You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

March 15, 2024

Vietnam Revs Up Fintech Sector with Updated Draft of Sandbox Decree

Subscribe to Updates

Vietnam’s fintech industry is booming, and the rapid emergence of tech startups and non-bank institutions offering innovative financial services has been outpacing existing regulations. This regulatory gap not only creates uncertainty for both innovators and consumers, but also poses a number of imminent risks in areas such as consumer protection, data privacy, cybersecurity, and anti-money laundering, among others.

The State Bank of Vietnam (SBV) is stepping up to tackle these challenges by accelerating the promulgation of a long-awaited Fintech Sandbox Decree with the issuance of an updated draft (“Draft Fintech Sandbox Decree”) on March 4, 2024. The Draft Fintech Sandbox Decree establishes a controlled environment where fintech companies and financial institutions can test solutions that do not fall squarely within the parameters of existing regulations. The pilot activities will be limited in scope, scale, and duration, with a number of precautionary measures in place. The SBV will supervise this “sandbox” closely, effectively mitigating risks and gathering valuable data to inform future regulations.

Who Can Participate in the Sandbox?

  • Traditional financial institutions (credit institutions): Banks and other institutions licensed to provide financial services can participate in the sandbox to test new offerings or refine existing ones.
  • Independent fintech companies: Startups and established companies specializing in fintech solutions can leverage the sandbox to pilot innovative ideas before seeking wider market adoption.
  • Other relevant organizations involved in the pilot: Depending on the specific solution being tested, other entities may also be involved in the sandbox.
  • Geographical scope: Limited to Vietnamese territory; cross-border testing is not allowed.

Focusing on Three Solution Categories

Earlier versions of the Draft Fintech Sandbox Decree included categories like blockchain technology and other innovative business models, but these were removed in the latest version. To allow the SBV to assess the associated risks and work on the solutions more effectively, this version focuses only on the following three solutions:

  • Credit scoring: Fintech companies can pilot new credit scoring models to assess the creditworthiness of individuals or organizations.
  • Data sharing via Open Application Programming Interface (“Open API”): Secured data-sharing mechanisms using Open APIs can be tested within the sandbox.
  • Peer-to-peer lending (“P2P Lending”): Platforms that connect lenders and borrowers can be piloted in the sandbox.

Participation Conditions

Fintech companies must meet specific criteria depending on the solution they are piloting. The criteria will vary depending on the complexity and potential risks associated with the solution. For example, P2P lending platforms might face strict requirements on cybersecurity and network information security.

All participants must submit a registration dossier and obtain a Certificate of Participation from the SBV.

Monitoring and Risk Control

The SBV will closely monitor activities, evaluate participation, and assess the effectiveness of the piloted solutions, with a dedicated team to oversee activities within the sandbox, ensuring that participants comply with applicable regulations and that pilots are conducted safely and effectively.

Participating organizations are required to submit regular reports and provide ad hoc information on the pilot process, operational indicators, risks encountered, and the results of the pilot implementation to the SBV.

Customer Protection

Participating organizations have a responsibility to ensure customer rights and interests. This includes informing them about potential risks associated with using the piloted solution, obtaining their informed consent, and clearly outlining data privacy practices.

Participating organizations must implement robust security measures to safeguard customer data collected during the pilot program.

For dispute settlement, organizations are required to establish a customer complaint handling department and have clear mechanisms in place to address any disputes or complaints arising from the use of their piloted solutions.

Sandbox Conclusion

The pilot period will last a maximum of two years, with the SBV having the authority to adjust the length based on the actual implementation. After the pilot period, the SBV will decide on the next steps based on participating organizations’ reports, its own monitoring data, and any feedback received from relevant state authorities. Options will include terminating the pilot, certifying its completion, or extending the pilot period.

Participation in the Sandbox Mechanism does not guarantee an operating license or market approval for the piloted solutions.

Outlook

Once it is officially passed, it is hoped that the Fintech Sandbox Decree will usher in a new era of controlled experimentation in the sector, fostering a dynamic fintech ecosystem where innovation can thrive alongside robust regulations. By balancing innovation with consumer protection, cybersecurity, and data protection, it has the potential to transform Vietnam into a hub for groundbreaking fintech solutions, all while safeguarding the integrity of the financial system and consumers’ interests.

Now that the sandbox program has been streamlined to include only the three most prominent fintech solutions, the SBV might be able to speed up the official issuance of the Fintech Sandbox Decree.

Related Professionals

Industries

Technology

Practices

Banking and Finance

Location

RELATED INSIGHTS​ 

January 6, 2026
On December 30, 2025, Thailand’s Electronic Transactions Development Agency (ETDA) notified digital marketplace operators of a consolidated list of “high‑risk products” that are subject to strict monitoring on digital platforms. The list was jointly prepared by the Thai Industrial Standards Institute (TISI) and the Food and Drug Administration (FDA) to guide platform compliance in the initial phase of implementation of the Electronic Transaction Committee’s Notification on Other Measures for Marketplace for Goods with Specific Characteristics under Section 18(2) of the 2022 Royal Decree on Digital Platform Businesses Requiring Notification B.E.2568 (2025). The notice is addressed to operators of digital platform services that function as product marketplaces with specific characteristics laid out in the notification. The ETDA states that the TISI and the FDA are closely monitoring the high‑risk product categories on digital platforms, and the published list serves as the baseline reference for platform screening during the initial phase of the notification’s implementation. High‑Risk Product List The list aggregates categories of products that are illegal to sell online or are otherwise tightly regulated under Thai law, with an emphasis on health-related products, controlled substances, medical devices, and a wide range of industrial products that require certification or compliance with specified Thai Industrial Standards, as detailed below. Prohibited and tightly controlled health products. This includes all categories of modern medicines subject to control other than general household remedies; all categories of controlled herbal products except for over-the-counter herbal products; narcotics; psychotropic substances; and medical devices requiring use in medical facilities or a physician’s prescription. Selected industrial products requiring heightened controls. The list highlights dozens of TISI-regulated items commonly sold online. Examples include pacifiers, rice cookers, electrical wire, food wrap film, crayons, washing machines and dryers, air conditioners, electric cookers and air fryers, water heaters, microwave ovens, LED luminaires, hair dryers
Read More
January 5, 2026
On December 31, 2025, the government of Vietnam promulgated Decree No. 356/2025/ND-CP detailing and guiding the implementation of the new Personal Data Protection Law (PDPL) that was issued in June 2025. The new decree, like the PDPL, entered into force on January 1, 2026, with the previous Decree No. 13/2023/ND-CP on personal data protection ceasing effect on the same day. Some key points of the new decree include the following: Comprehensive lists of basic and sensitive personal data are provided, which will require companies to review again their existing documents and data type classification to ensure compliance. New timelines are established for responding to specific data subject requests. These timelines are more reasonable and longer than the previous 72-hour requirements. Additional consent guidelines are provided, prohibiting default consent or ambiguous instructions that confuse data subjects about giving or withholding consent. Mandatory content for data transfer agreements/clauses in particular cases is provided. This covers, among other things, (i) the legal basis for the transfer of personal data; (ii) responsibilities for personal data protection during the transfer and processing of personal data; (iii) responsibilities for ensuring the exercise of the rights of personal data subjects; and (iv) responsibilities for coordination and compliance of the parties in cases where violations of personal data protection regulations are detected. The qualifications and responsibilities of data protection officers (DPOs) and data protection departments include, among others, having been trained and fostered in legal knowledge and professional skills regarding personal data protection. There are no specific provisions governing the qualifications or requirements for organizations that provide data protection training or education. New mandatory templates and requirements are provided in relation to data processing impact assessment and data transfer impact assessment, and for cases in which companies need to re-submit assessments to the regulator. Stricter requirements are
Read More
December 30, 2025
On December 17, 2025, Laos’ Ministry of Industry and Commerce (MOIC) issued a notice introducing a new digital system that allows e-commerce businesses to obtain required certificates and licenses through an online, application-based platform. Notice No. 3988, which will take effect on February 1, 2026, introduces the E-Trust platform, a downloadable application that allows e-commerce businesses to remotely obtain acknowledgement certificates and business operating licenses. New Digital Registration Options Under the previous framework established by the Decree on E-commerce (2021), businesses were required to complete registration exclusively through paper-based submissions. The new system now offers businesses two registration options: Traditional paper-based process at the Division of E-commerce Management within the MOIC; or Electronic registration and renewal through the E-Trust platform. This change is expected to streamline procedures, reduce administrative burdens, and enhance accessibility for businesses operating outside Vientiane. The E-Trust platform facilitates compliance for both individuals and legal entities required to submit applications and renewals for required certificates and licenses. The development is particularly beneficial for businesses located in remote provinces, as it eliminates the need for physical travel and significantly accelerates processing times. Compliance Requirements and Penalties Businesses must obtain or renew the required certificates and licenses to avoid sanctions under the Decision on Fines and Other Measures for Violation of the Decree and Regulations on E-commerce (No. 2828/MOIC, dated November 11, 2025). Penalties for noncompliance may include monetary fines and other enforcement measures.
Read More
December 26, 2025
Thailand has granted ride-sharing platforms additional time to comply with new regulatory requirements, extending the compliance deadline to March 31, 2026 (replacing the previous deadline of October 2, 2025). The postponement was made official on December 18, 2025, when Thailand’s Electronic Transactions Development Agency (ETDA) published the second Notification Regarding Supervision of Ride-Hailing Platforms Classified as High-Impact Digital Platform Services under the Royal Decree on Digital Platform Service Businesses. The notification provides additional time for ride-sharing platforms and drivers to transition to full regulatory compliance. The extension replaces the effective date provision of the earlier notification and applies specifically to ride-hailing activities. Background The postponement responds to feedback from operators and driver groups regarding challenges converting private vehicles into legally registered public vehicles, including complex registration procedures, high compliance costs, and operational delays. The Department of Land Transport (DLT) is concurrently reforming its vehicle registration and driver verification processes to streamline operations. Given these issues, the Electronic Transactions Committee has deferred enforcement to provide an adjustment period for operators and drivers to meet compliance requirements. Ongoing Obligations While the effective date has been deferred, the substantive obligations imposed on ride-sharing platforms remain fully intact. Operators must continue preparing to comply with the additional duties applicable to high-impact digital platform services, beyond the general requirements under the digital platform services framework. Operators are expected to use the extended transition period to finalize operational and compliance readiness ahead of enforcement on March 31, 2026. Key focus areas include: Integration with DLT vehicle-registration systems Deployment of robust driver and passenger identity verification mechanisms Updates to platform terms of service, driver-onboarding standards, and internal operational policies Preparation for ETDA reporting obligations and future audit and review processes Next Steps While the postponement replaces the previous effective date with the new March 31, 2026,
Read More