO model a private key is stored locally and only unlocked by a biometric match, meaning the biometric never leaves the device. VinCSS’s overarching recommendation is to combine biometrics with FIDO2 passkeys, noting that passkeys are rapidly saturating the market as part of a mandatory compliance sprint.
Vietnamese financial institutions and payment services have reacted differently to the new mandate. Below is a snapshot of the major players as of late 2025.
Status: Live
Vietcombank adopted biometric authentication for high‑risk transactions ahead of the July 2024 mandate.
Status: Live
Techcombank connected its banking apps directly to the national population database.
Status: Live
ACB rolled out facial authentication in the ACB ONE app pursuant to SBV Decision 2345 and Circulars 17/2024 & 18/2024.
Status: Facing implementation challenges
Foreign banks have faced complexity adapting to the mandate.
Status: Planned for 2026
Under SBV Circular 41/2025, e‑wallet providers must verify customers’ identity and biometric data in person or through approved remote procedures before activating wallets.
Status: Live (hardware)
VinCSS launched the country’s first FIDO2 security keys.
Vietnam’s digital economy has exploded in recent years, but so have fraud losses. In 2024 victims collectively lost approximately $744 million to online fraud. Attackers exploited weaknesses in SMS‑based OTP flows and launched voice‑bot phishing campaigns to trick users into revealing codes. The SBV recognized that Smart OTP - a soft token generated in the bank’s mobile app - is still a shared secret and therefore susceptible to phishing.
In December 2023 the SBV issued Decision No. 2345/QD‑NHNN, which mandates biometric authentication for specific categories of transactions. The regulation came into effect on July 1 2024 and requires:
"Any FIDO authentication solutions... must be certified by an organization recognized by the FIDO Alliance."
Circular 50/2024/TT-NHNN
In practice this means that the bank’s identity check now combines possession (the chip ID card), inherence (a biometric) and - increasingly - a FIDO passkey bound to the device. Decision 2345 was followed by Circular 50/2024/TT-NHNN governing biometric processes, and by 2025 its scope expanded to corporate accounts. Institutions that fail to meet the deadlines risk suspension of services.
The scale of Vietnam's biometric enforcement is unprecedented. On September 1, 2025, the SBV deactivated over 86 million bank accounts - representing 43% of all accounts in the country (86M of 199M total) - for failing to complete biometric verification (Vietnam News, Human Rights Foundation).
The fallout has been severe:
Foreigners locked out entirely: "Their app's AI can't recognise the faces of foreigners," reported one user on Reddit r/VietNam. Another thread with 220+ comments titled "What on earth is going on with banking for foreigners?" describes banks freezing accounts "at a whim" (Reddit). Expats abroad face an impossible choice: fly back to Vietnam or lose access to their funds.
E-wallets abandoning foreigners: MoMo, Vietnam's largest e-wallet, effectively stopped working for foreigners after the biometric rules took effect. "It feels like foreigners are being forced out of these apps," complained one user.
Deepfakes bypassing facial biometrics: Despite the draconian enforcement, fraudsters are already circumventing the system. In May 2025, Vietnamese authorities busted an AI-powered money laundering ring using deepfake face scans to bypass biometric verification, highlighting how AI deepfakes and mule accounts continue to fuel fraud losses.
This is precisely why Biometric Update recommends Vietnamese banks adopt FIDO passkeys: facial biometrics alone are not phishing-resistant. A passkey cryptographically binds authentication to the legitimate domain, making deepfake attacks irrelevant.
Vietnam's digital transformation hinges on a national population database. Since 2021 the government has issued chip‑based ID cards that embed photographs, QR codes and digital signatures. Authorities are linking this database to banks and public agencies to streamline online services. To ensure the system's integrity the central bank is forcing banks to validate customer records against biometrics captured through chip IDs and the VNeID platform; more than 120 million verification requests have already been processed. Beginning January 1 2026 domestic customers must primarily present a chip‑based ID card or a Level 2 electronic ID for banking services. The measure aims to improve data accuracy and fraud prevention.
Biometric rules extend beyond banks. Circular 41/2025 requires all e‑wallet providers to verify customers’ identity documents and biometric data before activating a wallet. Foreigners who cannot be physically present may complete verification through authorised third‑party channels. As of March 31 2025, Vietnam had licensed 47 e‑wallet providers, including MoMo, Viettel Money, ZaloPay, ShopeePay and VNPAY. The goal is to tie mobile payments tightly to the national digital identity infrastructure and eliminate anonymous wallets.
Circular 41/2025 also raises the monthly transaction limit for essential services (like electricity and water) to 300 million VND, facilitating higher-value digital payments.
Unlike Japan, where Windows desktops dominate professional environments, Vietnam’s financial services ecosystem is overwhelmingly mobile‑first. StatCounter data show that as of December 2025 Android accounted for roughly 78% of the mobile operating system market while iOS held ~21 %. By vendor the top devices were Apple (42.71 % share), Samsung (21.99 %), Oppo (13.56 %) and Xiaomi (10.37 %) data. This fragmentation means banks must support a wide range of Android OEMs with varying biometric sensors and browser implementations. It also suggests that cross‑device flows - for example using a phone’s biometric sensor to unlock a passkey for desktop login - will be critical because many consumers still access banking websites via desktop browsers.
Passkeys rely on WebAuthn and CTAP2 support in browsers. On Android, Chrome and Samsung Internet now support passkeys, but OEM‑specific browsers may lag on API updates. iOS Safari and Chrome offer built‑in iCloud passkey sync, but Apple’s market share is lower than in Japan. Local browser Cốc Cốc (~4.4% share) also requires specific testing. Developers should test flows on older Android versions and less‑common browsers to ensure that passkey creation prompts appear correctly. They should also implement cross‑device mechanisms - such as QR‑code flows or Bluetooth proximity - to let users with only mobile passkeys sign into desktop sessions.
Many Vietnamese enterprises operate in controlled networks with proxy servers and strict firewall rules. These policies can block FIDO metadata downloads or Google’s passkey attestation endpoints. Early deployments have run into issues where WebAuthn requests time out if metadata cannot be fetched. To mitigate this, banks should pre‑cache metadata or use offline attestation formats and ensure that their security policies allow outbound connections to FIDO infrastructure.
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Real‑world deployments in Vietnam highlight several challenges.
Customer onboarding bottlenecks (The "NFC Wall"). The requirement to read the chip-based ID card (CCCD) via NFC has proven to be the single biggest friction point. Users frequently fail to scan because of thick phone cases, dirty chips, or, uniquely, placing the card on metal tables, which causes NFC interference. "Lỗi quét CCCD" (CCCD scan error) became a top search term in mid-2024.
The "10-Fail" Lockout Trap. Banks like Vietcombank have introduced strict anti-fraud rules where 10 consecutive biometric failures (e.g., FacePay errors) result in a feature lockout, requiring a branch visit to unlock. For users with aging phone sensors or poor lighting, this turns a "security feature" into a "denial of service."
Legacy system limitations. Foreign banks such as HSBC and UOB struggled because their core systems lacked integration with Vietnam’s biometric API. This resulted in incomplete coverage and temporary service disruptions. Banks should audit their authentication stacks and invest in modern identity platforms that support FIDO and biometric verification.
Verification errors. Early integrations with the national population database produced high rejection rates due to data mismatches. Banks that aligned their APIs with the government's QR‑code authentication service saw significant improvements in verification accuracy. This underscores the importance of meticulous data mapping and API testing.
User experience and accessibility. In the VinCSS user study, one in six users said that biometric scanning tools on banking apps were “not smooth”. Elderly customers overwhelmed service desks in late 2024 because they were unfamiliar with biometric technology. Products need fallback flows and clear instructions, and support for assistive technologies such as screen readers.
Fragmented hardware. Android devices vary widely in sensor quality and security chip availability. Some low‑end phones lack secure enclaves to store passkeys, forcing banks to fall back to server‑side biometrics or OTPs. Developers should implement device capability checks and provide alternatives such as hardware security keys (e.g., VinCSS FIDO2® Touch 1) for users with incompatible devices.
Foreigners systematically excluded. Current facial recognition systems are trained predominantly on Vietnamese faces. Multiple Reddit threads document foreigners being told the "AI can't recognise" their faces, forcing them to rely on branch visits - or worse, losing access entirely when abroad. Banks serving international customers must implement fallback authentication paths.
Deepfake vulnerability. Server-side facial biometrics are now being bypassed by AI-generated deepfakes. Vietnamese police have already busted money laundering rings using fake face scans. This is the core argument for passkeys: even if a deepfake fools a facial recognition camera, it cannot forge a cryptographic signature bound to a specific device and domain.
Adopt passkeys to complement biometrics. Biometrics alone are not enough; they must unlock a cryptographic private key stored on the user’s device. Implement FIDO2 passkeys so that the biometric data never leaves the device and cannot be intercepted. Encourage users to upgrade from Smart OTP to passkeys by highlighting reduced friction and phishing resistance.
Integrate with the national ID infrastructure. Align your banking APIs with the government’s QR‑code authentication service to reduce verification errors. Ensure that your system can read chip‑based IDs via NFC and validate VNeID Level 2 credentials. Pre‑cache attestation metadata to operate in restricted network environments.
Educate customers. Communicate the differences between biometric verification and passkey unlocking. Provide clear instructions for updating chip‑based IDs, registering biometrics and adding passkeys. Proactively warn users about scams that exploit the biometric update process.
Offer hardware alternatives. Not all devices support on‑device passkeys. Support external authenticators such as security keys. The VinCSS FIDO2® Touch 1, for example, lets users authenticate with a simple touch and eliminates the need for SMS OTPs.
Plan for multi‑device and cross‑platform flows. Provide QR‑code or Bluetooth‑based cross‑device sign‑in so that users can authenticate on a desktop using a passkey stored on their phone. Test your flows across different Android OEMs and browsers.
Monitor performance and iterate. Track metrics such as authentication success rates, fraud rates and customer support load. Early adopters like Vietcombank have demonstrated that biometric adoption can reduce fraud and increase customer trust. Use these insights to refine your roll‑out strategy.
Corbado's adoption platform helps banks and fintechs deploy passkeys quickly and comply with Vietnam's new regulations. Our platform offers:
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