Thailand’s Ministry of Finance has issued a royal decree placing the business of hire purchase and leasing of cars and motorcycles under the scope of the Financial Institution Business Act B.E. 2551 (2008), effective December 2, 2025. This is to ensure appropriate regulatory oversight of these business activities, as they function similarly to credit granting and serve as a source of funding for the public with a broad impact on the overall economic system and consumers at large. The business operators that this royal decree applies to include corporate entities engaging regularly in the business of hire purchase or leasing of cars or motorcycles, currently excluding: Financial institutions and specialized financial institutions. Individuals operating such businesses (noncorporate entities). Cooperatives. Key regulatory obligations of this royal decree include the following: Business operators must disclose interest rates, service fees, and other relevant business information to the public and report to the Bank of Thailand (BOT). Business operators must display how the annual percentage rate (APR), including all annual charges covering interest and service fees, is calculated. Business operators must maintain accurate accounting records in accordance with recognized accounting standards. The BOT may issue warnings or suspend operations if business operators fail to comply with this royal decree or act unfairly in a way that may result in serious harm to customers. Directors, managers, and responsible persons of any business operator that violates this royal decree may also be subject to the prescribed penalties. Before the royal decree takes effect, business operators should conduct internal assessments and engage with counsel to prepare for regulatory implementation. The BOT is expected to issue further subordinate regulations and guidance regarding: Interest, service fees, deposits, collateral, benefits, and penalties that may be charged by business operators. Contract content, methods of benefit calculation, and format in conducting

As from July 1, 2025, as part of its ongoing efforts to digitalize and streamline the delivery of public services, the Vietnamese government will officially conduct administrative procedures, both online and offline, only via electronic identity (“e-ID”) accounts on the VNeID platform. In particular: Online administrative procedures carried out via the National Public Service Portal or via information systems for administrative procedures at the ministerial or provincial level are required to be implemented by using e-ID accounts only. When receiving dossiers, authorities will be required to check and verify the e-IDs of companies or individuals responsible for conducting administrative procedures. Further, it is worth noting that to complete the registration of an e-ID account for a company, the legal representative of the company must hold a level-2 e-ID account. Compliance Considerations Vietnam’s first regulation of e-ID accounts for individuals and organizations was issued in Decree No. 59/2022/ND-CP dated September 5, 2022, on electronic authentication and identification. This decree was subsequently replaced by Decree No. 69/2024/ND-CP dated June 25, 2024, which governs the same matters. Registration and operation of e-ID accounts are centralized through VNeID, a digital ID app developed by the National Population Data Center under the Ministry of Public Security of Vietnam. Although the registration of e-ID accounts for companies is not explicitly mandated by law, the absence of an e-ID account may hinder companies from completing administrative procedures, including licensing and reporting obligations. Such non-compliance could consequently result in administrative penalties. To mitigate unexpected non-compliance and administrative fines due to the lack of an e-ID account, companies should be well prepared for and implement the registration of a company e-ID account as soon as possible.

Tilleke & Gibbins attorneys in Vietnam have contributed the 2025 edition of Doing Business in Vietnam, a comprehensive Q&A-style resource from Thomson Reuters Practical Law that provides essential insights for companies navigating business operations in Vietnam. The guide presents a detailed overview of the country’s legal framework and regulatory environment, reflecting recent updates in Vietnamese legislation and practice. This annually updated guide offers key information on the following areas: Legal system: Structure of the Vietnamese judiciary and the role of codified law. Foreign investment: Conditions for market access, licensing requirements, foreign ownership restrictions, and investment incentives. Business vehicles: Formation and operation of legal entities, including limited liability companies, joint-stock companies, and representative offices. Employment: Employment contracts, social insurance, labor rights, and procedures for hiring foreign nationals. Tax: Overview of corporate income tax, personal income tax, value-added tax, and other tax obligations. Intellectual property: Procedures for protecting and enforcing patents, trademarks, copyrights, and other IP rights. Data protection: Compliance requirements under Vietnam’s data privacy laws, including the Personal Data Protection Decree. Competition law: Antitrust rules and regulatory oversight under the Law on Competition. Anti-bribery and corruption: Legal framework and enforcement practices aimed at curbing corrupt activities. E-commerce and digital business: Regulations governing online platforms, digital content, and cross-border services. Marketing and advertising: Laws and guidelines on advertising standards and consumer protection. Product regulation and liability: Safety requirements, product liability issues, and roles of relevant authorities. Doing Business in Vietnam is part of Practical Law’s global series of legal guides designed to support international practitioners and businesses. To access the most recent edition of the Vietnam guide, visit the Practical Law website and sign up for a free trial.

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.