Collecting wallet management fees and the story of user cash flow
From August 1st, users of VETC traffic e-wallets and Viettel Money accounts linked to ePass will begin to bear monthly account management fees.
According to the notice, individual customers must pay 6,600 VND/month/wallet, equivalent to 79,200 VND/year/wallet. For organizational and business customers, the fee is 66,000 VND/month/wallet, equivalent to 792,000 VND/year/wallet. The above levels include value-added tax (VAT).
Regarding the collection time, Viettel Money said that it will collect payment linkage fees on ePass from the 10th to the 20th of each month for individual customers; organizational and business customers are allowed to collect from the 5th to the 10th of each month. Meanwhile, VETC has not specifically announced the fee collection time.
The emergence of a new fee is receiving many opinions from users. Mr. Nguyen Ngoc Thanh, residing in Thanh Xuan, Hanoi, said that 6,600 VND per month is not a large amount of money for each driver, however, if multiplied by the number of vehicles using ETC services nationwide, the total amount collected is significant.
According to Mr. Thanh, BOT toll stations are the direct beneficiaries of the automatic toll collection system, so the operating costs of the system should be calculated from this revenue source, instead of continuing to transfer additional costs to users.
Meanwhile, according to Mr. Vu Minh Hai, residing in Dan Phuong, Hanoi, collecting 6,600 VND/month for all ETC accounts, including those who use less, is not really reasonable.
According to him, ETC accounts have similarities with bank accounts when users have to top up money in advance for payment. This cash flow is maintained on the system and can generate financial benefits for management units. Therefore, businesses should consider using this source of benefits to compensate for operating costs, instead of collecting additional periodic fees from users.
It's not like just announcing is allowed to collect fees
Talking to Lao Dong reporters, Lawyer Hoang Ha, Ho Chi Minh City Bar Association, said that current law does not prohibit organizations providing e-wallets from charging service fees.
According to the lawyer, point d, clause 1, Article 19 of Circular 40/2024/TT-NHNN, updated in Consolidated Document 76/VBHN-NHNN in 2026, stipulates that an agreement to open and use an electronic wallet must contain content on the type of fee, fee level, fee collection method and fee adjustment.
This regulation also allows the parties to agree on direct deduction of fees from wallets. Therefore, the law does not require businesses to request the State Bank for separate approval of each fee level such as 6,600 VND/month before application.
However, lawyer Hoang Ha emphasized that being entitled to collect fees does not mean that the specific fee is naturally legal in all cases.
For customers who have registered and used services before the new policy was applied, it is necessary to consider the terms in the initial agreement. In particular, it is necessary to determine whether the contract stipulates the right to adjust fees, notification methods and the rights of customers when they do not agree with changes or not.
According to the lawyer, Article 25 of the 2023 Law on Protection of Consumer Rights sets limits on businesses unilaterally changing contracts, general transaction conditions or service prices in a direction that affects consumer rights.
Regarding notification, Clause 1 and Clause 3, Article 27 of the 2023 Law on Protection of Consumer Rights require that general transaction conditions must be made public, creating conditions for consumers to research before transacting and only take effect when consumers are informed in advance.
Therefore, with a wallet management fee of 6,600 VND/month, it is necessary to compare the terms that customers have accepted when opening a wallet with the new policy announced by the business.
If the initial agreement clearly stipulates the fee adjustment mechanism, notification method and customer choice rights, businesses can implement according to the agreed mechanism without necessarily requiring customers to re-sign the contract each time there is a change.
Conversely, if the initial contract does not have a basis for adding a new periodic fee, the fact that the business only sends notifications about the new policy may not be enough to generate new payment obligations for customers.
Therefore, the legal issue is not only about whether VETC or a unit linked to ePass is allowed to collect fees or not, but also about how businesses establish agreements, notify changes and ensure consumer choice rights.
