Vietnam FinTech regulatory sandbox begins 1 July 2025
21 May 2025
On 29 April 2025, Vietnam issued Decree No. 94/2025/ND-CP (“Decree”) establishing a regulatory sandbox for testing new FinTech products, services, and business models within the banking sector (“Sandbox”).
This Alert provides an overview of the Decree which comes into effect on 1 July 2025.
Objectives
Financial regulatory sandboxes are controlled environments that allow financial institutions and FinTech startups to test innovative products or services with temporary regulatory flexibility, offering a safe space to experiment without the burden of full regulatory compliance.
The Decree states the objectives for establishing the Sandbox as:
- To promote innovation and modernisation of the banking sector;
- To create a testing environment to assess the risks, costs and benefits of FinTech solutions (“Solutions”);
- To support the construction and development of Solutions in accordance with market demands, legal frameworks, and management regulations; and
- To limit risks to customers when using Solutions provided by organisations participating in the Sandbox.
The Sandbox results will be used as a practical basis for competent state agencies to research, develop and complete the relevant legal framework and management regulations.
Eligibility
The Decree prescribes three Solutions eligible for testing under the Sandbox and the entities eligible to participate as set out below. The table below includes entities eligible to directly participate in the Sandbox by providing the Solutions as well as other entities eligible to participate and be involved in the Sandbox in other capacities.
|
FinTech solutions |
Scope of FinTech solution |
Eligible entities |
|
Peer-to-peer (“P2P”) lending |
|
Entities eligible to participate in the Sandbox to provide Solutions:
Other eligible entities related to the Sandbox:
|
|
Credit scoring |
|
Entities eligible to participate in the Sandbox to provide Solutions:
Other eligible entities related to the Sandbox:
|
|
Sharing data via open application programming interfaces (“Open API”) |
|
FinTech companies
The Decree defines a FinTech company as an organisation other than a credit institution or foreign bank branch with a licence to establish or having legally registered its business in Vietnam, that provides FinTech solutions either independently or through cooperation with credit institutions and foreign bank branches.
In order for a FinTech company to participate in the Sandbox, it must:
- be a legal entity lawfully established in Vietnam and not under any demerger, merger, consolidation, conversion, dissolution or bankruptcy process;
- ensure that its general director must (i) have at least a university degree in economics, business management, law, or information technology; (ii) have at least two-years’ experience as a manager in an institution in the financial or banking industry; and (iii) not be prohibited from holding a management position under applicable laws; and
- meet other conditions applicable to P2P lending companies mentioned below, if it seeks to participate in the Sandbox to provide P2P lending Solutions.
P2P lending companies
Entities seeking to participate in the Sandbox in relation to P2P lending must, at the time of registration and throughout its participation, be locally owned with its legal representative and general director being a Vietnam citizen and meeting certain conditions (including not holding managerial positions in a credit institution, foreign bank branch, or payment intermediary service provider).
Further restrictions are stipulated in relation to P2P lending Solutions, including prohibiting a P2P lending company from (i) conducting any other business not covered in its Sandbox registration; (ii) providing security for customers’ loans; (iii) operating as the customer; and (iv) providing P2P lending Solutions to pawn companies.
Participation in the Sandbox
The Decree stipulates that entities must obtain a registration certificate (“Certificate”) from the State Bank of Vietnam (“SBV”) in order to participate in the Sandbox and provide Solutions.
The Solution must meet the following criteria in order to be awarded a Certificate:
- Its technical and business contents have not been clearly and specifically regulated under current regulations;
- It is an innovative solution that brings benefits and added value to service users in Vietnam, especially solutions to support and promote the goal of financial universalisation;
- It is designed and built with (i) a risk management framework, limiting negative impact on the banking system and foreign exchange activities; (ii) a plan on handling and overcoming risks occurring during the testing process; and (iii) a plan to protect consumer rights;
- It has been fully reviewed and evaluated in terms of operation, function, utility and usefulness;
- It is a feasible solution that can be deployed to the market after the completion of the Sandbox; and
- If the Solution is a P2P lending Solution, it must meet specific criteria applicable to P2P lending.
The Certificate is initially valid for a maximum of two years; however, entities may apply for an extension, with a maximum of two extensions, each not exceeding one year. Extensions must be sought at least 90 days before the Certificate expires.
An entity may only provide Solutions within the scope set out in its Certificate. The scope can be adjusted, with SBV’s prior approval.
Sandbox participants are obliged to provide periodic reports and reports as requested. These reports should include information relating to the testing process, arising risks, and the results of the testing. SBV is able to request participating entities to build software and monitoring tools for this purpose.
SBV may issue a certificate of completion at the end of the Solutions’ testing period, upon determination of set factors, permitting the entity to officially launch its Solution.