On April 29, 2025, the government of Vietnam promulgated Decree No. 94/2025/ND-CP with regulations on a controlled “sandbox” for innovative fintech solutions in the banking sector (Decree 94). The decree aims to promote innovation, modernize banking, and enhance financial inclusion while assessing risks and benefits of fintech solutions in a controlled testing environment. Fintech Sandbox Currently, the fintech sandbox focuses on three specific areas: Credit scoring Open API data sharing Peer-to-peer (P2P) lending Eligible participants for the fintech sandbox include: Credit institutions and foreign bank branches (except for P2P lending) Fintech companies operating in Vietnam Cross-border supply by foreign providers is not included in the sandbox framework. Eligible participants are permitted to provide fintech solutions only within the scope specified in the Certificate of Sandbox Participation issued by the State Bank of Vietnam in consultation with other ministries. P2P lending companies face specific restrictions within the fintech sandbox, including prohibitions against: Providing security for customer loans Operating as a customer (i.e., P2P lender or borrower) Providing P2P lending solutions to pawn shops The maximum sandbox period is two years, with the possibility of extension as permitted by law. The outcomes of the fintech sandbox will serve as a practical basis for authorities to develop and refine future fintech regulations. It is worth noting that participation in the sandbox does not guarantee that participants will meet relevant business and investment conditions that may be stipulated in future regulations. Decree 94 will take effect on July 1, 2025, signaling that the Vietnamese government intends to take a proactive approach to fostering fintech development. Implications Parties interested in participating in the fintech sandbox should begin preparing now to be ready to apply for a Certificate of Sandbox Participation when the decree takes effect.

Attorneys from Tilleke & Gibbins have updated the latest edition of Doing Business in Thailand, a Q&A-style guide from Thomson Reuters Practical Law that offers an overview of key legal considerations for companies operating in jurisdictions worldwide. The contribution outlines the country’s legal and regulatory framework for foreign investment and business operations and reflects the latest legislative developments. The chapter addresses the following core topics: Legal system: Structure of the courts and the codified nature of Thai law. Foreign investment: Business restrictions under the Foreign Business Act, sector-specific regulations, exchange control rules, and investment incentives. Business vehicles: Overview of partnerships, private and public limited companies, and other legal entities. Employment: Labor protections, employment contracts, foreign worker requirements, and termination procedures. Tax: Corporate and personal income tax, indirect taxes, and tax obligations for residents and non-residents. Intellectual property: Registration and enforcement of patents, trademarks, designs, and copyrights. Data protection: Key provisions of the Personal Data Protection Act and related compliance obligations. Competition law: Regulatory framework under the Trade Competition Act. Anti-bribery and corruption: Relevant legislation and enforcement mechanisms. E-commerce and digital business: Legal regime for online transactions and digital platforms. Marketing and advertising: Consumer protection laws and regulations affecting advertising and marketing practices. Product regulation and liability: Safety standards, liability regimes, and roles of enforcement authorities. Practical Law, a legal reference resource from Thomson Reuters, publishes a range of guides for hundreds of jurisdictions and practice areas. The insurance and reinsurance guide is a valuable resource for legal practitioners, covering numerous jurisdictions worldwide. To view the latest version of the guide, please visit the Practical Law website and enroll in the free Practical Law trial to gain full access.

To foster foreign investment and attract leading international universities to establish campuses in Vietnam, the government has recently adopted several regulations, including Decree No. 124/2025 on foreign cooperation and investment in the field of education, Decree No. 125/2024 on regulatory requirements for educational investment and operation, and Decision No. 452/QD-TTg approving the Planning of the Network of University and Teaching Institutions for the Period 2021–2030, with a Vision to 2050 (the “University Network Plan”). However, foreign investors and private higher educational institutions must still navigate regulatory complexities, build strong academic reputations, and ensure financial sustainability to compete effectively in an increasingly competitive landscape. Below are highlights of recent developments in university-related regulations that may open new opportunities for foreign investment in Vietnam. Adopting the University Network Plan The University Network Plan encourages the development of private higher education institutions (“HEIs”), especially not-for-profit ones, and welcomes top foreign HEIs to open their own foreign branch campuses (“FBCs”) in Vietnam, with the following targets. Until 2030: Encouraging new establishment and expansion of the network of private HEIs (including their branch campuses) and FBCs of top foreign HEIs, especially those offering training majors of science, engineering, and technology. Developing regional HEI networks along economic corridors centered on large cities—not only the traditional economic hubs of Hanoi and Ho Chi Minh City, but also other provinces and cities throughout the country such as Hai Phong, Nghe An (Vinh), Thanh Hoa, Hue, Da Nang, Khanh Hoa (Nha Trang), Binh Đinh (Quy Nhon), Dak Lak (Buon Ma Thuot), Lam Dong (Da Lat), Binh Duong, and Can Tho. Vision to 2050: Increasing the number and proportion of private HEIs, especially not-for-profit ones. Having private HEIs account for about 50% of learners. Requirements for Foreign Investment in Higher Education Foreign investors can engage in higher education business

In recent years, Vietnam has positioned itself among the leading countries in the world in terms of digital asset ownership and trading volume. This rapid adoption reflects the country’s growing digital economy and the increasing engagement of individuals and businesses in blockchain-based financial activities. Central to this growth are Resolution No. 57-NQ/TW of the Politburo dated December 22, 2024, on breakthroughs in science, technology, innovation, and national digital transformation with a vision to 2045 (“Resolution 57”) and Resolution No. 03/NQ-CP of the Government dated January 9, 2025, promulgating the Action Plan to Implement Resolution 57 (“Resolution 03”), which outline a flexible and innovative policy framework that embraces pilot programs for emerging technologies to lay the groundwork for Vietnam’s legislative framework concerning cryptocurrency and blockchain technologies. Regulatory clarity in terms of digital assets and blockchain technologies is now more critical than ever for businesses and investors. In light of this, Vietnam is currently in the process of introducing three key legal instruments, with drafts of the Law on Digital Technology Industry (“Draft DTI Law”), Resolution of the National Assembly on the Establishment of Regional and International Financial Centers in Vietnam (“Draft Financial Center Resolution”), and Resolution of the Government on the Pilot Implementation of Crypto Asset Markets in Vietnam (“Draft Crypto Pilot Resolution”) nearing promulgation. Current Regulatory Direction and Schedule Vietnam’s regulatory framework for crypto assets and blockchain has been in a developmental stage since 2017, focusing on directions, plans, and schedules rather than established regulations. In February 2024, under Decision No. 194/QD-TTg of the Prime Minister, the Ministry of Finance (MOF) was assigned to draft a legal framework to either prohibit or regulate virtual assets and service providers by May 2025, signaling a clearer regulatory direction. In March 2025, Directive No. 05/CT-TTg of the Prime Minister directed the MOF