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May 5, 2025

Vietnam Issues Fintech Sandbox Decree

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.

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